EPA/600/R-93/151
ApriM993
MEASURING POLLUTION PREVENTION PROGRESS
PROCEEDINGS
Coordinated by:
Center for Environmental Management
Tufts University
Medford, MA 02115
EPA Cooperative Agreement No. CR813481
Project Officers:
Harry M. Freeman
U.S. Environmental Protection Agency
Risk Reduction Engineering Laboratory
Cincinnati, OH 45268
and
Ann Rappaport
Center for Environmental Management
Tufts University
Medford, MA 02115
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OH 45268
Printed on Recycled Paper
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NOTICE
The papers in these Proceedings were presented at the workshop, "Measuring
Pollution Prevention", sponsored by Tufts University, Center for Environmental
Management and U.S. Environmental Protection Agency, on March 31, April 1 and 2,
1993, in Salem, MA. This publication has been reviewed in accordance with the U.S.
Environmental Protection Agency's review policies and approved for publication.
Approval does not signify that the contents necessarily reflect the views and policies of
the EPA, nor does mention of trade names or commercial products constitute
endorsement or recommendations for use.
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FOREWORD
The growing importance of pollution prevention as an environmental strategy
has increased pressure to develop systems for measuring achievements. The
Pollution Prevention Act of 1990 charges U.S. Environmental Protection Agency with
responsibility for developing national pollution prevention goals, and for devising a .
scheme for measuring national progress. Individual firms are under increasing
pressure, in part from the public disclosure of toxic release information required under
SARA Title III, to practice pollution prevention and to communicate successes to the
public. All of these activities must occur within a recognized frame of reference or
measurement scheme to be meaningful.
U.S. EPA's Risk Reduction Engineering Laboratory has identified pollution
prevention measurement as a high priority for research, and as a result has provided
support for this project, "Management Tools to Support Pollution Prevention", to be
undertaken cooperatively between the Pollution Prevention Research Branch and the
Center for Environmental Management of Tufts University.
These Proceedings from a 1993 Workshop provide the results of current
information on projects presently underway. Those wishing additional information on
these projects are urged to contact the authors or the EPA Project Officer.
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
in
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ABSTRACT
The workshop, "Measuring Pollution Prevention Progress", was held in Salem, MA,
March 31, April 1-2, 1993. The purpose of this Workshop was to present the latest
significant research and practical findings related to pollution prevention measurement
from ongoing and recently completed projects in industry, research and development
institutions, and governmental organizations.
These proceedings are organized into two sections, contain complete paper
presentations in the first section and brief and extended contributions in the second.
Subjects include the application of system analysis, system input and output
definitions, data handling, pollution prevention measurement types, financial aspects,
management practice, and participants' discussions and recommendations.
IV
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TABLE OF CONTENTS
Section A
PRESENTATIONS OF PARTICIPANTS
Pollution Prevention: The Importance of Measuring Progress
Jim Craig, U.S. EPA, Office of Pollution Prevention and Toxics .......... 2
Measuring State Pollution Prevention Program Effectiveness in the
Northeast: A Working Paper
Terri Goldberg, NEWMOA . . .......... 9
Polaroid's Toxic Use and Waste Reduction Program
Robert T. Hawes, Polaroid Corporation 23
Summary of Materials Accounting as a Tool for Measuring Progress
in Pollution Prevention
Shelley A. Hearne, New Jersey DEPE 27
Waste Reduction Measurement Project at IBM
Joel S. Hirschhorn, Hirschhorn & Associates, Inc 29
Textron's Effects to Ensure Integrity on Numbers
Patricia lezzi, Textron Inc 31
Financial Planning and Pollution Prevention
Raymond P. Lizotte, Jr., Texas Instruments Inc. 33
Source Reduction Through Total Quality Environmental Management
Richard F. Mannion, Foxboro Company 35
Voluntary Pollution Prevention and Opportunity Assessment
David McEntee, Simpson Tacoma Kraft Company 47
Measuring Progress in Pollution Prevention in Bristol-Mayers
George Nagle, Bristol-Mayers Squibb Co 49
Pollution Prevention
Robert B. Pojasek, GEI Consultants, Inc 50
Implementing and Tracking Waste Reduction Progress at DuPont
Randy Price, DuPont 52
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Normalized Measures of Pollution Prevention
Julie Roque, UCLA 54
U.S. EPA Region I Pollution Prevention Measurement Issues
Abby Swaine, U.S. EPA Region I 60
The Use of System Analysis for Measuring Pollution Prevention
Progress in the Manufacture of Electronic Components
George Williams, AT&T Bell Laboratories .' 62
Measuring Environmental Performance
Thomas W. Zosel, 3M 64
Section B
CONTRIBUTIONS OF PARTICIPANTS
Building the Infrastructure for Pollution Prevention
Dana Barkley, Arizona Public Service Company 71
Statement of Professional Interests
Barbara L. Bush, American Petroleum Institute 73
Measuring Progress in Pollution Prevention
Barry Dambach, AT&T 74
Measuring Pollution Prevention Effectiveness
Lisa Dufresne, MA OTA 75
Management Tools to Support Pollution Prevention
Margaret Flaherty & Ann Rappaport, Tufts University 77
Measuring Toxics Use Reduction at the Production-Unit Level
Timothy J. Greiner, MA OTA 79
Enhancing Environmental Return on Investment
John Paul Kusz, Safety-Kleen Corporation 80
Development of a Computerized Integrated Information System
for Pollution Prevention
Rada Olbina, U.S.EPA RREL 82
VI
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Pollution Prevention Interest
David Panco, Weyerhaeuser Company 85
Interest in Fugitive Emission Reduction
Elizabeth Pfeiffer, Givaudan-Roure 86
TURA Compliance at Merrimack Valley Works
Anne Reynolds, AT&T 87
Computer Simulation of Fugitive Emission Measurement
Jordan Spooner, U.S. EPA RREL ... ..-. . 88
WORKSHOP RESULTS
Workshop Questions for Work Groups 90
Workgroups 92
Closing Remarks
Jim Craig, U.S. EPA, Office of Pollution Prevention and Toxics . . 93
Summary of Discussions 95
Recommendations of the Workgroups 97
VII
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ACKNOWLEDGEMENTS
This workshop, "Measuring Pollution Prevention Progress", was planned in partial
fulfillment of the project, Management Tools to Support Pollution Prevention, by the
Center for Environmental Management of Tufts University under sponsorship of the
U.S. Environmental Protection Agency. Dr. Ann Rappaport of the Center for
Environmental Management is Project Leader responsible for coordinating this project.
The workshop program and activities were planned by a committee consisting of the
following individuals: Harry M. Freeman of U.S. EPA, RREL, Ann Rappaport,
Margaret Flaherty and Maureen Hart of CEM. This Proceedings was compiled by Dr.
Rada Olbina, a Tufts postdoctorate fellow at the RREL.
VIII
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Section A
PRESENTATIONS OF PARTICIPANTS
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POLLUTION PREVENTION: THE IMPORTANCE OF MEASURING PROGRESS
Jim Craig
US EPA, Office of Pollution Prevention and Toxics
(PM 222B)
401 M Street, SW
Washington, D.C. 20460
PHONE: (202) 260-4168
INTRODUCTION
Many of us at EPA feel strongly that the Agency has a responsibility to work
cooperatively with industry, states, and academia whenever possible, to achieve
environmental results, just as we have a corresponding obligation to regulate and
enforce our Nation's environmental laws. We want to accomplish our work in a
manner which helps keep American industry prosperous and competitive, and I hope
some of the activities I mention today will indicate our commitment to that approach.
Before talking about measuring progress in working to achieve results, let me
briefly describe the key components of EPA's program for pollution prevention. I want
to emphasize the fact that this is not the Division's program, nor the office's, but rather
is an Agency-wide program that even includes activities at other federal Agencies.
EPA's POLLUTION PREVENTION ACTIVITIES
Five themes characterize and guide our pollution prevention efforts and they
may be useful in designing other programs.
(1) Incorporate prevention principles into the mainstream work of EPA and the
Federal government.
(2) Help build and facilitate a network of prevention programs, particularly
among states and local governments.
(3) Identify and pioneer new environmental programs which:
- Emphasize cross-media prevention
- Reinforce the mutual goals of economic and environmental well being,
and
- Represent new models for government/industry interaction.
(4) Generate and share information to promote prevention and track its
progress.
(5) Develop partnerships in technological innovation with the private sector.
Let me briefly outline a few highlights of our programs in each of these five areas.
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Incorporating Prevention into the Mainstream
One of our goals has been to include pollution prevention (P2) principles in all
facets of EPA's ongoing regulatory and program agenda. The EPA Pollution
Prevention Strategy, formally announced in February 1991, sets forth guidance and
direction for this effort. Both organizationally and programmatically, EPA has been
working hard to ensure that prevention becomes a routine part of the way we do
business.
How is this done? One initiative underway is the Source Reduction Review
Project, a cross-program effort within the Agency to incorporate P2 into the process of
developing statutorily mandated regulations for 17 industrial categories. The goal of
the project is to ensure that each EPA office considers source reduction measures as
a primary means of obtaining compliance with the desired standard and pushes as far
up the environmental protection hierarchy as possible.
In addition, EPA's Office of Enforcement has a policy of including pollution
prevention conditions in enforcement settlements when appropriate. Through
supplemental environmental projects, violators can mitigate their fines and penalties by
applying P2 practices in their operations. , '
In modifying bur programs, it is clear that developing a P2 orientation even
among our own staff is a difficult undertaking and one that will not happen overnight.
For this reason, we have developed an Agency P2 training program which includes
both general prevention training and orientation for all new employees, as well as
specific training for permit writers and other EPA Regional staff. We're just now
expanding our efforts to work with Agency programs to help them help themselves in
promoting prevention. The idea is to enable them to take promising ideas and move
them forward by obtaining management commitment at all levels, ensuring that
training is available, and finally, providing guidance and oversight where 'needed to
help them in their efforts.
EPA is also devoting attention to putting the federal government's P2 house in
order -- developing a pollution prevention approach for the federal sector/The goal is
to promote source reduction among federal agencies in their various capacities: as
generators of hazardous and solid waste, in their ability to influence the marketplace
as major purchasers of goods and services, and as policy-makers, regulators, and
educators.
Network of State and Local Governments
It is critical for EPA to develop and strengthen state and local government P2
programs, and facilitate their coordination. It appears that the face of government on
environmental issues, especially source reduction and toxic use reduction, is
increasingly at the state level. EPA's assistance comes in several forms, including
technical assistance and grant funding.
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On the technical front, EPA is developing a pollution prevention information
clearinghouse (PPIC) to provide assistance to targeted customers through the
repository of prevention information and a database of industrial cases.
In 1993, EPA will provide about $6.8 million to states for P2 program activities
- an amount comparable to the last several years. This supplemental funding has
helped state toxic use reduction and other similar programs take root and expand their
prevention activities.
Pioneer New Programs
We will continue to identify and pioneer new environmental approaches and
programs which emphasize cross-media prevention, reinforce the mutual goals of
economic and environmental well-being, and offer imaginative new models for
government/industry interaction.
EPA has launched a series of innovative programs designed to capture
industry's attention and interest while engaging business in projects that will achieve
real environmental benefits. The programs have mostly involved industry in voluntary
pollution prevention projects that feature collaboration rather than confrontation.
An example? The voluntary 33/50 Program initiative to reduce toxic waste
generation from industrial sources is expected to achieve real P2 results in a relatively
short time frame. Under this program EPA has targeted 17 chemicals for reductions of
33 percent by the end of this year and 50 percent by the end of 1995.
Another exciting initiative is the "Green Lights" program, an aggressive,
non-regulatory effort to reach corporate decision-makers with information on new
energy-efficient lighting technologies.
Finally, we believe our new Design for the Environment, or DfE. program will
encourage the design of safer products and processes and will, accordingly, eliminate
or minimize the generation of pollution. Improved technologies lie at the heart of DfE -
we at EPA want to help make available information and help promote new analytic
tools in ways which are most meaningful to the needs of those professional groups
which guide industrial design decisions.
There are two areas that we're pursuing DfE: industry, and professions who
have an influence on practices, decision making and activities that generate pollution.
Initial industry efforts involve the printing and dry cleaning industries.
I'd also like to advise you of four projects which have longer run implications.
o We've recently provided grants to six university research groups exploring
alternative synthetic pathways - ways to design safer chemicals. Safer
chemicals generally lead to safer products.
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We're working with property and casualty underwriters to develop an
insurance incentive for P2 -- and they seem very interested. Our first focus
is on the curriculum they use to train their profession.
We're also considering a national accounting workshop to promote total
cost assessments which allocate overhead to processes and material
decisions which fail to prevent pollution.
Sharing Information and Tracking Progress
Sharing information is key to promoting prevention. We need to "keep book" on
P2 progress and document real achievements to build public credibility. Here, we feel
EPA must serve as an honest broker which recognizes genuine success but also sorts
out false claims of public health and environmental protection.
TRI data is one of the most powerful changes that has occurred in the U.S.
environmental sphere. In response to the Pollution Prevention Act of 1990, EPA has
devoted considerable attention to additional types of information that should be
collected and how the information should be used to measure progress in pollution
prevention. EPA will soon be releasing TRI data from reporting year 1991 which will
contain the new pollution prevention data for the first time. Over the next few years,
we will be improving methods for measuring progress as data are received and
analyzed.
EPA is also using information to achieve change in the consumer sector
through environmental or eco-labellina. We are working closely with the U;S. Federal
Trade Commission and the U.S. Office of Consumer Affairs to provide a coordinated
and cohesive national response to the issue of environmental labeling
and marketing claims. This past summer, the FTC announced new guidelines for
environmental marketing claims in advertising and labeling of consumer products. The
guidelines are intended to help reduce consumer confusion and prevent the false or
misleading use of terms such as "recyclable," "degradable," and "recycled".
We expect that this will be an area of increasing interest and attention in the
coming years as consumers seek more reliable information in the marketplace in order
to act effectively on their concerns for the environment.
In this area, we are paying close attention to the experience of other countries
with labeling and environmental marketing claims programs.
More on information and measuring progress in a moment.
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Develop Partnerships in Technological Innovation
A truly effective pollution prevention program must look beyond its own
resources to cooperative efforts with other organizations. Developing partnerships with
other agencies and private groups can have a multiplier effect in bringing about
greater awareness of P2 and in bringing to bear the resources and technological
capabilities of other organizations, many of which are greater than the Agency's.
WHY DO WE MEASURE PROGRESS?
I can offer three important reasons for measuring progress and evaluating
pollution prevention initiatives. I'm sure there are others, but let me start with these.
First - Measuring progress helps us figure out what works and what doesn't so
we can modify programs over time. If you don't know what works, you can
waste time and money on efforts that are launched with the best of intentions.
Second - Credibility - If we're not willing to open our programs (and I mean both
the public and private sector) to outside scrutiny and measurement of progress,
how can we expect the public to believe us when we say what we're doing is
protecting them and the environment?
Third - (for the altruistic) Measuring progress lets us know if we're having any
impact on the environment.
TYPES OF MEASUREMENT
1) Level of Program Activity - Counting the number of:
- inspectors and inspections,
- enforcement actions,
- FTEs' (how many bodies),
- dollars in budget,
I could go on, but I won't
2) Environmental Improvement - Tools like TRI can provide trends in
environmental loadings over time. We're a ways away from where we'd like
to be due to uncertainties in reporting. However, environmental
measurement is a relatively new field. In a much more mature field,
economic measurement, the Commerce and Labor Departments have
developed a series of economic indicators that we anxiously await each
month to see how we're doing. Consumer Price Index, Unemployment
level, Housing starts, to name a few.
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3) Cause of Environmental improvements - This is very difficult and expensive
to do. I'm not sure even the sophisticated economic measures attribute
changes to specific causes; however, there seems to be much discussion
of what are the effects of various measures.
A CONSTRAINT ON MEASURING PROGRESS
I'll just mention one constraint on developing ways to measure progress -
RESOURCES. We don't want to spend more on measuring progress of our programs
than we spend on the programs themselves.
WHAT ARE WE DOING TO SHARE INFORMATION AND MEASURE PROGRESS?
The Agency spends a lot of time collecting and using information to assess
progress. Traditionally, measurement has meant counting - how many of you name it
are there. This bean counting has never been a great way of measuring progress, but
it was what we had.
This traditional role has evolved over time to the point where EPA's major
contribution is simply providing public information, TRI being the best example. The
profound effect of the TRI data happened simply because information was made
available to the public.
While there has been a pronounced downward trend in releases reported in TRI
since its inception, we are not quite ready to declare victory and go home. Prior to the
Pollution Prevention Act data, there has been no indication of the reasons for
reductions and admittedly, much of the reductions are due to paper changes -
changes in the way the same quantities are reported, rather than actual changes in
quantity. I don't want to minimize the effect of these paper changes; however, real
changes are also occurring. A soon to be released study comparing 1989 and 1990
releases indicates that source reduction is occurring and is responsible for a reduction
of approximately 7% of the total 1989 releases and transfers.
Fortunately, with the advent of TRI, we can use it as a major source of
information for measuring the effect of our programs. In addition, as we develop more
innovative programs, we have more and better ways of measuring progress. TRI and
some of the measures of the new and innovative programs have the capability of
becoming much more focused on the effect we're having on the environment.
However, I should caution that we're not ready yet to state with certainty what is the
true effect on the environment, and we're farther away from stating the cause for the
effects.
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Some examples of how we measure progress:
33/50 Program: Since the Program's inception in February 1991, EPA has
received commitments from over 1,000 U.S. companies. These commitments translate
into a minimum of 340 million pounds of toxic emissions reduction by 1995. EPA is
almost halfway to reaching its goal of commitments for a reduction of 700 million
pounds. EPA is planning to use TRI data and supplemental information submitted by
companies
Green Lights Program: Over 270 corporate partners plus 12 states have signed
on so far, committing themselves to use energy efficient technologies to light some
2.65 billion square feet of space. EPA estimates that every time an ordinary
incandescent light bulb is replaced with an energy-efficient compact fluorescent bulb,
carbon dioxide emissions are reduced by 300 pounds a year.
The above measures are the ones that have been identified to date for these
programs and we ask your help in identifying others as the programs mature. These
programs are ones that seem to lend themselves to tracking progress; however, there
are many others for which measures of progress are not readily available. This is why
counting (bean counting) has been used as a measure of progress. Earlier in my talk,
I slipped in some counts as measures of progress for the state grants program.
Remember - In 1993, EPA will provide about $6.8 million to states for P2 program
activities. The challenge is to develop measures of progress for the state grants
program. Another example I'll leave you with is our Design For Environment
Accounting Project - How do we track its progress without devoting more resources to
tracking than to the project itself? I hope you all will give some consideration to these
questions as the conference gets underway.
SUMMARY
In summary, EPA's pollution prevention program has gone through a period of
rapid development and growth over the last few years. The five themes discussed
here point to a continuing dynamic effort, one that seeks institutional change,
innovative programs, expanding P2 partnerships, improved tools to measure and
encourage progress, and greater state and local P2 infrastructure.
Pollution prevention, as we see it, is as much your mission as ours. Sharing
information and jointly measuring our progress is a key component of the program and
we look forward very much to a strong partnership with you in accomplishing it.
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MEASURING STATE POLLUTION PREVENTION PROGRAM
EFFECTIVENESS IN THE NORTHEAST: A WORKING PAPER
Terri Goldberg
Pollution Prevention Program Manager
NEWMOA
85 Merrimac Street
Boston, MA 02114
PHONE: (617) 367-8558
The New England states, New Jersey and New York (Northeastern states)
pollution prevention programs* have begun to develop methods for measuring the
effectiveness of their activities. To assist the states in this effort, the Northeast States
Pollution Prevention Round table (NE Round table), a program of the Northeast Waste
Management Officials' Association (NEWMOA), has developed this working paper.
NEWMOA and the states anticipate that we will update and revise this paper in the
future as we develop better methods of measuring state pollution prevention program
effectiveness.
The challenge to states and others in evaluating the effectiveness of pollution
prevention programs is that the overall goal of these programs is to reorient the
behavior of manufacturers and commercial institutions toward prevention or source
reduction. This requires a change in organizational attitudes as well as possible
changes in organizational culture and structure. These changes can also require an
investment in new technology and in some cases research and development of new
products and manufacturing techniques. All of these types of changes take time.
Tracking or measuring such changes is difficult and challenging at best. The tools
available for evaluating the impact of state PP efforts on manufacturers are crude and
not well developed. Furthermore, if states are successful and companies begin to
integrate pollution prevention concepts into the design of new manufacturing
processes or new products, states would have great difficulty in determining how
much waste and pollution was avoided because there would be no baseline. The
purpose of this paper is to discuss these and other measurement issues facing the
Northeast state programs and the status of their efforts to address them.
This paper reviews the various pollution prevention (PP) activities in the
northeast states and how the states evaluate them1. The paper summarizes key
This paper is based on a survey of how the northeast states evaluate the effectiveness of their
pollution prevention program (see Appendix) and discussions at several NE Round table meetings.
Other sources of information are the Massachusetts Office of Technical Assistance, the New
Hampshire Department off Environmental Services Waste Management Division staff, the
Massachusetts Department of Public Health, EPA Headquarters project on measuring program
effectiveness, the National Round table of State Pollution Prevention Programs, and the
Department of Social Science at Boston University.
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issues facing the state pollution prevention programs and describes several ideas on
how EPA and others should approach measuring state program effectiveness.
The NE Roundtable and the National Roundtable of State Pollution Prevention
Programs have identified measuring program effectiveness as a priority issue for a
variety of reasons. First, program evaluation enables states to make choices among
the components of its PP program so that resources can be allocated to those
activities that are the most effective. Second, states can share their successes with
each other and encourage each other to initiate similar successful activities. Third,
evaluation can help states justify appropriations of funds from the state legislature or
through EPA grants. Finally, the Pollution Prevention Act of 1990 mandates that EPA
evaluate pollution prevention program effectiveness.
State Pollution Prevention Activities
All of the states in the northeast provide non-regulatory technical assistance on
pollution prevention to commercial facilities and manufacturers. The services provided
by these technical assistance programs (TAPs) include: (1) on-site technical
assistance to business through assessments of pollution prevention opportunities; (2)
financial assistance to businesses in the form of matching grants or low interest loans;
(3) research on pollution prevention methods for specific industrial processes or
wastes; (4) outreach to business through newsletters, fact sheets, manuals, surveys
and case studies; (5) telephone assistance and referrals to businesses; (6) workshops
and conferences on pollution prevention techniques targeted toward specific
businesses; (7) training for state agency staff and others on pollution prevention
methods and concepts; (8) clearinghouses of literature and vendor lists; and (9)
analysis of data on changes in hazardous waste generation, toxics use reduction and
other pollution prevention trends in the states.
Maine, Massachusetts, New Jersey, New York, Rhode Island, and Vermont
also have initiated pollution prevention programs in their regulatory agencies. For most
of these states, the programs include requirements for certain facilities to conduct
toxics use or hazardous waste reduction plans and report on their progress. Several
states, including Massachusetts, New Jersey and New York are also piloting various
approaches toward integrating pollution prevention into their air, water and waste
regulatory programs. These states have initiated multi-media source reduction-biased
compliance, permitting or enforcement programs.
Each state has developed a different functional relationship between their
regulatory and non-regulatory programs2. For instance, in some states the programs
are housed separately within one agency, while in others they are part of different
agencies. States have organized these programs into different offices or agencies
because they have different goals and objectives. Each state has developed a unique
For the purposes of this discussion, we will refer to these varied types of programs as "pollution
prevention programs".
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PP program and evaluation of their program must be conducted with sensitivity to their
specific context. However, there are some common issues feeing all of the state PP
programs and some common methods of evaluation that they can utilize.
Current Methods of Program Evaluation
Most of the northeastern state PP programs evaluate their effectiveness. In
their evaluations, they distinguish between measuring the outputs and quality of the
activities of their state programs from actual reductions in pollutants and wastes in the
environment. These two types of measurements should be related, but the
measurement tools available to the states make linking them difficult. They currently
qualitatively evaluate the effectiveness of their services, use some quantitative
measures of the level of their activities, and analyze the available data on emissions
and wastes generated by manufacturers. These methods of program evaluation are
described below.
Surveying the Users of State PP TAP Services
Surveying users usually involves sending out a written questionnaire to firms
that have contacted the state (TAP) programs for information or asking attendees at
workshops and conferences to complete an evaluation form. This method allows the
state to evaluate the level of activity in a program and provides a sense of whether the
state is expending its funds on the services it promises to offer. The benefit of this
approach is that some amount of information can be obtained about the program's
quality or effectiveness. However, the drawbacks of this method are that it is primarily
non-quantitative, survey respondents may have biases (that the surveys cannot
correct), and surveys are impersonal and may violate a sense of trust in a new state
program. Furthermore, most companies do not want to fill out another government
form.
Personally Contacting Firms to Document Their Pollution Prevention Achievements
This type of tracking system is widely used in the northeast states to document
the toxics use or waste reductions by the firms served by the states' TAPs. The
method involves personal contacts with the firms either by a site visit or a phone call
to gather information on a firm's accomplishments and to request comments and
suggestions. The benefit of this tracking system is that it can show what types of
outreach and promotional programs work in various industrial settings. Personal
interviews with users of the program's services may be the best method of obtaining
qualitative information on the users' impressions of the state program. In addition,
anecdotal information gathered during personal contacts can be useful in justifying a
program's funding from the state legislature or EPA. However, a drawback of this
method is the extensive time required.
Many state TAPs have published case studies or success stories of firms that
they have assisted using the information collected during follow-up visits and phone
calls. These reports are written with the permission of the facility and provide useful
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anecdotal information on the value of the state's programs to particular companies. By
publishing case studies on how firms have overcome barriers to pollution prevention,
state TAP programs help others who are confronting similar challenges. However, not
all successful facilities want the TAPs to publicize their successes or information on
how they achieved toxics use or waste reduction. Furthermore, the case studies
generally publicize only the successful firms and do not cover those that were
unsuccessful in using the state's PP services. Therefore, case studies have limited
value in providing a measure of the overall effectiveness of a state program.
Tracking the Number of Attendees at Workshops. Information Requests. Telephone
Calls. Onsite-Assistance Visits and/or Other State Activities
By tracking the number of contacts with industry and variety of services offered,
the pollution prevention TAP and regulatory programs can provide some measure of
how aggressive its outreach activities have been. This approach provides quantitative
information and tends to provide positive feedback. However, the approach affords no
measure of the success of the transfer of information during the activities or the quality
of the services offered.
Reviewing Data Provided by Industry
The northeast state TAP and regulatory programs currently analyze biennial
report data; manifest data; permit information; generator estimates of waste reduction;
Right-to-Know data; TRI data; reports on toxics use or hazardous waste under the
states' PP planning requirements; process-specific data; or data on industry type and
size, waste type, the number of businesses in that industry, and technology transfer
potential. This data typically provides a numerical representation of a company's
emissions, waste or toxics use reduction (TUR). It can help states determine whether
firms are reducing their use of toxic chemicals, air emissions, wastewater discharges,
or waste generation. This type of data is utilized by regulatory programs to track the
progress of their compliance and enforcement efforts and by state toxics use and
hazardous waste reduction programs to track the progress of firms in reducing or
eliminating their use of toxic chemicals and wastes.
Industry data has many drawbacks as a means of measuring state program
effectiveness. First, some of this data, such as manifest data and permit information,
does not account for changes in production levels at manufacturers. Second, much of
this data is not able to distinguish between reductions due to treatment techniques
versus pollution prevention. Third, industry has not been accustomed to reporting
waste or toxics use reduction data and accurate information can be difficult to obtain
from them. Fourth, many industries simply collect the wrong data or cannot effectively
collect the information needed to report correctly. Often, baseline waste generation
and toxics use information is difficult to get from industry due to the nature of many
corporate materials accounting systems (or the lack thereof). Finally, the data may
indicate whether reductions are taking place overall in a particular state, SIC code or
facility, but the data may not indicate whether these reductions are associated with
particular services provided by the state agencies or requirements in the state
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planning laws. As a result this data may not provide a direct indication of the
effectiveness of particular outreach or regulatory activities of the state programs.
States are interested in improving the indices that relate toxics use and waste
generation to product produced or some other factor that can be tracked from one
year to the next. Massachusetts and New Jersey have begun to require firms to report
on toxics use reduction within individual production processes or on a facility-wide
throughput basis. They are currently analyzing this data to develop a baseline of
information for future analyses and to assess its quality. The Massachusetts and New
Jersey experience indicates that depending on the reporting criteria, it may be
possible to track actual toxics use and release reductions. However, many states do
not have mandates that allow them to require industries to report this reduction
information.
Measurement Issues
There are a number of issues concerning the evaluation of state pollution
prevention program's effectiveness that need to be resolved before states can develop
effective measurement methods. The National Roundtable of State Pollution
Prevention Programs' position on evaluating state program effectiveness argues that
there is a lack of agreed upon methods and adequate data for evaluating program
effectiveness. The position also expresses the concerns of the states that pollution
prevention changes take place over a long period of time, and as such, real changes
that may be associated with a state programs activities may not be detectable for a
long time. State TAPs have different goals and objectives from regulatory pollution
prevention programs. Therefore, different evaluation approaches may be necessary to
analyze their respective effectiveness. The northeast states concur with the National
Round table's position. Other issues identified by the NE Roundtable are described
below.
Recognize the Inherent Value of PP Activities
The position of the NE Roundtable is that pollution prevention programs are
inherently valuable; this must be recognized, not measured. Technology transfer and
training need more support than does measurement of state program effectiveness.
There is a great deal of anecdotal information collected by state pollution prevention
programs that indicates that the programs are working. Pollution prevention programs
are getting an excellent reception from the regulated community. Therefore, states
place a higher priority on expanding the services that they currently offer than on
measuring past accomplishments.
Define "Effectiveness"
A major problem with measuring state pollution prevention program
effectiveness is that the issue has not been framed accurately. "Effectiveness" has not
been defined. Some believe that effectiveness must be evaluated quantitatively or in
reference to numerical reductions in waste generated/toxics used. Others 'argue that a
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qualitative measure is necessary to assess whether users value the services provided
by the state. Each state should define effectiveness according to its pollution
prevention mandate and program components.
The assumption behind using a quantity of waste or toxics use reduction to
demonstrate the effectiveness of state pollution prevention programs is that this
assumes that the relationship between these variables is a causal one. These two
variables may not be related. A state program may be highly effective in
communicating the benefits of pollution prevention and may have convinced firms to
invest in pollution prevention changes, however, these changes may not appear in
data reported to the state for a number of years after the firm has been in contact with
the state program. For example, a state program might be able to change the attitudes
within a firm toward pollution prevention, but such a change may not be measurable
until the firm implements a PP process change several years later. Similarly, a state
program may not be effectively promoting pollution prevention, but the quantitative
data indicates that firms have reduced their emissions. Such reductions could be
related to economic or technical factors that are not controlled by the state.
Some quantitative results may be necessary to justify state program funding
from EPA and/or the state legislature and to provide accountability to the general
public. For example, reductions in hazardous waste generation could be used as
measures of the achievement of state waste reduction goals within their hazardous
waste capacity assurance plans. However, evaluation of the achievement of specific
goals should not be used as a measure of the overall effectiveness of a state's
pollution prevention program. Furthermore, the delayed effects of pollution prevention
efforts make it difficult to use quantitative measures exclusively to justify a program's
funding.
The participants in the NE Roundtable believe that a qualitative evaluation of a
program's effectiveness and the quality of its services should be documented to report
on a state program's effectiveness and improve its functions.
Define the Program's Audience
Another important concern of the NE Roundtable participants is how to define
the audiences of the various types of state PP programs. These audiences can vary
widely from one state to the next. Some state programs have mandates to "perform"
primarily for industry, while others are required to report success to state
environmental agency heads. These audiences must be defined before methods of
measurement of program effectiveness can be developed by states in a consistent
manner. In addition, non-regulatory TAPs have different goals and objectives from
toxics use reduction and pollution prevention programs in regulatory agencies. The
TAPs may need to use different methods of evaluation from the regulatory programs.
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Develop a Baseline
If states use quantitative measures of pollution prevented or services provided
to evaluate their programs effectiveness, they will have to develop a baseline of data
for purposes of comparison from year to year. Establishing a baseline is important
because state programs must justify their funding. However, identifying the baseline is
difficult because the data may change from one year to the next. For example, the
regulated community under EPA's TRI data has changed since 1989 when the Agency
first started collecting information. In addition, the regulated community has become
more knowledgeable about filling out the TRI forms, so the quality or accuracy of the
information may have improved over the past few years. These and other factors may
make selection of a baseline year of information a crucial issue in conducting any
quantitative analysis of toxics use or waste reduction.
Proposed Methods of Evaluation to Investigate Further
States should develop their own criteria for evaluating the effectiveness of their
programs and build an effectiveness evaluation around the criteria. States could use a
combination of qualitative and quantitative criteria and methods as described above.
The participants in the NE Roundtable believe that any evaluation of the quality
and impact of state programs must be integrated into the program from the outset.
This requires that state programs clearly define the goals and objectives of their
overall program and specific activities. In addition, the state programs should consider
criteria for evaluating their efforts during the design of the activity rather than after the
activity has been completed.
The participants in the NE Roundtable believe that EPA and others should not
put pressure on state pollution prevention programs to justify their existence. Rather,
they should place a priority on facilitating the establishment of up-front quality
assurance procedures that are built into the operation of state PP programs. The NE
Round table views this as a more effective strategic use of scarce state resources
than requiring states to produce lengthy reports evaluating their fledgling pollution
prevention programs.
The northeast states recognize that they must constantly improve the quality of
the technical assistance and other services they provide to industry and increase the
reliability and effectiveness of the advice they provide. This can be done by
systematically organizing technical information in state information clearinghouses and
encouraging TAP staff to work in teams. Furthermore, the states encourage interstate
collaboration of the state pilot programs on integrating PP in the air, water and waste
regulatory programs to facilitate comparisons of their effectiveness.
A possible quality assurance mechanism would be to establish a network of
state PP programs in each region of the country to help states build upon each other's
successes, discuss technical applications, and gauge program effectiveness relative to
other programs. Though not an empirical tool, this would help address some of the
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issues raised above.
Linking Cost Reductions to Pollution Prevention
By encouraging companies to link the wastes they generate and cost increases
and process inefficiencies, a state program can motivate them to implement pollution
prevention programs at their facilities. This could be the goal of all state pollution
prevention programs. Therefore, states could qualitatively analyze whether it has
changed the view of corporations toward the costs associated with pollutants and
wastes. This could be measured by (1) examining how much firms have invested in
pollution prevention equipment or other capital expenditures in certain well defined
sectors in particular industries, (2) by collecting anecdotal information on whether
companies are reviewing the costs associated with wastes and pollutants, or (3) by
documenting the number of firms that have established teams or committees to
investigate pollution prevention opportunities and options. Another similar measure
could be to document the success of the state in convincing companies to track their
use of materials, particularly toxic substances.
Analyzing Pollutants Generated Per Unit of Product or as Throughout
State progress in achieving pollution prevention goals (as distinguished from
evaluating program effectiveness) can be measured through tracking changes in the
generation of industrial byproducts per unit of product as reported under various state
laws. Tracking progress may provide an indirect indicator of the effectiveness of a
state program, and is only one of many measures of its effectiveness.
The TUR data collected by Massachusetts and New Jersey may provide
models for other states on measuring reductions on a per unit of product or a
throughput basis. The northeast states believe that these quantitative measures
incorporate indirect measures of risk reduction associated with pollution prevention.
Using Anecdotal Information
A great deal of information on state program effectiveness is anecdotal. Letters
of thanks, good responses during on-site visits and presentations, and indications of
support by colleagues can be used as indicators, not measures, of program
effectiveness. States could also collect some quantitative information from firms that
have received onsite technical assistance on their reductions. The combination of
anecdotal information and reports on the quantity of toxics use and waste reduction at
facilities receiving on-site technical assistance would provide useful information on the
effectiveness of these programs.
Furthermore, firms sometimes comment on whether they understand how to
comply with state regulations to pollution prevention technical assistance staff. These
general comments could be provided to regulatory officials as a way of enhancing the
effectiveness of state regulatory programs. Similarly, firms may provide comments to
state inspectors on the effectiveness of the services provided by the technical
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assistance staff, and these could be communicated to the TAP programs as a way to
help them improve their services.
Summary
State PP programs have delayed, long term and indirect effects for which they
should be credited, but there are no widely accepted methods to quantify them. The
participants in the NE Round table believe that states should not be required to use
quantitative measures alone to evaluate their program's effectiveness. The Northeast
states are pursuing development of qualitative measures of the effectiveness of their
PP activities and quantitative measures of overall toxics use and waste reduction
statewide. The states also plan to focus on building quality assurance into the design
of their programs and activities in addition to measuring program effectiveness after
the activity has been conducted.
Next Steps
Participants in the NE Round table propose to undertake the following steps to
follow up on this position paper:
• Investigate methods of program evaluation available in human service and
public health programs. Some of these methods may be applicable to PP
since both are attempting to measure changes in behavior. NE Round table
participants have begun such discussions with social scientists, public
health experts and others in New Hampshire and Massachusetts.
• Contact state programs in other parts of the country to identify how they
are approaching evaluation of their programs. The Northeast states plan to
participate in the measuring program effectiveness activities of the National
Round table of State Pollution Prevention Programs.
• Work with EPA on several pilot measurement projects to be conducted by
the various types of state PP programs in the Northeast. Such a program
would enable the states to more formally test various measurement
techniques and data sets. This program would also enable the states and
EPA to test the various evaluation methods that may be appropriate for the
different types of state service. EPA Headquarters Waste Minimization
Program has initiated a PP measurement work group and is planning
several pilot measurement projects in selected states. The NE Roundtable
plans to participate in this initiative as members of the work group as
potential pilot states.
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Appendix
NORTHEAST STATES POLLUTION PREVENTION PROGRAM
EFFECTIVENESS ASSESSMENT SURVEY RESPONSES
What typefs) of programfs) do you currently operate? What activities do you conduct
under each program?
ConnTAP operates a non-regulatory program based in a quasi-public state agency.
Conducts technical assistance (on-site and off-site), financial assistance, and
research.
Erie County OPP operates a non-regulatory technical assistance program for small to
medium-sized businesses. Conducts on-site and telephone technical assistance,
research, workshops, training, publishes newsletters, and provides compliance info as
needed.
Maine PEP operates a regulatory TUR program based on a statute, and conducts
nonregulatory work. Conducts outreach, education, and technical assistance.
New Hampshire DES operates a non-regulatory technical assistance program.
Conducts onsite waste reduction assessments, process and product research, and
informational outreach. New Jersey Institute of Technology operates a non-regulatory
program at a university. Conducts technical assistance, seminars, literature research,
contracts with state agencies and counties, and training.
New Jersey DEPE operates a regulatory program to implement the Pollution
Prevention Act of August 1991. Conducts research on data contained in industry
progress reports (required under the Act) to develop trends in pollution prevention
achievements; also conducts a pilot program in facility-wide permitting.
New York DEC operates regulatory and non-regulatory technical assistance programs
with strong enforcement requirements and university R&D. Conducts hazardous waste
reduction planning, technical assistance, conferences, Waste Min Assessment
reviews, workshops, annual report, clearinghouse, BRS data management, CAP, siting
requirements, grants management, publishes fact sheets and bulletins, and household
hazardous waste research.
Rhode Island DEM operates a non-regulatory state government/university chemical
engineering pollution prevention program. Conducts on-site assessments, R&D grants
to university/industry, information clearinghouse, conferences/workshops, data
analysis, P2 & POTW industrial pretreatment compliance program.
Toxics Use Reduction Institute. UMass at Lowell operates a university-based program.
Conducts research activities such as funding research fellows, developing lab
resources for small and medium sized companies, and providing industry matching
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grants. Education and training projects include a TUR planners course, developing
educational materials for schools, and conferences.
Vermont DEC operates the WasteCAP program for industry, and non-regulatory and
regulatory programs. Conducts hazardous waste reduction and TUR plans under the
regulatory program, and non-regulatory program conducts limited on-site technical
assistance, workshops and conferences, publishes a newsletter, and is member of
waste exchange. WasteCAP conducts primarily on-site audits.
US EPA. Region I operates a non-regulatory program with some regulatory program
influence. Conducts P2-promoting activities, resource identification, project
organization and initiation, training, transportation committee, strategic planning.
How do you evaluate each program? What are the benefits/drawbacks associated with
each method of evaluation? What types of data do you use in evaluating your
proaram(s)? How do you collect these data?
ConnTAP evaluates programs through tracking number and type of request, and
one-time survey of users of programs. Benefit is that some useful info was obtained.
Drawbacks are inability to quantify effects of services and lack of an overall
assessment of satisfaction. Biennial report data is used to track waste reductions.
Erie County OPP evaluates programs by number of companies requesting assistance,
number of individuals that attend seminars, and overall number of individuals who
become aware of pollution prevention through its efforts. Uses manifest data, SPEDES
permit requirements, air permit info, and estimates made during inspections of
baseline waste generation.
Maine PEP does not evaluate programs at this time. Other programs are measured
primarily by the number of programs offered and interest by the regulated community.
Benefits are that it's a more positive program (positive interaction with public) and is
easily tracked. Drawbacks are that it's not effective in measuring success of transfer of
information.
New Hampshire DES does not evaluate programs at this time. For grant reporting
purposes, it tracks number of contacts, information packages sent, and workshops
attended. Drawback is that it does not provide quantitative information. Uses manifest
data, biennial reports, and questionnaires to conduct assessments.
New Jersey institute of Technology evaluates programs through follow-up surveys to
users. Drawbacks are response rates and built-in bias of responders. Uses data on
type of industry and wastes, business and industry size, number of businesses in an
industry, and potential for technology transfer.
New Jersey DEPE evaluates chemical use through data provided by industries under
NJ Right-to-Know law. Benefit is that source reduction achievements can be separated
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from release reduction. Uses TRI data and other data including use, quantity in
product, consumed in process, beginning and ending inventory, and quantity brought
on site. No formal evaluation reports are prepared.
New York DEC evaluates programs through reports to EPA, evaluation of hazardous
waste reduction plans (HWRPs), generator annual reports, HWRP annual reports, and
biennial updates of HWRPs. There are penalties for non-compliance with HWRP law
requirements. Drawbacks are need to improve indices that relate waste generated to
product produced or another value that can be documented from year to year. Looking
only at waste quantities will not quantify if changes resulted from actual waste
reduction activities or from changes in production levels.
Rhode Island DEM evaluates programs with a computer tracking system of all
technical assistance recommendations, does follow-up plant visits, and tabulates and
quantifies waste and toxics use reduction as the direct result of TA program efforts.
Benefits are that it allows one to understand what works and what doesn't work in a
variety of settings, and allows program staff to gage effectiveness. Drawback is that it
takes time. Uses process specific data on a case-by-case basis, collected in the field
through follow-up visits and phone calls.
Vermont DEC evaluates programs through industrial surveys to determine needs and
rates results of technical assistance. Uses TRI, biennial reports, hazardous waste and
TUR plans, manifest data, and air and water permits.
US EPA. Region I evaluates programs through qualitative progress reports from
programs. Drawbacks are that reporting is irregular and qualitative, and that without it
programs may go unnoticed.
If you do not currently evaluate your program, what types of program evaluation
methods have you considered using? What is your assessment of these method(s)?
What future plans do you have for an evaluation system? If you have no plans, what
type of evaluation system do you envision or have you considered?
ConnTAP will computerize a technical assistance request tracking system.
Erie County OPP has considered evaluating programs through measuring actual toxics
use reduction and generation records. Drawbacks are inability to force companies to
implement recommendations, companies' lack of capital resources to implement
recommendations, absence of adequate company records to establish baseline data
and conduct analysis, lack of upper management support necessary to implement
recommendations. No other evaluation plans at this time.
Maine PEP plans to use annual report data with reduction information from TRI data,
SARA 312 & 313 reporting data. Will implement a system allowing quick comparison
of percentage reductions from an annual reporting system. Will most likely evolve from
a facility database now under development.
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New Hampshire DES will set up a database to track and collect data, and will use
some form of adjusted quantity change method in order to generate numbers.
New Jersey DEPE will be performing a trend analysis of pollution prevention data from
similar industries (e.g., by SIC), to help determine what accomplishments should be
expected in certain industrial categories and which specific facilities are above and
below the industry wide trend.
New York DEC: HWRPs will identify details on waste to be reduced and programs to
be implemented. Annual status reports will be used to evaluate progress and biennial
updates will result in re-evaluation of reduction methods and their economic feasibility.
Vermont DEC will try to quantify reduction and provide qualitative information,
depending on hazardous waste and TUR plans received.
US EPA. Region I has attempted increased communication with Agency leaders on
this issue. Future plans for evaluation will be detailed in Strategic Planning documents
now under development.
How can states work together to develop methods for measuring and evaluating P2
program effectiveness? Other comments or suggestions?
ConnTAP: States should look at what EPA OSW and Region X are doing on
measurement.
Erie County OPP: States should network with each other to determine ongoing
activities and effectiveness. States with programs that target priority pollutants or large
quantity generators should base effectiveness on generator reductions. Effectiveness
depends on your program goals and who you have to answer to.
New Hampshire DES: States should compare notes and try to come up with some
ideas that work. There should be a workshop on this subject that state folks should be
invited to by EPA and/or NEWMOA to explain an evaluation system that has been
developed.
New Jersey Institute of Technology: States should compare existing survey/evaluation
results. P2 programs are inherently valuable; this needs to be taken into account, but
not measured. Technology transfer and training need more attention than
measurement.
New Jersey DEPE: States should collect the same data so comparisons can be made.
New York DEC: An evaluation method that is applicable to all states could be
developed from HW generator and TRI data, because this info is required of all states
by EPA, regardless of individual state PP, TUR or source reduction program elements.
An effective pollution prevention program must be multi-disciplinary with strong
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regulatory and enforcement components as well as traditional technical assistance.
Toxics Use Reduction Institute. UMass at Lowell: States should develop a standard
methodology for normalizing use or emission quantities to account for changes in
production.
Vermont DEC: States should establish a data work group, assure that federal
reporting contains information we need, and develop methods to assess program
effectiveness for CAP purposes.
US EPA Region I: States should use the Roundtable's recommendations as a basis
for discussion, select one method that they will use, and at NEMPP meetings discuss
how each state is succeeding (or not) in using its chosen evaluation method. EPA
Headquarters is very interested in this issue and would look favorably on any state
that demonstrates how various evaluation methods work. Although future PPIS Grant
awards criteria are yet to be determined, methodology analysis may be featured
prominently.
NOTE: A letter is available from Rick Reibstein, MA OTA, on this subject.
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POLAROID'S TOXIC USE AND WASTE REDUCTION PROGRAM
"50% IN 5"
Robert T. Hawes
Corporate Chemical Compliance Manager
Polaroid Corporation
1265 Main Street
Waitham, MA 02254
PHONE: (617) 684-5337
Pollution Prevention is not a new concept. I can recall some of Polaroid's early
Toxic Use and Waste Reduction (TUWR) efforts as far back as the mid-70's. My old
division, the Chemical Operations group, began working with people in the process
development laboratories to prioritize and work on key candidate waste streams for
recycling and waste reduction efforts. The problem was that this was an adjunct to the
primary job of developing chemical synthesis processes which made better and
cheaper film products rather than better waste streams.
Waste minimization didn't become an important concept until the mid '80's
nationally with efforts such as a study by the Office of Technology Assessment in
Washington, a project Polaroid participated in. Using the O.T.A. work as a model, we
began coalescing our program in early 1987. I was fortunate to participate as a '
member of the team which developed the framework for the TUWR Program, working
with our CEO Mac Booth towards the planned announcement of the program at the
1987 Annual Meeting.
We developed an early version of the reporting format based upon the following
concepts:
1. The reporting system should serve as an overall chemical material
balance around the reporting unit.
2. It should include all chemicals, regardless of toxicity or their inclusion on
any Federal or State lists (remember this predated SARA Title III).
3. It should track all waste streams in extreme detail (drum vs.bulk,
physical state, TSDF destination and ultimate treatment technique).
The team then began the task of setting appropriate goals and began addressing such
questions as:
1. Should we aim for reductions of 100 per year or 50% over 5 years? More?
Less?
2. Do we reduce usage or wastes?
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These and other questions resulted in compromise whereby chemicals would
be slotted into four categories by a team of experts and recycle/reuse counted as
waste reduction depending upon category. It was easy to agree that the reduction
index be calculated on a per unit basis to account for changes in production schedule.
Finally, it was decided that the reduction goal would be corporate-wide and the
accounting system developed to afford tracking of progress at all levels of the
corporation.
The accounting system, dubbed EARS (Environmental Accounting and
Reporting System), was developed for reporting quarterly via the corporate-wide VAX
system already in place to allow data entry at the divisions and data base
administration at the corporate level.
Chemical categories were assigned initially to approx. 1300 chemicals and
approx. 200 more have been assigned since. Those chemicals having the highest
environmental risk were placed into Category 1 and include substances such as
acrylonitrile and Freon 11. Category 2 contains dichloromethane, ammonia and silver
nitrate among others while Category 3 contains such materials as toluene, ethylene
glycol and hydrochloric acid. Category 4 includes most alcohols, ketones and zinc dust
and is the largest chemical category. A Category 5 was later added to track solid,
non-chemical wastes such as paper, plastics and molded metal products.
The final product, announced in 1987, set a 5 year goal of 10% reduction per
year in usage of Category 1 and 2 Chemicals and 10% per year reduction of waste
by-products of Category 3,4 and 5 materials. The Category 3 reduction allows credit
for on-site recycle (off-site for Categories 4 and 5) providing the generating division
actually reuses the recycled materials. The program also established a waste
management hierarchy with preference shown to recycle over disposal and internal
disposition over external handling. At the bottom of the hierarchy are emissions and
land disposal.
The final goal established was a "virtual" elimination of emissions of Category 1
chemicals at the end of 5 years.
The program was initiated with 1988 as the baseline year and was to be
voluntary in nature with corporate-wide (international) scope and local autonomy over
accountability. I was among the early skeptics and there did not seem to be much
going on well into 1989 in many areas until a Polaroid "Earth Day" was established in
the Fall of 1989. It was hosted by Polaroid's Vice President of Worldwide
Manufacturing and attended by the CEO and approx. 200 officers and other
operations, research, engineering and environmental types. Plant Managers had to
present their TUWR progress reports to this corporate-wide forum. In my opinion, this
was the first time many of them thought much about their waste minimization efforts. I
think we turned the corner that day.
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Now, Polaroid has made an annual event of this "Earth Day" process and has
instituted several other waste reduction forums such as Waste Reduction
University (an all day exchange of ideas held at Bentley College), a waste reduction
newsletter issued periodically to all employees, a grassroots Waste Reduction Now
program and an annual awards program where approx. 20 employees are awarded
plaques by the CEO or another senior Officer at a luncheon he or she hosts.
In order to achieve successful waste reduction, a cooperative effort was needed
involving operations, R&D and engineering representatives. The company is now
committing significant capital spending to the program, encouraging toxic use
reduction via process changes and funding installation of solvent recovery systems. It
has been recognized that different T.U.R. techniques are required in the varied
divisions with such diverse products as chemicals (dyes and polymers), photographic
negative, cameras, film (assembly), coated sheet and the film pack battery. Thus,
each division is encouraged to manage its own program while drawing on the
resources of the corporation as needed.
-*
Today, I'm going to summarize five case studies which illustrate the diversity of
the projects encountered.
The Camera Division replaced degreasing equipment which resulted in
increased condensing/recycling capability and an 80% reduction in Freon. Meanwhile,
the Battery Division completely eliminated the small quantity of mercury in our battery,
giving up a small amount of energy for a major environmental benefit. The Chemical
Operations Division has, among its many successes, managed to replace the
chemical sodium chromate which was used as an oxidizing agent in a synthesis with
air as the oxidant. One can be sure air is lower on Polaroid's list of toxics than sodium
chromate!
The Industrial Coatings group has already converted one solvent based coating
mix to an aqueous system and has committed to the same for its primary product, a
coating fluid containing a four solvent system which is virtually impossible to recycle.
Finally, two groups have instituted an interdivisional waste reduction program
where a methanol-caustic waste from one division is sent to another who separates
the two components and reuses the caustic as a neutralizing agent in the plant By the
end of 1991, the methanol was also being reused, in this case by the generator.
At this point, we are trying to fit the TUWR Program into other on-going
initiatives such as SARA Title III (TRI), EPA's Industrial Toxics Program, Clean Air Act
Amendment reductions and Massachusetts' Toxics Use Reduction Act (TURA).
Polaroid is now targeting SARA TRI reductions in our EARS reports and will
attempt to modify the data base to allow us to cull the SARA Form R reports directly
out of EARS. In addition, we have "signed up" for EPA's voluntary Industrial Toxics
Program (ITP), recommending to the EPA that we use our existing program to
generate the data. Of course, the EPA's program is emissions reduction oriented while
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ours measures reductions in total "toxics" used or generated as wastes, depending
upon the category.
With regards to CAA Amendment compliance, we are currently looking at the
potential for utilizing our TUWR Program to achieve Air Toxics reductions of at least
90% in order to achieve M.A.C.T. early reduction credits.
Finally, we are now in the midst of preparing our third annual TURA reports
(Form S's which complement Form Rs), using EARS data as much as possible to
generate the data. It will require considerable modifications and reprogramming of
EARS to allow data reporting as required by the Form Ss and for appropriate
Production Units. This may be accomplished in time for the reports due July 1, 1994.
The main thing our program will do for TURA will be to help us achieve its
goals since we are aiming for 50% reduction by 1993 using 1988 as the baseline year.
Conversely, TURA will help us achieve the TUWR Program goals by forcing us to
report (and evaluate) each production unit annually. In addition, it will probably spur a
second generation TUWR Program when T.U.R. Plans are required biennially
beginning in 1994.
At this point we have achieved an approx. 27% reduction corporate-wide after
the first four years but have been experiencing some difficulty in the third and fourth
years. The "low hanging fruit" has now been picked and some of the substantial
process changes (use reduction) and new solvent recovery systems will take a year or
more to implement, putting the company somewhat behind its expectation to achieve
its goals by the end of 1993. Discussions have begun regarding development of the
next phase of the program once the first stage is completed at the end of 1993.
Expectations are the program will broaden in scope into such areas as post-consumer
waste.
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SUMMARY OF MATERIALS ACCOUNTING AS A TOOL FOR MEASURING
PROGRESS IN POLLUTION PREVENTION
Shelley A. Hearne,
Bureau Chief,
Office of Pollution Prevention
New Jersey Department of Environmental Protection and Energy
CN 423
Trenton, NJ 08625-0423
PHONE: (609) 777-0518
While it is critical for an industrial facility to have a means of gauging pollution
prevention progress within their operations, there is also a public need for reliable and
uniform reporting on source reduction achievements. The Toxic Release Inventory
(EPCRA Form R) has been modified to include pollution prevention data elements that
will help the public better understand industry source reduction activities. Yet because
pollution prevention occurs at the production source - not at the end-of-pipe where TRI
measurements occur ~ this database may offer a limited perspective on pollution
prevention progress.
The New Jersey Department of Environmental Protection and Energy is using
materials accounting data as a means of augmenting TRI release information for pollution
prevention purposes. Since pollution prevention focuses on changes in production inputs
and production efficiency, along with innovative production technologies, it is also useful
to measure production inputs as a means of tracking pollution prevention progress.
Materials accounting data can provide information on the amount of chemicals used at
a facility level and allow efficiency calculations to be made, such as use: release, or
amount of chemicals used normalized to production. This is important, particularly since
use may change due to pollution prevention activities, but releases may remain constant.
Material accounting determines the quantity of the chemical at key junctures in its
progression through a production plant by quantifying the amount of chemical brought on-
site, consumed in-process, shipped off-site as or in product, starting and ending inventory,
and released into the environment. Materials accounting is a simplified mass balance of
what comes in and what goes out of a plant and thus provides a critical facility wide
perspective of toxics use. Below are the specific throughput reported under the NJ
Community Right to Know law.
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7. Maximum Inventory of Substance
8. Starting Inventory of Substance
9. Quantity Produced on Site
10. Quantity Brought on Site
11. Quantity Consumed on Site (used, not emitted)
12. Quantity Shipped off Site as (or in) Product
13. Ending Inventory of Substance
QUANTITY
(Ibs)
Rgure 1: Materials Accounting Data Elements
Theoretically, throughput data, in combination with TRI release data, could make
possible some important pollution prevention analysis. For instance, yearly chemical use
comparisons can be determined which would provide insight into the magnitude of
chemical use and be quantitative indicator of actual toxics use reduction. Production-to-
use ratios, use-to-release, and consumption-to-use can also be calculated along with
chemical use efficiency. In addition, materials accounting data not only provides a
potential mechanism for direct pollution prevention measurements, but also offer a
broader and more meaningful perspective on a facility's operations than TRI release data
alone.
New Jersey has required materials accounting information to be reported by
manufacturing facilities since 1987. Several different versions of the RCRA reauthorization
bills have included provisions for expanding TRI to have materials accounting data
elements. While concern have been raised nationally about confidentially of this
information, a minimal number for NJ facilities have made trade secret claims for
materials accounting data. On the average, between 3-6 trade secret claims are made
per year for more than 1,000 materials accounting forms submitted.
Though this information was not originally collected for pollution prevention
reporting purposes, it is anticipated that this information can be used to evaluate pollution
prevention progress that has been achieved by NJ industries prior to passage of
mandatory pollution prevention planning law. A research project, partially funded through
EPA's Office of Pollution Prevention, has recently been initiated to test effectiveness of
throughput data for measuring pollution prevention progress at industrial operations at a
facility wide perspective. In addition, this materials accounting information will be the
cornerstone of the state's pollution prevention tracking and reporting.
28
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WASTE REDUCTION MEASUREMENT PROJECT AT IBM
Joel S. Hirschhorn
President
Hirschhorn & Associates, Inc.
4221 Forbes Blvd., Suite 240
Lanham, MD 20706
PHONE: (301) 731-4095
Several years ago it became clear to various IBM managers that there were
several needs for obtaining data which accurately reflected the progress from many
pollution prevention/waste reduction actions being taken at IBM plants. In addition to
reporting and planning regulatory requirements under state and federal laws, corporate
headquarters wanted to be able to have comparable data for different plants.
However, various efforts by some plant personnel had not proven effective enough.
Indeed, to some extent some efforts yielded disappointing results, because data did
not seem to capture various improvements in manufacturing.
A major complexity facing the measurement issue at IBM was that within any
one facility many different "products" were being manufactured. Moreover, the mix of
products and the products themselves typically changed very frequently.
The goal of this project was to design a measurement approach which would
make maximum use of existing plant data, be relatively simple to use in many different
plants, and produce data which could both satisfy regulatory requirements and also
allow aggregation of plant data to create accurate company-wide data on waste
reduction progress.
From the beginning, it was clear that changes in waste generation (or chemical
use) has to be correlated with changes in production output. The major issue which
became clear after initial examination of data and extensive examination of several
major plant facilities was the need to rethink and reconceptualize the meaning of
production output.
The key concept which was used in development of the new measurement
approach was to redefine products in terms of their technology content rather than to
use conventional metrics which described products in terms of physical attributes. All
previous efforts had used traditional measures of production output, including, for
example, number of products produced and total area of a product or some
intermediate item in the production process. However, many products were routinely
being redesigned and improved so as to produce higher value and greater
performance without necessarily changing conventional measures of output.
29
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The new approach sought ways of describing production output in terms of
what customers purchased and valued, which is not a physical object (in terms of size
or weight), but rather some technological performance capability. Use of the right
technology metric would reflect changes in materials usage and manufacturing
practices. It would also allow aggregation of data across many different products, as
seen from a manufacturing or sales perspective, but which really are essentially the
same generic type of product in terms of technological performance capability. Data
for one major facility were used to show how the new method yielded very improved
results as compared to conventional measurements, using the same basic waste and
production data for several years.
The approach and methods developed have been implemented by a number of
IBM facilities.
30
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TEXTRON EFFORTS TO ENSURE INTEGRITY OF NUMBERS
Patricia I ezzi
Supervisor
Textron, Inc.
40 Westminster Street
Providence, Rl 02905
PHONE: (401) 457-2215
Textron is a multi-industry company with operations in three major business
sectors: Aerospace Technology, Commercial Products, and Financial Services.
Textron consists of about 35 Divisions, 135 manufacturing locations, 54,000
employees and has revenues of $8.3 billion.
What follows is a broad overview of Textron and its pollution prevention
program and a description of the means we are using to help ensure that our numbers
are reliable.
Textron policy requires each manufacturing facility to reduce or eliminate the
generation of hazardous and nonhazardous waste and emissions of toxic chemicals
through implementation of a plan. Other program elements are as follows:
1988 is the base year (for hazardous waste and toxic chemicals);
1991 is the base year for nonhazardous waste;
each facility must show a 5% annual aggregate reduction;
each Division must submit a plan that identifies its goals for the year and
report numbers which reflect the previous years activity.
The numbers for hazardous waste are based on biennial reports and on
manifests; the numbers for toxic chemicals are based on Form Rs. The numbers are
adjusted due to changes in regulations and production levels.
Below is a list of some of the factors that complicate the number crunching.
Acquisitions
may result in need to recreate figures for base year,
how will acquisition impact Textron.
31
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Overlapping reporting requirements may result in confusion
caused by reporting same data in different ways. Different reporting
requirements and formats result in different numbers.
Detection of errors in Form Rs by auditors, Textron, regulatory authorities -
using 1988 as base year presented problems because the Form R was new;
people were not familiar with the form and thus made errors.
Employee turnover may result in inability to recreate same number
twice.
Downsizing - Ability to determine aggressiveness of program and rely on data
depends on ability to view entire picture (true waste minimization v. changes in
production). These factors may result in need to revise figures continually.
Textron has not joined the 33/50 program, we canceled an award program
Also, communications to the public are limited to the extent that we do not translate
data into cost savings. A standard method for calculating costs has not been
developed and applied corporate wide.
In 1991 Textron started a program to audit the chemical accounting and control
programs at each facility, Essentially, auditors have been asked to track chemicals
through the plant as they would dollars. Chemical Accounting and Control Programs
are evaluated based on their ability to perform the following functions:
Identify all regulated chemicals;
Compare chemical amounts and activities at the facility against those that
trigger reporting;
Provide a signal when reporting is required;
Assist in effort to eliminate/reduce used of regulated chemicals;
Help prepare for and predict future reporting requirements; and
Produce and summarize current and accurate data.
The focus in 1993 is to continue the effort to ensure the integrity of our
numbers through use of our compliance assurance program and by ensuring the
development of effective chemical accounting and control programs at each facility.
32
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FINANCIAL PLANNING AND POLLUTION PREVENTION
Raymond P. Lizotte, Jr.
Senior Environmental Engineer
Texas Instruments Incorporated
34 Forest Street Ms 10-04
Attleboro, MA 02703
PHONE: (508) 699-3016
The costs of complying with environmental requirements through pollution
control is expected to increase dramatically over the next decade. Companies do not
have sufficient resources to pay these costs and remain competitive in the world
economy. One of the major selling points of Pollution Prevention/Toxics Use
Reduction (PP/TUR) is that it offers a method of reducing these costs without forfeiting
environmental imperatives.
Common practice within industry has been to place environmental costs into a
separate account (i.e. "overhead") and allocate the costs back to the manufacturing
areas based on a formula. When environmental costs were only a small percentage
of a company's total budget, this arrangement worked fine. However, as
environmental costs have increased, they are beginning to be a significant percentage
of the cost of doing business. The financial practices presently employed by industry
often do not adequately describe environmental costs.
The lack of description of environmental costs results in management making
major strategic decisions with insufficient information. To correct this, the corporate
cost accounting system needs to be modified to comprehend all environmental costs.
Once these costs are fully described, the financial tools that are being used by the
company can be applied on this data. In this way, the impact of environmental issues
are integrated into the routine procedures used by the company to analyze financial
information.
Besides identifying the actual costs that a company is expending for
environmental compliance, a cost accounting system such as this allows a company to
proactively pursue PP/TUR as a method of achieving cost reductions. By integrating
environmental costs into the cost accounting system, they become another line item in
a company's financial assessment procedure. The expenditures related to operating a
new manufacturing line may be compared with an existing line and a decision to install
the new manufacturing line may be justified. With environmental costs, a significant
part of the total cost of doing business, manufacturing options which reduce the
environmental costs, such as options based upon PP/TUR, may be implemented to
produce a savings.
33
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Tracking environmental costs may also provide a powerful tool for optimizing
the amount of resources a company expends towards environmental compliance. For
example, as environmental regulation becomes more stringent over time, the cost of
compliance via pollution control/abatement methods also increases. Performing an
analysis, which compares the cost of an existing operation under tighter emission
controls with a estimate of the costs of an alternative operation that employs PP/TUR
to reduce emissions, may demonstrate that it is more cost effective to implement
PP/TUR option that reduces emissions below a regulatory threshold rather than
attempt to abate the emissions with emission control technology. In this way,
expensive regulatory requirements may be avoided and the cost of complying with
environmental regulations reduced.
At Texas Instruments (Tl) a team has been formed to meet these challenges.
Tl is evaluating its existing cost accounting system to determine if modifications are
necessary to ensure that environmental costs are being completely tracked and
auditable back to the area responsible for the cost. In addition, the existing financial
tools are being modified to allow them to manipulate the added environmental costs
data. In this way, Tl intends to include this data as an additional variable within all its
routine financial planning procedures.
34
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SOURCE REDUCTION THROUGH
TOTAL QUALITY ENVIRONMENTAL MANAGEMENT
Richard F. Mannion
Manager
Environmental Services
Foxboro Company
33 Commercial Street (MS NO52A)
Foxboro, MA 02035
PHONE: (508) 549-3620
Bevond Compliance: Total Quality Environmental Management
Due to increasing governmental regulation, environmental compliance has come
to represent a significant percentage of total production costs for many U.S.
manufacturers. In most cases, source reduction remains the single most cost-effective
means to achieve compliance. Not only does source reduction result in a direct reduction
in tangible compliance costs (licensing fees, disposal costs, lab fees, waste treatment,
and so on), it simultaneously reduces costly waste in the production process/Additional
benefits include improved employee safety, enhanced community relations, and - more
and more - the approval of end-user customers.
Instituting an effective, ongoing source reduction program in a manufacturing
environment involves total management commitment and often, a culture change in
operations. At The Foxboro Company, a manufacturer of instruments and automation
systems for industrial process control, source reduction efforts were integrated within an
ongoing Total Quality Management (TQM) Program. The resulting process is known as
Total Quality Environmental Management (TQEM).
The Foxboro Company's three major manufacturing facilities are located in
Southeastern Massachusetts. Specific manufacturing operations at these facilities include
electronic assembly, cleaning, plating, painting, degreasing, and machine shop
operations.
Foxboro has been actively involved in source reduction since the late 1970s.
Previous to instituting TQEM, the most significant accomplishment had been a reduction
in VOC emissions (Fig. 1). This reduction was achieved by modifying the existing solvent
paint process to a powder coating process, and by implementing product design changes
that eliminated the need for painting altogether. Other source reduction programs reduced
wastewater discharge and eliminated a number of degreasing operations. These
programs, which had been informally managed by the environmental department, were
focused primarily on compliance issues.
35
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In 1992, TQEM was implemented to enable Foxboro to progress to a level
of environmental responsibility that went above and beyond regulatory compliance.
A structured approach to source reduction
Foxboro instituted its Total Quality Management program (TQM) in 1989. The goal
of this ongoing program is to meet or exceed customer expectations. This is achieved
through continuous improvement of our work processes and by reducing variability in our
individual efforts. "Customers," in this context, can be external (i.e. other companies that
purchase our products and services), internal (other Foxboro departments or downstream
manufacturing operations), or in the case of environmental management, local, state, and
federal regulatory agencies, the neighboring communities, and the environment itself.
At Foxboro, TQM encompasses three interrelated elements: quality planning,
quality teams, and quality operations.
The purpose of quality planning is to focus the entire company on strategic quality
targets and provide the means to accomplish them. Quality planning is performed
primarily at the staff-level Quality Council and by lead quality teams.
The team element includes formal teams composed of individuals from
corporate, operations, technology, manufacturing, and marketing departments that are
trained and empowered to solve specific problems through the 7-step Quality
Improvement Process (QIP) shown in Table 1. Training covers the five principles of QIP:
customer satisfaction, respect for people, structured problem solving techniques,
management by fact, and continuous improvement (Fig. 2).
Quality operations extends the problem-solving training and mentality established
in the team efforts to the day-to-day activities of the company. In this manner, Foxboro
is working toward making customer sensitivity an embedded characteristic in the culture
of the company.
In this kind of quality-process-focused environment, implementing a Total Quality
Environment Management program was simply a matter of isolating strategic
environmental targets by stratifying the manufacturing process (Fig. 3) to indicate where
emissions or waste were being generated and forming QlP-type problem-solving teams
to address the specific environmental issues. Ultimately, specific team themes were
selected on the basis of the relative impact to the customer, the urgency of a solution,
and the practicality of finding a solution.
Individual teams are composed of five to seven individuals representing a variety
of different departments (environmental management, production, engineering,
purchasing, quality control, facilities, inventory control, and so on). TQEM teams meet
once a week to develop a strategy and a plan to solve their assigned environmental
objective. Once again, this process involves stratifying the manufacturing process to
identify the root cause of the problem. The teams develop effective, easy-to-understand
measures of improvement - or "indicators" - and then apply structured problem solving
36
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techniques to attain continuous improvement in these indicators with the ultimate goal
being the total elimination of the hazardous component in question.
Each team is directly supported by a senior operations sponsor manager. The
Foxboro Environmental Manager serves as a technical consultant to all TQEM teams and
as a team member on more than one of the teams. A full-time Foxboro quality consultant
serves as a quality system consultant (facilitator) to the teams and a corporate Foxboro
vice president sponsors the TQEM teams and serves as the link to the Quality Council.
As a whole, the TQEM teams represent an environmentally focused organization
matrixed within the entire Foxboro quality organization. TQEM teams frequently get
together as a single group to update each team's progress and share approaches to
addressing environmental issues.
TQEM in action
Six Foxboro TQEM teams -- each with a different environmental objective - were
established in January 1992 (Fig. 4). One year later, all six teams were already in Step
4 of the 7-step QIP problem-solving process, developing effective counter measures.
Most teams are confident that they will be through all seven steps by the end of 1993,
and sooner in some cases.
Let's examine the results achieved by two of the teams empowered to reduce
CFCs and heavy metals usage, respectively.
The goal of the "CFC" team (which stands for Changing Foxboro's Cleaning
systems) goal was to eliminate the use of ozone-depleting chlorofluorocarbons (CFC)
from the manufacturing process. Their first step was to analyze the situation by
determining the current usage at the three manufacturing plants (Fig. 5). The problem
was then stratified by chemical, by application, and by process (Fig. 6) to allow the team
to determine actual cleaning requirements. This data made it possible to investigate and
promote alternatives. The team subsequently implemented several alternative CFC-free
processes, such as the use of no-clean fluxes. The team also received authorization to
purchase the new equipment required to implement a semi-aqueous process that will
totally eliminate the use of all CFCs in manufacturing operations at Foxboro.
Another team, the "Cad Cutters," was initially charged with reducing heavy metals
from manufacturing operations effluent. After studying the problem, they chose to
specifically target the cadmium used in some plating operations with the ultimate goal of
eliminating its use altogether. The first task was to stratify the operation to isolate those
manufactured parts requiring cadmium plating (Fig. 7). From this data, the team
developed a dendrogram (Fig. 8). This is a series of questions and answers concerning
the need for cadmium. ,
37
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This investigation resulted in the elimination of many parts having to go though the
cadmium bath. The team is also investigating and evaluating alternatives to cadmium
plating to eliminate its use altogether.
Conclusions
TQEM certainly isn't the only way for manufacturers to achieve source reduction. But
since TQEM focuses on continuous performance improvements (rather than the
incremental improvements achievable with other methods), TQEM is clearly an ideal
process to enable a company to go beyond strict regulatory compliance and achieve, as
Foxboro has in several cases, the total elimination of the hazardous materials in question.
At Foxboro, witnessing the TQEM "buy in" on the part of senior management has
been gratifying. But it has been even more gratifying to share with the team members
themselves the satisfaction in seeing significant reductions in the use of materials that
have proven to be detrimental to the environment.
Table 1:
The 7-step problem-solving process utilized by Foxboro QIP teams:
1. Reason for Improvement
2. Current Situation
3. Analysis
4. Counter Measures
5. Results
6. Standardization
7. Future Plans
38
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Fig. 1
THE FOXBOROCO
VOC REDUCTIONS
from PAINT LINE
tons
160
78 79 80 81 82 83 84 85 86 87 88 89 90 91 92
Tons VOC
year
39
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46
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VOLUNTARY POLLUTION PREVENTION AND
OPPORTUNITY ASSESSMENT
David McEntee
Environmental Manager
Simpson Tacoma Kraft Company
P.O.Box 2133
Tacoma, WA 98401-2133
PHONE: (206) 596-0257
ABSTRACT
Simpson Tacoma Kraft Company, in voluntary cooperation with EPA Region X
and the Washington Department of Ecology, developed a mill specific pollution
prevention plan. Using funds provided from EPA's Industrial Pollution Prevention
Project, EPA Region X was tasked with the development of a model pollution
prevention plan for the pulp and paper industry, one of the largest industries in the
Region. As a part of that project, a specific pollution prevention opportunity
assessment and voluntary implementation plan was developed for the Simpson
Tacoma Kraft Mill in Tacoma, Washington.
An EPA contractor conducted the opportunity assessment and developed the
implementation plan for Simpson Tacoma. Representatives of Simpson, EPA, and the
Washington Department of Ecology participated in the mill observations and
discussions that helped shape the study. By reviewing the major process areas and
equipment within the Simpson Mill, interviewing plant personnel, noting recent
equipment upgrades, and evaluating emission and discharge estimates from the
Toxics Release Inventory (TRI) data, feasible procedures were identified and
evaluated for potential implementation by Simpson.
The study identified a number of pollution prevention measures currently in
place at Simpson Tacoma and presented recommendations to develop an ongoing
pollution prevention program. The report included recommendations for
implementation of short-term and long-term process modifications to attain pollution
prevention benefits.
Looking beyond the study, a key issue is the implementation process. Industry
and Regulators alike recognize the merit of short and long-term planning aimed at
multi-media environmental benefits. However, even with this common interest, moving
a project from a plan to implementation can be a significant challenge.
With the multitude of regulatory jurisdictions (local, state and federal) and the
array of interconnected programs within individual agencies, good intentions can
quickly turn to frustration and disappointment for regulators and industry alike.
47
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However, the process of multi-media management and pollution prevention
planning provides promise for regulators and businesses when considering project
implementation. Just as good pollution prevention planning weighs total environmental
benefits in a single framework, the implementation process should also.be integrated
and coordinated, and reside with a single entity. A coordinated process would
stimulate more aggressive pollution prevention planning, but more importantly, it would
result in implementing more pollution prevention products.
The implementation dilemma, as well as its solution, is recognized by both the
regulators and the regulated community. From this awareness has come hopeful
signs, such as the cooperative pollution prevention effort of EPA, Washington
Department of Ecology and Simpson, and development of the cross-media
assessment program by Oregon DEQ.
While the regulators, regulated community, and public can easily point to the
merits of cross-media environmental management, to realize these benefits, these
same entities must work together.
48
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MEASURING PROGRESS IN POLLUTION PREVENTION
George Nagle
Director
Environmental, Health and Safety Services
Bristol-Myers Squibb Co.
5 Research Parkway, P.O.Box 5100
Wallingford, CT 06492
PHONE: (203) 284-6120
ABSTRACT
Bristol-Myers Squibb Company is a large, decentralized organization supplying
pharmaceutical, nutritional, medical devices and consumer products worldwide. Our
environmental, health and safety program has historically addressed pollution
prevention activities in a variety of ways.
Current programs include waste minimization procedures, packaging guidelines,
capital appropriation request reviews and purchasing guidelines. Pollution prevention
performance measurement has been facility-focused and anecdotal in nature.
In 1992 we embarked on a company-wide pollution prevention program entitled
ENVIRONMENT 2000 which is based on integrating product life cycle management
into the core of our businesses. Our goal is to conduct product life cycle reviews of
both new and existing products.
The preparation of an initial Company environmental report to our stakeholders
has caused us to focus our efforts on developing company-wide pollution prevention
performance metrics. Such metrics must be clear, precise and relevant to both our
stakeholders and businesses. This need has been recognized as a priority and initial
elements should be identified later this year.
49
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POLLUTION PREVENTION
Robert B. Pojasek, Ph.D.
Corporate Vice President
GEI Consultants, Inc.
1021 Main Street
Winchester, MA 01890
PHONE: (617) 721-4097
Manufacturing is defined as the mechanical or chemical transformation of
substances or materials into new products. The assembly of component parts of
products is also considered to be manufacturing if the resulting product is neither a
structure nor other fixed improvement. Any loss of materials, energy or other resource
whatsoever, represents an inefficiency in manufacturing. A company needs to utilize a
variety of proven management tools, together with effective process re-engineering, to
minimize the losses (i.e., wastes). As much material and energy as possible must be
recovered from process wastes and from post-use products to enhance the gains in
efficiency. Management tools, which include Total Quality Management (TQM),
Just-in-Time (JIT) and Computer Integrated Manufacturing (CIM), are the pillars upon
which the competitive enterprise is built.
What we are calling "pollution prevention" is not a special field but is
concentrated on improving efficiency in all manufacturing activities. Every loss from
the process is an opportunity not to have the loss. A "pragmatic" pollution prevention
program is attained when a process is operated efficiently by an enlightened
management with employee participation in that management. Pollution prevention
comes about in practice through continuous improvement of manufacturing efficiency
and not through the imposition of a prescriptive or opportunistic program. By
practicing pollution prevention, industry can obtain increased industrial efficiency,
profitability, and competitiveness.
Management's skills and attention must be continuously devoted to decreasing
its total costs over time. This can be accomplished through the use of Activity-Based
Costing (ABC) techniques. ABC methods recognize that activities associated with
certain unit operations and their resultant products cause costs. These ABC systems
allocate overhead (i.e., indirect costs) in proportion to the activities associated with a
product or product family. For instance, if one product by its nature has losses of
regulated chemicals to the workplace and environment associated with it, it must bear
a significantly higher cost burden than another product made without significant
regulated chemical loss. ABC methods really form a basis for value-added and
business process analyses and redesign that fosters global competitiveness. The use
of ABC provides a company with a wonderful tool to identify and reduce resource
consumption by increasing both efficiency (productivity) and effectiveness.
50
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Two measurements of production efficiency are as follows:
Material Use = (Amount of Material Used - Amount of Products) x 100%
Efficiency (%) Amount of Material Used
Economic Efficiency (%) =
(Production Unit ABC - Cost of Loss) x 100%
Production Unit ABC
How does this measurement meet the criteria posed by this workshop?
1. How do you measure waste that is not created? Waste (i.e., losses) which
is not created improves production efficiency. Therefore, it is counted in this
method.
2. How can you compare results from differing companies or industries?
Efficiency is universal to all manufacturing processes. However, some are
inherently more efficient than others thus making cross-industry
comparisons difficult.
3. How do you account for changes in production? Production efficiency is a
normalized unit less measurement. Remember that some processes may
become less efficient at lower production ratesl
4. Is it meaningful to compare a company with a history of successful pollution
prevention with another company that is just beginning? In th.e best practice
of TQM and JIT, a firm strives for maximum efficiency. The goals are
always zero losses or 100% efficiency.
5. To what extent does accounting for "hidden" costs, such as recordkeeping
and reporting, get factored into environmental decision making? Indirect
costs must be factored into all manufacturing decision making. The use of
total costing methods, which include intangible costs, will not receive
favorable management acceptance. ABC takes real costs normally attributed
to overhead and reassigns them to the units responsible for them. Wasteful
unit operations appear a lot more costly in this accounting practice.
REFERENCES
1. Thomas G. Gunn, 21st Century Manufacturing, Harper Business, New York
N.Y., 1992.
2. Robert B. Pojasek, "Contrasting Approaches to Pollution Prevention
Auditing," Pollution Prevention Review, Summer 1991.
3. Everett E. Adam, Jr. and Ronald J. Ebert, Production and Operations
Management, Prentice-Hall, Inc., Englewood Cliffs, NJ., 1982.
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IMPLEMENTING AND TRACKING
WASTE REDUCTION PROGRESS AT DUPONT
Randy Price
Manager
Waste Programs
E.I. DuPont De Nemours & Co.
P.O.Box 80721, MR 2024
Wilmington, DE 19880-0721
PHONE: (302) 999-4128
The DuPont company has an active waste reduction program. This program
consists of a three-tiered approach. The first tier focuses on present activities and
facilities. At this tier we look for immediate results typically requiring a relatively low
investment and results in a relatively high rate of return (these are the so-called "low
hanging fruit").
The second tier focuses on near-term changes by upgrading existing processes
using existing technology. These initiatives tend to take from 1-5 years to complete.
The third tier focuses on developing new technology and requires basic
research and development. These initiatives tend to take more than 5 years to
complete. This tier usually results in major capita! investment through either major
process modification or construction of new facilities. The rate of return for these
Initiatives tend to be lower than the other two tiers as well as having a lower
probability of success.
DuPont has several waste reduction goals for such categories as air toxics, air
carcinogens and hazardous waste. To properly plan for the successful achievement of
the goals as well as to track our progress, the company has developed a Corporate
Environmental Plan (CEP). The CEP integrates environmental planning with business
planning as well as identifies the initiatives required to achieve our environmental
commitments.
The company also maintains or is in the process of developing several data
bases to enable the company to track progress more accurately and on a more
frequent basis. Currently, the company operates the Corporate Solid Waste
Information System (CSWIS). This system tracks our generation of hazardous and
non-hazardous waste and is updated annually. The company also has a corporate TRI
data base which tracks our TRI numbers, both "as generated" and "releases and
transfers". We are currently developing systems which will help our sites track their air
emissions and manage their waste management programs.
52
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in addition, the company has implemented the Chemical Manufacturers
Association's Responsible Care* program whose purpose is to promote the continuous
improvement in environmental performance of member companies. Responsible CareR
tracks improvement in management systems. Programs like TRI track progress in
waste reduction. Both systems aid a company to understand its performance and
helps to identify where progress is needed the most.
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NORMALIZED MEASURES OF POLLUTION PREVENTION
Nasrin Behmanesh
Julie Roque, PhD
Associate Professor
and
David T. Allen
UCLA
Graduate School of Architecture & Planning
405 Hilgard Avenue
Los Angeles, CA 90024-1467
PHONE: (310) 825-0577
ABSTRACT
Releases and off-site transfers reported in the 1987 Toxic Release Inventory
(TRI) were normalized by a variety of economic indicators reported through the 1987
Census of Manufactures (employment, payroll, sales, value added and others).
Industrial sectors, identified by two digit Standard Industrial Classification (SIC) codes,
were ranked according to total TRI releases and transfers and by the normalized
measures. The normalized measures yielded industry rankings that were different
than the rankings based on total releases and transfers. Among the normalized
measures, however, the rankings were largely independent of the choice of economic
indicator despite the fact that both labor and capital intensive industry sectors were
included.
INTRODUCTION
Initiatives to promote pollution prevention have been undertaken at the federal,
state and local level across the United States. One of the greatest challenges to
strengthening and expanding these efforts, however, is developing measures to
assess progress toward reducing or minimizing industrial discharges. Measures of
pollution, normalized to levels of industrial activity (i.e., emissions/production), would
enable decision-makers to track emissions over time and identify facilities that are
making great, little or no progress in pollution prevention, despite changes in economic
conditions. The concept of normalizing pollutant releases and discharges to
production levels has been widely discussed, with significant debate centering on the
choice of appropriate production indices1,2. The general perception is that the choice
of production index may influence the apparent environmental performance of a facility
or an industry sector. The goal of this paper is to assess the validity of the perception
by normalizing releases and transfers reported through the Toxic Release Inventory
(TRI)3 by economic indicators available through the Census of Manufactures4.
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The TRI is the single most comprehensive source of multimedia data available
on releases and transfers of hazardous materials to the environment. Mandated by
Title ill of the 1986 Superfund Amendments and Reauthorization Act (SARA), the TRI
reports quantities of hazardous materials, on a facility by facility basis, that are
released into the air or surface waters, managed on land on-site, or shipped off-site
for treatment and disposal. It is compiled from annual reports submitted to the U.S.
Environmental Protection Agency by manufacturing facilities that use and store any of
the approximately 320 chemicals (or classes of chemical compounds) listed in the
inventory.
In 1992, the TRI reporting requirements were revised to include a production or
activity index that would enable waste generation to be normalized to levels of
production5. The production index is a facility specific ratio of some measure of
production in the current year to the same measure for the previous year. The
addition of a production index to TRI reports will enable pollution prevention trends to
be evaluated for single facilities, taking into account increases or decreases in activity.
As currently reported, however, the productivity indices used by different reporting
facilities will be vastly different and cannot be compared or aggregated. For
comparisons and aggregations to be made, activity must be expressed in a common
set of units such as number of employees, or value added by manufacture. It is
uncertain, however, whether the development of such as index would significantly
supplement the information already in the Toxic Release Inventory. To explore this
issue, we normalized TRI reports using indicators of economic activity such as
employees, payroll, value added by manufacture and total sales. The measures are
available from the Census of Manufactures4, which is collected every 5 years and is
reported by the U.S. Department of Commerce. Economic indicators such as
employment and value added, measure different characteristics of economic activity.
Therefore, we expected that labor intensive industrial sectors might appear "greener" if
emissions were normalized by employees, while capital intensive industries might
benefit from a production index based on value added. We found, however, that with
only a few exceptions, the choice of economic indicator had little bearing on the
overall ranking of industrial sectors. These are very preliminary results, however, and
must be confirmed by more detailed analysis, particularly an examination of individual
facilities. The details of our methodology and results are described below.
METHODOLOGY
Measures of environmental performance used in this work are the ratios of a
numerator, the total mass of TRI chemicals released to the environment or transferred
from a manufacturing facility, to several different denominators. The denominators
considered were: total payroll of all employees, wages of production employees, value
added by manufacture, value of shipments, total number of employees, and number of
production employees. The total amounts of chemical releases and transfers by each
industry category were derived from the 1987 Toxic Release Inventory (TRI) using on-
line and published TRI data. The denominator data were all obtained from the 1987
Census of Manufacturers for the same industry categories.
55
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Both sources of data are national in scope, and both contain data on general
manufacturers identified by Standard Industrial Classification (SIC) codes 20-39. The
TRI is collected from all facilities with ten or more full-time employees which produce,
import, or process more than a threshold amount of any of the TRI listed chemicals.
These facilities are required to report the amounts of toxic chemicals that are released
to air, water, land or injected underground. In addition, manufacturers must report the
amount of chemicals that are transferred off-site to other facilities. The threshold
value of TRI chemicals for triggering a report was set as 50,000 Ib/year for the year
1987 and 1988 but it was reduced to 25,000 Ib/year for 1989 and 1990. Approximately
20,000 facilities report through the TRI3.
The Census of Manufacturers, on the other hand, covers all establishments that
had one paid employee or more at any time during the census year, primarily engaged
in manufacturing. In the 1987 Census, approximately 150,000 small single-
establishments (from the total of 350,000 establishments) were excused from filing
reports. This included all single-establishment companies with less than five
employees4. Thus, the data from many facilities with less than five employees were
not included in the 1987 Census of Manufactures.
These differences in the scope of the data sources introduce uncertainty into
the evaluation of measures of pollution prevention. The number of facilities used in
establishing economic indicators was significantly larger than those reporting under the
TRI, and the fraction of TRI reporting facilities varied from sector to sector. Additional
uncertainties were imposed by differences in SIC codes. Specifically, the Census data
were reported on the basis of the newly revised SIC system (1987 revisions)4. In this
system some 4-digit and some 3-digit codes were either substituted by new codes or
were categorized under other existing code(s). For example, since 1987, the SIC
codes 2793 (photoengraving) and 2795 (lithographic plate-making and related
services) are both classified under a single code, 2796 (plate making services). A
similar example is 3-digit SIC 264 which is included with SIC 267. In other cases, one
industry code is split into two separate new industry codes. For example, the 1972
SIC-based industry 2831 (diagnostic substances) has been divided into two distinct
industry codes: 2835 (diagnostic substances) and 2836 (biological products, except
diagnostic substances). The revisions, however, were not considered in TRI
database.
Another complication involves an individual facility reporting under more than
one SIC code. In some cases, where emissions, from a facility are categorized under
more than one SIC, the amount of releases might be counted more than one. For
instance, a detailed examination of data corresponding to industries represented by 3-
digit SIC codes of 261 (pulp mills) and 262 (paper mills) reveals 557 double counts of
SIC codes as follows:
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1. There are 21 streams which are identified by both SICs of 2610 and 2620.
The sum of total releases and transfers of these streams is equal to
78,569,695 Ib/yr.
2. There are 536 chemical streams which are reported to be released from the
industries identified by both SICs of 2611 and 2621. Total rate of releases
and transfers for these streams adds up to 1,019,666,506 Ib/yr (1987 data).
Therefore, a total amount of 1,098,236,201 Ib/yr could be double counted when
the releases and transfers of SIC codes 261 and 262 are determined. Examples of
multiple counts are not rare at the 3-digit SIC code level. In some cases three or four
SIC codes per chemical release are reported that all belong to the same 2-digit SIC
code. For instance, 114 streams were identified by four 3-digit SICs of 281, 282, 286
and 287 that had total releases and transfers of 203,175,218 Ib/yr. In other cases,
only a 2-digit SIC code is reported by the manufacturer. An as example, there are 14
streams within SIC 21 which are identified by only the 2-digit code. The sum of
releases and transfers of these chemicals is 14,528,072 Ib/yr, which is large than the
sum of releases for all 3-digit SICs within 2-digit code of 21. In contrast to the
confusion at the 3- and 4- digit SIC code levels, there is relatively little multiple
counting at the 2-digit SIC code level. (Thus, the results of the analysis presented
below focus on the 2-digit level.)
RESULTS
As shown in Table 1, the Chemical and Allied Products Industry (SIC 28) is the
major contributor to the total releases and transfers reported through the TRI in 1987.
More than 47 percent of the total annual releases of industrial toxic chemicals is from
chemical industries. Primary metals (SIC 33), paper and allied products (SIC 26), and
transportation (SIC 37) are the other major contributors to total releases of TRI
chemicals with 13.7 percent, 5.6 percent, and 4.3 percent of the total annual release,
respectively. It must be noted here that including the "multiple 2-digit codes" category,
with a contribution of 8.4 percent to the total TRI releases and transfers3, introduces
uncertainty.
Table 1 also lists the rankings of industry sectors based on emissions
normalized by production indicators. The rankings of TRI releases and transfers,
normalized by economic measures are roughly similar to the ranking by total mass of
TRI releases and transfers for all but five 2-digit SICs. The exceptions are the SICs
21, 25, 29, 31, and 35. Four of these five SICs rank higher using normalized indices
than when the rankings are based on total releases and transfers. Only SIC 35
appears substantially greener when normalized indices are used.
Although the renkings of these five industry sectors vary when normalized indices are
used instead of total releases and transfers, the rankings based on the normalized
economic indicators (ratios 1 through 6) are relatively consistent, with one notable
exception. Tobacco manufacturing (SIC 21) ranks how based on normalized TRI
57
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emissions and also based on emissions per value added and value of shipment. Its
rank according to the emissions normalized by number of employees is relatively high,
however.
CONCLUSIONS
The primary goal of this preliminary research report has been to assess the
effect that the use of different measures of production may have on normalized
measures of pollution prevention. This limited analysis shows that the choice of a
particular production index for normalizing TRI releases and transfers does not
substantially change the rankings of major industrial sectors. The findings described
in this article demonstrate that the choice of a particular normalized index, consistently
applied , will not substantially influence the perceived environmental performance of
major industry categories. Nevertheless, the normalized rankings are different in a
number of cases from the rankings based on the mass of TRI releases and transfers.
Because facility-specific economic data were not available for this research (such data
are treated as proprietary by the Bureau of the Census), the utility of production
normalized data for the comparison of individual facilities cannot yet be
comprehensively evaluated. Work is currently underway by the Department of Energy
and the Bureau of the Census researchers to couple the Census of Manufactures to
environmental databases at the facility level6. Their effort should provide a more
better foundation on which to judge pollution prevention performance.
REFERENCES
1. R.W. Dunford, R.D. Baker, J.L Domanico, J.L Warren, Alternatives for
Measuring Hazardous Waste Reduction, Final Report, EPA Contract #89-
067, Center for Economics Research, Research Triangle Institute, August
1989.
2. J. Craig, R. Baker, J. Warren, Evaluation of Measures Used to Assess
Pollution Prevention Program in the Industrial Sector, Final Report, EPA
Contract # 68-W8-0038, EPA Office of Pollution Prevention, January 1991,
3. U.S. Environmental Protection Agency, Toxics in the Community, EPA
560/4-91/014,1991.
4. U.S. Department of Commerce, Bureau of Census, Census of
Manufacturers, Summary Series, U.S. Government Office, Washington D.C.,
1989
5. U.S. Environmental Protection Agency, Toxic Chemicals Release Inventory
Reporting Form R and Instructions, EPA 700-K-92-002, U.S. EPA, Office of
Pollution Prevention and Toxics, Washington D.C., 1992.
6. B. Cranford, U.S. Department of Energy, Office of Industrial Technologies,
personal communication, 1993.
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U.S. EPA. REGION I POLLUTION PREVENTION MEASUREMENT ISSUES
Abby Swaine
Coordinator
Pollution Prevention Program
U.S. EPA, Region I
JFK Federal Building, Mail Code - PAS
Boston, MA 02203
PHONE: (617) 565-4523
The following is an overview of the two major measurement topics I will cover in
my short panel presentation. I will address these topics from the point of view of a
regional EPA office, rather than attempting to characterize national EPA thinking.
Although regional offices sometimes pilot test national measurement techniques (for
example, Region I's work in Comparative Risk and Region 10's work on Environmental
Indicators), they generally rely upon national programs to develop analytic and
assessment techniques and policy. The regional perspective is useful, however, in that
way we see how effective these tools are in guiding implementation of programs and
in convincing others that the programs are worthwhile.
Strategic Planning in Region I
Region I was one of the first EPA regional offices to undertake strategic
planning, and from the beginning established pollution prevention as a top priority. Our
"long-term objective" for pollution prevention sets the following ambitious and
admittedly arbitrary goal: to reduce the quantity of pollution produced by all sources in
New England by 30% by 1996 and to avert all future pollution of the Region's
resources." Short-term objectives set for fiscal years 93 and 94 target more easily-
measured goals, expressed in terms of EPA resources expended, that are not really
intended for function as surrogates for the long-term goal.
Our senior managers see a need to justify shifting our staff time and dollars
away from lower-priority traditional activities toward pollution prevention, but are of at
least two minds on how to accomplish this -- whether to undertake a major
measurement experiment that attempts to get as close to true environmental indicators
as possible, or to develop and track more modest surrogates. Holistic environmental
assessment appeals to our identities as scientists and protectors of a specific
geographic area (end ecosystems), but the task is boggling. Surrogates are easier and
more familiar, but are also suspect: we are familiar with the artificial and inflexible
aspects of the "bean-counting" we have done for years to show our management in
Washington that we are fulfilling our statutory and programmatic responsibilities.
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Pollution prevention is bearing perhaps an unfair measurement burden: it needs
to "prove itself" more, and earlier, than our command-and-control programs had to.
We must develop new pollution prevention "beans" to count without much guidance
from law or Washington, and risk that they will be superficial, or embrace the even
more consuming challenge of measuring actual environmental impacts.
The 33/50 Program and the Toxics Release Inventory • ,
One of the crown jewels of the national EPA pollution prevention program, and
one that Region I has taken quite seriously, is the 33/50 program. Here again, EPA
has set admittedly crude percentage reduction goals: a 33% nationwide reduction in
releases and transfers of 17 toxic chemicals by 1992, and 50% by 1995. Based on
tallies of commitments made thus far by companies who have volunteered for the
program, EPA feels the 1995 target will be met. However, measuring actual reductions
is a confusing and touchy prospect, one that is likely to be shouldered mainly by the
Regions.
Region I's questions on the subject are too numerous and complex to
characterize well in brief. Among them are the following:
Can the 1988 TRI data -- an early, spotty reporting year -- function at all adequately
as a baseline? Will the new TRI Form R yield any meaningful information on
production changes and pollution prevention (versus control and treatment) techniques
used, to help us assess if reported changes really signify pollution prevention gains?
Has the downturn in New England industry already hopelessly confounded the data?
To what extent is it appropriate to use more close-up assessment techniques (such as
site visits) to verify Toxics Release Inventory data and progress oh commitments,
given that the 33/50 program is voluntary, and that EPA is offering only recognition in
return for commitments?
Notwithstanding our trepidations regarding data quality and measurement
techniques, and the looming task of assessing progress with these imperfect tools,
Region I is convinced that the 33/50 program is a very useful outreach tool and has
played at least a part in achieving substantial pollution prevention.
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THE USE OF SYSTEMS ANALYSIS FOR MEASURING POLLUTION PREVENTION
PROGRESS IN THE MANUFACTURE OF ELECTRONIC COMPONENTS
Dr. Manjlnl Samlnathan
Dr. Janine C. Sekutowski
and
George Williams, PhD, P. E.
Environmental Technology Department
AT&T Bell Laboratories
Engineering Research Center
P.O. Box 900
Princeton, NJ 08542-0900
PHONE: (609) 639-2473
ABSTRACT
Environmental concerns over waste disposal and efficient utilization of
manufacturing process materials, together with evolving state and federal government
policy on these issues, have led to the development of an on-line Factory Systems
Environmental Advisor for tracking process materials consumption, and the generation
of waste or byproduct (per unit of manufactured product), at each step in the
manufacturing process. Of particular interest to the authors is the manufacture of
electronic components which involves many process intensive, semi-continuous, and
repetitive wet chemical and physical operations, that define circuit patterns on
polymer, ceramic, or silicon substrates. These manufacturing operations typically
involve numerous product codes (having unique processing sequences) and many
processing operations. The value of the application of systems analysis concepts for
environmental considerations to complex sequential manufacturing operations, lies in
its capability to ascertain materials consumption and waste generation at all times, at
the individual process step, manufacturing line, or factory levels, and to provide
process optimization and control from an environmental perspective.
This paper describes the formulation, concepts, and automation of the systems
analysis for electronic components manufacturing. The first step in the analysis is the
identification and quantification of all the input (raw materials) and output streams
(product and byproduct) in the manufacturing process. A proposed scheme is
illustrated to quantify process materials streams through the use of typically available
information residing in incoming and outgoing material data bases supporting the
manufacturing operation. Typical data bases may include: Chemical Tracking Systems,
Bill of Materials data base, and shop production and product routing data bases. The
waste streams will be categorized and quantified using information from the above
data bases coupled with engineering inputs, energy consumption data, shop records,
detailed process audits, physical property data, on-line sensor data from process
streams, the results of laboratory analysis, and stoichiometric calculations.
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A proposed architecture for the application of the Factory Systems
Environmental Advisor to a typical manufacturing process line in a UNIX- (UNIX is a
registered trademark of UNIX Computer System Laboratories) System environment is
illustrated. The major elements of the system are: acquisition of data from available
sources at periodic intervals, a menu-driven interface for engineering input, automatic
and on-demand report generation, and a user interface to query the system. A major
element for future incorporation in the Systems Advisor Platform is the "Smart"
Analysis Module which provides intelligent manufacturing systems assessments having
environmental impact at both the micro- and macro- manufacturing levels, and
recommends process alternatives or control using knowledge of best available process
technology.
As environmental regulations and reporting criteria evolve relative to
manufacturing waste and materials utilization, the authors anticipate a trend towards
the application of "Smart" Systems Advisor concepts to manufacturing operations. The
proactive development of these systems today will serve to prevent pollution and
reduce manufacturing costs.
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MEASURING ENVIRONMENTAL PERFORMANCE
Thomas W. Zosel
Manager
Pollution Prevention Programs
3M Company
900 Bush Avenue
St. Paul, MN 55144
PHONE: (612) 778-4805
How to measure the success of a company's or a facility's environmental
performance has been a question that has significantly increased in importance as
environmental issues have become the concern of top corporate management. Many
corporations are spending a significant portion of their capital and operating
expenditures on environmental issues. Top management wants to have ways of
measuring the results of these efforts.
As environmental managers within a corporation, we need to determine what
measurements need to be taken and reported to top management. We also need to
remember that there are many others that are interested in our company's or our
facility's environmental performance.
The communities in which our plants are located may be extremely interested in
. what we are releasing into the environment. The customers of our products have an
interest and potentially a legal requirement in knowing what materials are in our
products or are used in their manufacture. Of particular legal interest today is if CFC's
are used in a product's manufacture.
And of course the environmental agencies have a distinct interest in tracking
environmental performance. However, in this case, we do not have much choice in
conducting the measurements. Our permits, our plant's operations, and as the criminal
aspects of many laws are implemented, our personal freedom may depend on these
measurements.
When all of these stakeholders are taken into consideration it becomes obvious
that there is no single environmental metric or one single measurement system that
meets everyone's needs.
Let's just look at some of the advantages and disadvantages of some of the
metrics that are currently in use. Perhaps the data that has been given the most
publicity in the last few years has been the SARA Toxic Release Inventory (TRI)
reports. This information is the actual measurement of the releases into the
environment of a selected list of "toxic" chemicals.
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This is the measurement system that is generally focused upon by the local
community, by environmental groups, and by the media. It gives them a single number
which has some degree of reference to a facility's environmental performance.
However, the SARA TRI numbers do not take into consideration the risk associated
with these releases. A very small quantity of a potent carcinogen may pose a
significantly greater health risk than a large quantity of a mild irritant. The SARA
numbers do not make this differentiation.
Even with that inherent flaw, the SARA releases have become the focal point
for environmental groups, the local communities, and the media. The primary reason
for this is that the numbers are very easy to understand. This is of particular value to
the media. This is a single "pounds per year" number and this can easily be compared
to past performance. In addition, since all major manufacturing facilities are required to
file this report on a yearly basis, there is the ability to compare a specific facility's
releases to other similar plants in other locations.
This comparison is being used by many of the environmental organizations to
push plants with high releases to meet the lower levels of comparable facilities. There
has even been suggestions that this could be the foundation for legislation. Today in
the air regulation area, new sources in non-attainment areas are required to meet
Lowest Achievable Emission Rate standards. This is the lowest emission rate that is
achieved in practice or is required by any state law or regulation.
In a similar vein, new plants could be required to meet a "Lowest Achievable
Release Rate". This would be the release rate to all media that is achieved by the
best performing similar manufacturing facility. This type of regulation could be
extremely burdensome and raises some very disturbing issues regarding proprietary
information.
The basic concern is that the best performing plants may be achieving these
exceptional results through the use of proprietary technology. Could this type of
legislation result in a mandate that the superior yet proprietary technology be shared
with one's competitors? Even if a licensing fee was offered, the mandatory release of
this technology would create a significant monetary and competitive loss for the
company which developed it.
While there are many ways in which the SARA TRI information can be utilized,
the development and reporting of the data is determined through published
requirements. A plant or a company does not have much leeway in how this is done.
Consequently, the company does not really have the ability to modify the data to best
suit its individual needs. This means that facilities and companies must develop the
SARA data but may also want to consider the development of other metrics that are
more utilizable for internal environmental performance measurements.
At 3M, we have been quantitatively measuring environmental performance
since 1975. The initial measurement system which we have kept in place since its
inception, has been the measurement of the pollution that has been prevented under
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SM's Pollution Prevention Pays (3P) program and the monetary savings that have
been accomplished through these efforts. While this metric does not indicate total
environmental performance, it does apply to an extremely important issue for top
corporate management. This metric tracks the amount of pollution that has been
prevented through cost effective projects.
It emphasizes to all employees that there are actions which they can take to
reduce both the actual volume of pollution which is being generated and the monetary
savings that are accomplished through these actions. However, this metric did not
address the reductions that were being achieved on a basis that was indexed to
production, nor did the system include reductions that were achieved that were not
reported as specific projects.
In the late 1980's 3M began looking at ways in which we could measure and
report waste and waste reductions that would better fit into a Total Quality
Management program. The criteria which we established for this system was that it
needed to be simple yet be accurate and reproducible. It needed to be indexed to
production so that the waste was viewed in relationship to the total plant output. The
system needed to measure the reduction in waste through pollution prevention which
3M defines as source reduction and environmentally sound reuse and recycling. It also
needed to accomplish this measurement before the waste was subjected to treatment,
control, or disposal. And finally, the system needed to be amenable to the
establishment of goals on both a total corporate and on an individual division basis.
After considerable discussion and pilot projects on different measurement
schemes, a system was implemented in 1990. This system classifies the outputs from
a production facility into one of three categories:
Product - this is the intended output from the manufacturing facility.
By-product - this is the residual from the operations that is then productively
used through some form of recycling or reuse.
Waste - this is the material that is subjected to waste treatment, pollution
control, or is directly imposed upon the environment.
Together these items add up to be the total output from the manufacturing
facility. The metric that is then reported is the waste ratio which we define as:
Waste
Waste + Byproduct + Product
Waste
Total Output
This metric is, in a manner of speaking, a measurement of manufacturing
efficiency. If the waste ratio is zero then all raw materials are being productively used.
This does not mean that the plant's processes are 100% efficient, that all raw
materials are being converted to product. We all know that for the majority of
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operations, this is a total impossibility. However, to say that all materials are going into
product QL are being reused or recycled makes the attainment of zero waste within
the realm of feasibility.
At 3M, this waste ratio is reported on a divisional basis. It is not solely a plant
issue. The manufacturing people can make significant contributions but there are
many others that are also necessary to the full implementation of waste reduction and
pollution prevention. The Research and Development scientists need to develop new
products and new processes that generate less waste. The Engineers need to design
equipment that is more efficient and will accept recycled or reused materials. And let's
not forget marketing. They need to know which products generate the least amount of
waste and sell them in preference to the high waste generating products. In short,
waste reduction and pollution prevention is everyone's job. If our objective is to
change the corporate culture and the way that we view environmental waste, then
each and every employee must see that they can participate and play an integral part
in the program.
Now, let's take a more detailed look at exactly how 3M facilities are measuring
our wastes. The objective is to have a single number for each division, therefore we
do not need to actually measure each specific waste stream, but we need to find ways
of accurately measuring all of the wastes that are generated by that division or facility.
What we have found is that currently there is an extensive amount of
information in various databases that, if properly integrated, can be used to calculate
the waste that is generated. In doing this, we at 3M have divided the waste
measurement into five specific categories.
1. Chemical Waste
2. Trash
3. Organic Waste (air and water)
4. Particulate Waste (air)
5. Water Waste (excluding the water)
If we look at these categories, we find that the measurement of each is
relatively simple.
If we define this category as all of the material which is included on a RCRA
required manifest, then finding out how much is generated is as simple as tapping into
the database that contains the manifested information, since the quantities are
required on the manifest. If this information is not in a database it may be necessary
to calculate by hand, but there is no question that the information is available. If it is
not, the facility and the company's management personally has a much greater
problem than measuring waste.
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Trash
Many people do not realize it but most of the major landfills in the United States
already weigh the amount of trash which is sent to their facilities. They normally have
a truck scale that weighs the truck on the way in and on the way out. The difference is
the amount of waste that was dumped. It is generally fairly easy to make
arrangements with the landfill operator to obtain this information.
If the local landfill does not weigh the trucks, we have found that it is relatively
simple and inexpensive to find a truck scale in the local area that can accomplish this
weighing procedure.
Many people have said that because of the extreme difficulty in measuring
organic releases into the air, particularly from fugitive sources, that obtaining a value
for organic wastes is next to impossible. That is probably correct if you attempt to
measure each air stream. However, If you measure by difference using a material
balance, things become much simpler.
If you look at how we have formulated the definitions, the organic waste would
be the total amount that is brought into the plant minus that which goes out as
product, that which is shipped off-site as chemical waste, that which is shipped off-site
for recycling, and that which is consumed or reacted in a chemical process. Each of
these individual items are relatively easy to calculate. The amount of total volatile
organics brought into the plant should be available from purchasing records. The
amount shipped in the chemical waste should be available from the manifests. The
amount that is shipped for recycling should be available from shipping record. The
amount which is reacted or consumed should be available from production or process
engineering yield or production data. The remaining amount is the volatile organic
material that is waste before it is subjected to treatment or pollution control. Granted,
you may not know exactly where it went but for the purposes of this metric to show
management the progress that is being accomplished, this detailed information is not
necessary.
The majority of particulate waste will actually be measured in the other
categories. Material that is collected from dry control systems such as bag houses, will
either be in the chemical waste measurement if the material is hazardous, or in the
trash measurement if the material in non-hazardous. If a wet control system is used,
the material will end up in the water waste measurement. With this in mind, the actual
particulate waste that is in an air stream is very small and in most cases, can be
neglected. In those few cases where it is relevant, an actual measurement system
may be needed.
Since the objective is to get a measurement of the total waste and not of the
individual components, the amount of waste in the water can be determined by a
simple total solids analysis. This also takes into consideration the fact that any
organics in the water have previously been accounted for in the organics categories.
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Establishment of Goals
This metric and measurement system was implemented throughout 3M in 1990
with that as a base year. 3M management then established a waste reduction goal of'
35% by 1995 -- we called it Challenge 95 and asked each division to accomplish a 7%
per year reduction in the rate of waste generation in each of the next five years.
In 1991 3M accomplished an 8.3% reduction in the rate of waste generation
and it appears that our accomplishments for 1992 will also be ahead of schedule.
Summary
The metrics that are required by laws and regulations can be useful to indicate
environmental performance but are not suited for internal corporate purposes Usinq
existing databases that are currently available 3M has developed a waste metric that
conforms to a Total Quality Management structure, is simple yet accurate is a qood
employee motivator, can be utilized to establish goals, and after three years of
experience has proven to be effective in accomplishing waste reductions and pollution
prevention.
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Section B
CONTRIBUTIONS BY PARTICIPANTS
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BUILDING THE INFRASTRUCTURE FOR POLLUTION PREVENTION
Dana Berkley
Environmental Consultant
Arizona Public Service Company
P.O.Box 53999, Mail Station 9308
Phoenix, AZ 85072-3999
PHONE: (602) 250-3838
Arizona Public Service Company (APS) is an investor-owned electric utility
serving over 200 communities in Arizona. Our mission is to be one of the top five
investor-owned electric utilities in America. Our success in achieving this goal will be
measured, in part, by our environmental performance.
APS operates a nuclear power plant, two coal-fired plants, four gas and oil
plants, and a hydro plant. Sen/ice centers are located throughout our territory. Aside
from our primary function of electricity generation and distribution, the utility business
includes activities such as vehicle maintenance, instrument repair, and the operation
of paint shop, a photo shop, a transformer shop, a meter shop, and a carpenter shop.
Field work is also essential to the daily operation of our business.
As indicated by diversity of our operations, APS has many small waste streams.
These waste streams necessitate a dramatic change in environmental culture if APS
is to succeed in focusing its efforts on proactive prevention, rather than on pollution
control engineering and compliance issues as has been done in the past.
Initial evaluation of company-wide pollution prevention efforts revealed that
many different pollutants were being reduced or eliminated throughout the company.
These efforts were not, however, being measured or coordinated with others. From a
corporate perspective, our goal is to educate our employees on the concept of
pollution prevention, reinforce the message that everyone's commitment is necessary,
and create the infrastructure to support current and future pollution prevention efforts.
A common corporate focus will act as surrogate to accomplish these goals.
APS initiated a pollution prevention pilot with a corporate critical success
indicator to reduce the use of chlorinated solvents by 100% as of January 1, 1995.
The solvents targeted are 1,1,1-trichloroethane (methyl chloroform), carbon
tetrachloride, methylene chloride, trichloroethylene and tetrachloroethylene. Though
the volume of products containing these chemicals is relatively low, they are used
throughout the company in a diverse range of applications.
By establishing a narrowly-focused indicator, APS now has a specific issue to
rally around. We are able to raise the general level of awareness around chlorinated
solvents and educate our employees as to what types of products may contain the
targeted chemicals. Everyone in the company is asked to look at their products since
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these chemicals can be found in products ranging from degreasers to adhesives to
insecticides. This will assist in changing the culture by making employees more
comfortable with chemical names. We hope to raise our employees' comfort level in
the same way that, as a society, we have become familiar with computers over the
past two decades.
As products containing these chemicals are identified, we will begin to share
information on potential substitutes. This will encourage teamwork and enhance our
communication efforts. In parallel, APS is working to interface our purchasing system
with our chemical tracking system, allowing the product to be reviewed and approved
and the chemical composition recorded before it is brought on-site. A system that is
integrated in this manner will enable APS to identify, measure and track chemicals.
This capability will allow us to implement additional proactive environmental programs
with measurable results.
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STATEMENT OF PROFESSIONAL INTERESTS
Barbara L. Bush
Senior Regulatory Analyst
American Petroleum Institute
1220 L Street NW
Washington D.C. 20005
PHONE: (202) 682-8325
Five years as Senior Regulatory Analyst with the American Petroleum Institute
(API) with duties that involve the management and implementation of key health and
environmental programs related to pollution prevention and waste minimization for the
petroleum industry. This includes management of research activities to develop tools
to assist member companies in the development and implementation of pollution
prevention programs within their operations. Specific on-going research activities
include: (1) an annual survey of wastes and residuals generated and managed at
petroleum refineries that captures quantitative information on source reduction
activities underway within refineries, (2) an engineering design and construction study
of a refinery process unit that suggests ideas for how environmental release can be
minimized while maximizing energy efficiency, and (3) an case study at a refinery that
demonstrates how existing accounting systems are used to fully identify the costs of
waste generation and management.
Selected Publications
1. American Petroleum Institute, Waste Minimization in the Petroleum Industry:
A Compendium of Practices. API Publication 302, 1991.
2. American Petroleum Institute, Generation and Management of Wastes and
Secondary Materials: 1989 Petroleum Refining Performance. API
Publication 303, 1992.
3. American Petroleum Institute, Responding to Environmental Challenge: The
Petroleum Industry and Pollution Prevention. API Publication 312, 1992.
4. American Petroleum Institute, Environmental Design Considerations for
Petroleum Running Crude Processing Units. API Publications 311, 1993.
5. Bush, B.L., The Pollution Prevention Research Program of the American
Petroleum Institute. Presented at the Air and Waste Management
Association annual meeting June 1992.
6. Bush, B.L, Measuring Pollution Prevention Progress: How Do We Get
There From Here? Pollution Prevention Review 2:431-443, 1992.
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MEASURING PROGRESS IN POLLUTION PREVENTION
Barry F. Dambach
Senior Environmental Engineer
AT&T
131 Morristown Road, Rm B2237
Basking Ridge, NJ 07920
PHONE: (908) 204-8237
My current work area is to implement Pollution Prevention (PP) throughout
AT&T. We are presently working on implementing the results of a PP Benchmarking
project that included interviews with 3M, Dow, DuPont, Xerox, H.B. Fuller, Intel and
AT&T.
The data from the interviews was analyzed and grouped into elements critical to
the success of a corporate wide PP program. Two of these critical elements were
"monitoring progress/metrics" and "reward/recognition", which ties into the metrics
issue also. It was recognized that there must be some methodology to evaluate how
well the program is succeeding for both environmental and business reasons.
At this point in time, AT&T has corporate environmental goals for which we are
tracking progress, but it is mostly "end-of-pipe" type metrics. We still need to develop
new metrics that will track and promote pollution prevention and tie into the business
performance of the company. This is the type of information that I hope to get help on
from this seminar.
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MEASURING POLLUTION PREVENTION EFFECTIVENESS
Lisa Dufresne
Toxic Use Reduction Engineer
and
Paul Richard
Massachusetts Office of Technical Assistance
100 Cambridge Street, Suite 1904
Boston, MA 02202
PHONE: (617) 727-3260
OTA has seen industry measure its own effectiveness in pollution prevention.
Some of the key results common to a successful pollution prevention program include:
• reduced use of toxic chemicals,
• elimination of toxic chemicals through substitution, process modification,
product reformulation,
• improved end of pipe compliance, '
• improved business economics, • j
-' ,->--'"
• more efficient process, * ' *••
• defined procedure for applying pollution prevention concepts (like
implementing a pollution prevention of toxics use reduction team and
policies),
• clear accounting system for money spent and actual product costs,
• clear inventory system for chemicals,
• clear environmental auditing system.
Case studies show how all of the above benefits were measured in different
companies, and other benefits derived from the measurement system itself that are
not readily apparent. These include:
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1. The ability to locate a non-compliance situation quickly.
EXAMPLE
- A company had a copper discharge issue and because they had such a
good handle on their process, they immediately could locate the operation
and piece of equipment that caused the problem.
- A company had a discharge issue with a metal, and was able to trace it
back to a particular process and determine that the metal was in a product
but was not listed on the MSDS. Contacting the supplier confirmed the
metal was in the product, and they were able to rectify the non-compliance
situation.
2. The ability to determine whether a process line is making or losing money.
EXAMPLE
- A company thought one of its process lines was marginally profitable. After
implementing a measurement system for TUR, they were able to better
quantify the cost of running the line, determined it was losing money, and
dropped it.
In addition to added benefits, OTA has found some impediments to effective
measurement of pollution prevention. Sometimes OTA works with state schools and
gets graduate students involved in assisting companies, however it was difficult to
transfer money from the state to the State school.
There are levels of effectiveness for measurement. Again, case studies
illustrate examples of how companies can implement and measure pollution prevention
in stages.
• Pollution prevention measure (actual reduction in pollution and TUR) right in
the facility,
• measure of reduced loadings at local POTW due to TUR at facility,
• more efficient use of chemicals without changing them, etc.
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MEASUREMENT TOOLS TO SUPPORT POLLUTION PREVENTION
Margaret Flaherty
Environmental Research Analyst
and
Ann Rappaport, PhD
Center for Environmental Management
Tufts University
Medford, MA 02155
PHONE: (617) 627-8558
Since 1988, Margaret and Ann have been collaborating on projects that seek to
advance understanding of corporate decision making with respect to the environment.
They explored the complex process in which multinational companies make decisions
on how to implement environmental programs in the different legal, social and
economic regimes in which their disparate operations are located. In the course of
that research, it became clear that corporate decision makers were very interested in
knowing how their environmental programs compared to those of their corporate
peers. It was possible to compare types of activities, but few companies had
established measurement systems that would enable managers inside or people
outside the organization to draw conclusions about the effectiveness of programs that
had been implemented.
In research on the development and transfer of pollution prevention technology
within a multinational corporation, Ann found that extensive formal and informal
communication was associated with more effective transfer of technology. One
element of communication is describing in quantitative terms the reductions that
resulted from pollution prevention projects.
The current project builds on earlier work, and focuses on Management Tolls to
Support Pollution Prevention. Outlined below are components of the two-year effort:
I. Benchmarking Seminar Convene corporate leaders, government decision
makers, academics and interested others to exchange information on analysis
systems and measurement schemes for pollution prevention. Identify
leadership firms, and chart directions for future research. A seminar was
chosen as the most effective approach to encouraging: mutual learning;
exchange of know-how among corporate participants as well as across sectors;
and serious reflection that will advance the state of knowledge as in the field.
II. Case Studies Following the benchmarking seminar, researchers will identify
companies where pollution prevention measurement is in place, or being
implemented, and will undertake selected case studies. Attributes of
measurement systems, and strategies for their implementation will be explored.
In at least one case, field research will be conducted to examine pollution
prevention practice in developed and developing country facilities of the same
multinational corporation. Key questions to be addressed include: What role
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does pollution prevention measurement play in observed outcomes? How is
measurement technology transferred? Is the technology adapted to fit
requirements of multiple locations? If so, why and how?
Seminar participants are encouraged to discuss with Margaret and Ann their
interest in participating as case companies.
III. Simulation Modeling The project supports a post doctoral research fellow
based in the Pollution Prevention Research Branch of the Environmental
Protection Agency's Risk Reduction Engineering Laboratory. Dr. Rada Olbina,
who was previously with the International Centre for Chemical Informatics at the
University of Ljubljana in Slovenia, has an established record in research on
waste management, information sciences applied to environmental issues, and
computer simulation to identify pollution prevention opportunities. Dr. Olbina is
building on her experience by developing several computer supported methods
to enhance the prediction capability of simulation models, thus making them
more useful to decision makers.
IV. International Seminar Proposed for the end of the second year (May/June,
1994), an international seminar on pollution prevention will enhance
opportunities for mutual learning and dissemination of research results. Case
study results will be presented and discussed, and leaders from industry, a
variety of governments, non-government organizations and academia will be
convened to examine opportunities for developing innovative policy and
management initiatives within government, corporations and other institutions to
promote pollution prevention.
Selected Publications
1. Flaherty, M., Rappaport, A., Multinational Corporations and the Environment: A
Survey of Global Practices, Medford MA: Center for Environmental
Management, Tufts University, May, 1991.
2. Rappaport, A., Flaherty, M.F., Corporate Responses to Environmental
Challenges: Initiatives by Multinational Management, Westport, Conn.: Quorum,
1992.
3. Rappaport, A;, Flaherty, M., Multinational Corporations and the Environment:
Context and Challenges, International Environment Reporter Vol. 14, No. 9, pp.
261-267, May8, 1991.
4. Rappaport, A., Dillon, P., Private-Sector Environmental Decision Making, in
Richard A. Chechile and Susan Carlisle eds. Environmental Decision Making: A
Multidisciplinary Perspective, New York: Van Nostrand Reinhold, 1991.
5. Rappaport, A., Development and Transfer of Pollution Prevention Technology,
Westport, Conn.: Quorum, in press.
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MEASURING TOXICS USE REDUCTION
AT THE PRODUCTION-UNIT LEVEL
Timothy J.Greiner
and
Joseph Paluzzi
Massachusetts Office of Technical Assistance
100 Cambridge Street
Boston, MA 02202
PHONE: (617) 727-3260
Lori Columbo
Sandra Wyman
Chris Witchard
The Environmental Careers Organization
Boston, MA
ABSTRACT
In a study to assess toxics use reduction among a subgroup of Massachusetts
manufacturers, 110 firms were studied from a stratified random sample of metal
intensive producers (SIC 34-39). Seven percent of the mostly small and medium
sized firms documented and measured their toxics use reduction changes on their
own unless required by state law. Of those that did measure their progress, roughly
half did so accurately. To address one of the predominant toxics use reduction
measurement problems, normalizing toxics use reduction changes for production level,
we experiment with linear regression techniques. Linear regression is used to
determine whether normalization factors correlate to toxics use. The study documents
over 2.4 million pounds of toxics use reduction, mainly acids and solvents, from 28
firms.
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ENHANCING ENVIRONMENTAL RETURN ON INVESTMENT
John Paul Kusz
Manager of Product Development
Safety-Kleen Corporation
Elgin, II 60123
PHONE: (708) 697-8460
The work being pursued currently at Safety-Kleen Corporation has focused
largely on pollution prevention through the application of life cycle concepts to the
development of new products and the redesign of existing products. Measuring
progress has been accomplished by assessing actual material reductions in products,
waste reduction associated with product use, and product life extension. We are also
implementing systems for the recovery of the materials embodied in the products
subsequent to their use.
Applying this closed-loop stewardship approach to the products provided by the
Company is an extension of the recycling philosophy on which Safety-Kleen's core
business was established.
An example of redesign resulting in pollution prevention can be exemplified in
the redesign of a hazardous waste container in 1985. The Company used open head
steel drums to recover still bottom waste from dry cleaning plants. The drums were
used an average of only 1.5 times before disposal was necessary as a result of
denting, rusting, and potential corrosion. The cost of drum replacement was
approximately 1.3 million dollars per year.
A redesign of an open-headed container made of rotationally molded medium
density polyethylene with high stress crack and impact resistance has proven to be a
viable solution that significantly increases product life, reduces risk associated with
product transport and allows for controlled and cost-effective destruction of the
container when its utility has been exhausted. The container is easier to maintain and
handle and has exceeded its projected life of four to five times that of the original steel
drum.
The environmental benefits of the product have been augmented by turning
what was an annual loss of 1.3 million dollars in product to a profit of 500,000 dollars.
The annual economic value of the redesign is 1.8 million dollars. In this concurrent
project, the Company was able to improve a product technically, operationally,
economically, and environmentally with quantifiable results through comparative
analysis.
The product was designed in 1985 and was recognized as a "Design of the
Decade" by the Industrial Designers Society of America, for innovative solutions in
1989. The product is made of a material which contains a high energy value (17,000
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to 19,000 BTU's per pound). It therefore can be recovered after its useful life for
energy -- a choice more appropriate than recycling in light of the potential for
contamination with hazardous materials over its lifetime.
A number of the Company's products have been redressed in order to minimize
materials and maximize material recovery. Using the simple hierarchy of reduce,
reuse, and recycle has had a significant impact on resources used, reused and
recovered in the equipment manufactured by the Company. A conscious effort to
retain the product in order that it might be managed has been an underlying
philosophy which allows for this form of stewardship.
The implementation of these footprint-reduction strategies has proven both
environmentally and economically beneficial.
Realizing that all products are components of larger product delivery systems
has resulted in an essential shift in the concept phase of our product development
efforts.
We have begun to look much more closely at the utility needed by the end user
and how we might provide the result desired with the lowest possible environmental
burden.
By using the conventional comparative analysis that allows for examining the
potential economic return on any given investment, such as a product improvement,
and including the real or perceived environmental benefits or costs related to those
product improvements, what might be called an "environmental return on the
investment" can be assessed. Our experience has shown that in many cases these
environmental benefits can be quantified economically and result in an economic
improvement as well. Implementing product improvements that fall into this "win-win"
category becomes the first order of business in reducing the environmental footprint
related to any product and/or product system.
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DEVELOPMENT OF A COMPUTERIZED INTEGRATED INFORMATION SYSTEM
FOR POLLUTION PREVENTION
Rada Olbina, PhD
Visiting Scientist
US EPA, RREL
Pollution Prevention Research Branch
26 W. Martin Luther King Avenue, Mail Stop 466
Cincinnati, OH 45268
PHONE: (513) 569-7526
The Pollution Prevention Research Branch of the US EPA's Risk Reduction
Engineering Laboratory in Cincinnati, OH, has shown interest in the development of an
Integrated information system for pollution prevention (P2). Following is an
abbreviated description of the project:
Available on-line, CD-ROM and conventional sources of information are being
searched to acquire relevant data on P2 measurement concepts, methodologies and
applications. Comparative analysis of over 30 papers has shown that many different
approaches to P2 measurement in industrial production have been used, and that the
majority of the approaches deal with measurement of P2 quantity, while very few deal
with toxicity.
Criteria for selection of the most appropriate P2 measurement concept will be
developed. Furthermore, parameters of a model of an industrial production and waste
generation system will be defined and the boundaries of such a system will be
determined. Computer simulation will be applied to study the system capability and
behavior under a variety of conditions. The model for measuring of P2 in an industrial
sector will then be a basic part of an information system. The information system will
include quantitative and qualitative data on industrial production processes, including
Standard Industrial Classification (SIC) number, raw and other materials, production
technology types, products, energy consumption, waste and wastewater generation.
Databases on P2 strategies as well as waste management technologies will also be
incorporated into the system (Fig. 1).
Taking into consideration that there are numerous types of waste and
numerous data for their proper identification as well as constant updating in legislation
and regulations, it is more than obvious that information on waste management
systems needs to be integrated into a computer supported information system for
pollution prevention.
The functions of such an information system are to select pertinent data from
the infinite variety of available sources, to create information by applying the
appropriate tools to data selected; and to communicate the information to the user. In
short, information systems deal with collection, storage, processing, transmission,
retrieval, distribution and utilization of information.
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An integrated information system for P2 could provide governmental institutions with a
powerful tool for implementation of P2 strategies and introduction of efficient waste
minimization practices by:
1. prediction of waste and/or wastewater generation in industrial sectors,
2. introduction of process optimization while minimizing waste in production
processes,
3. suggestion for application of P2 strategies,
4. measuring achievement in P2.
REFERENCES
1) "The EPA Manual for Waste Minimization Opportunity Assessments",
EPA/625/7-88/003, U.S. EPA, Risk Reduction Engineering Laboratory, Office of
Research and Development, Cincinnati, OH 45268, pp.97 (July 1988)
2) "Evaluation of Measures Used to Assess Progress in Pollution Prevention",
U.S. EPA, Pollution Prevention Office, Pollution Prevention Division,
Washington, D.C., and Center for Economic Research, Research Triangle
Institute, Research Triangle Park, NC, pp.52 (April 1990)
3) R.B. Pojasek, L.J. Cali, Measuring Pollution Prevention Progress, Pollution
Prevention Review, pp. 119-29 (Spring 1991)
4) P.D. Harper, Application of Systems to Measure Pollution Prevention, Pollution
Prevention Review, pp. 145-53, (Spring 1991)
5) Industrial Pollution Prevention Opportunities for the 1990s, EPA 600/8-91/052,
U.S. EPA Office of Research and Development, Washington, D.C. 20460, pp.
60 (August 1991)
6) Glazar, S.A., Olbina, R., Vrtacnik, M., Model of an Integrated Information
System for Pollution Prevention and Control, Workshop, Zeleni Slovenije,
Ljubljana, Slovenia, pp. 17-25 (May 21, 1991).
7) D.G. Willis, Pollution Prevention Plans -- A Practical Approach, Pollution
Prevention Review, pp. 347-55 (Autumn 1991)
8) R. Olbina, Computer Supported Modelling of Hazardous Waste Management,
Dissertation, University of Ljubljana, Faculty of Science and Technology, 95-
101 (October 1991)
9) Facility Pollution Prevention Guide, EPA/600/R-92/088, U.S. EPA, Office of
Research and Development, Washington, D.C. 20460, pp.143 (May 1992)
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POLLUTION PREVENTION INTEREST
David Panco
Program Manager
Weyerhaeuser Company
Environmental Sciences and Technology
Corporate Research and Development
WTC 292
Tacoma, WA 98477
PHONE: (206) 924-4441
Weyerhaeuser Company is principally engaged in growing and harvesting
timber; the manufacture, distribution, and sale of forest products; and real estate
development and construction. Its principal business segments include timber lands,
wood products, and pulp and paper.
The Environmental Sciences and Technology group provides specialized
scientific and engineering support, primarily, to Weyerhaeuser's manufacturing
operations. Our staff of about 40 works directly with facilities across the U.S. and
Canada - including 12 primary pulp and paper manufacturing sites, sawmills, plywood
and composite panel plants, and a growing network of recycling facilities. We also
provide technical support to the Office of the Environment and the corporate level, and
execute research programs with sponsorship from both Weyerhaeuser Paper
Company (mid-term targets) and corporate (longer-term targets).
Pollution prevention and product life cycle analysis are among the topics we
have decided warrant particular attention. Specific topics of interest include:
Measuring economic results - accounting and financial analysis methodologies;
Integration of pollution prevention options into business planning processes and
investment decisions; and
Current best practices in pollution prevention measurement.
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INTEREST IN THE FUGITIVE EMISSION REDUCTION
Elizabeth Pfeiffer
Manager
Environmental Services
Givaudan-Roure Corporation
P.O.Box 560
East Hanover, NJ 07936
PHONE: (201) 386-9800
My major interest in the area of pollution prevention is the reduction of volatile
organic emissions primarily from fugitive sources.
Givaudan-Roure is currently integrating several separate operating facilities into
a single operating facility, and will be installing a biofiltratlon unit to capture most of its
process emissions; however, we are still faced with significant fugitive emission
releases.
Due to the complex nature of our distillation and extraction processes, we are
faced with the issue of having many portable pumps as well as many flanges and
valves. Our process engineering department have been investigating alternative
controls including new seals for pumps and welding flanges wherever possible;
however, it is not feasible to use certain types of seals in our facility.
I am, therefore, interested in learning how other facilities are controlling fugitive
emissions and the cost of doing so.
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TURA COMPLIANCE AT MERRIMACK VALLEY WORKS
Anne Reynolds
Environmental Engineer
AT&T
1600 Osgood Street, Department 209100
N. Andover, MA 01845
PHONE: (508) 960-4475
Merrimack Valley Works is AT&T's largest single manufacturing plant. Two
business units have manufacturing operations at the facility. About 6,000 people are
employed at the plant which operates three shifts. A large part of the facility is
devoted to the assembly of telecommunications equipment. The Transmissions
Systems Business Unit was a 1992 Winner of the Malcolm Baldridge Quality Award.
Two-thirds of Transmission System Business Unit's 7,500 US employees work at this
North Andover Massachusetts facility.
The Microelectronics [Business Unit manufactures integrated circuits at the plant
and this is the most chemically intensive manufacturing at the plant. Under the
Massachusetts Toxics Use Reduction Act, the facility is required to report chemical
usage on a unit of product basis. Electronic circuit manufacturing consists of a
selective addition and removal of layers of conductive and non-conductive material.
Some of these layers are added or removed by chemically intensive processes. The
number of layers varies on different products. Production units at this factory produce
as many as 500 different types of circuits. To accurately calculate the chemical usage
per unit of product it is necessary to know the area of the circuit and the number of
layers or passes through a chemical process the circuit requires. It became apparent
that this could be accomplished very accurately using a manual system. The plant
contracted the Bell Laboratories Engineering Research Group to design a
computerized system for measuring chemical use by unit of product. The system
developed is described in a paper delivered by Dr. George Williams, one of the
principle designers of the system.
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COMPUTER SIMULATION OF FUGITIVE EMISSION MEASUREMENT
Jordan M. Spooner
Process Engineer
US EPA, RREL
Pollution Prevention Research Branch
26 W. Martin Luther King Avenue, Mail Stop 466
Cincinnati, OH 45268
PHONE: (513) 569-7422
Since May of last year, I have been involved in various technical research and
project management efforts as a process engineer for the EPA's Pollution Prevention
Research Branch. This research position is part of a two-year Masters degree
program with Tufts University in Environmental Science and Management. My
research activities have primarily been in the areas of computer process simulation
and pollution prevention (P2) measurement.
The predominant research and project management activity has been in
computer process simulation, as this is the subject of my Tufts University Masters
Report. The objective of this research project is to evaluate the ability of existing
process simulation computer software to be used for industrial process pollution
prevention, and in particular fugitive emissions prediction and estimation. Computer
process simulation involves modeling on a computer any process that can be
described as a compilation of discrete unit operations and flow streams. Developed
and used primarily by the chemical process industries, process simulation has rapidly
emerged as a design and analysis tool that is now used by many different process
industries.
For this project, I began by searching the technical literature for all prior
applications of process simulation for P2. I then gathered information on several
leading commercially available simulation packages in order to examine their basic
features. Presently, I am examining how some of these specific features are currently
applied for P2 and fugitive emissions prediction, and how they might be applied in the
future. I plan to finish with conclusions on the overall P2 and fugitive emissions
prediction capabilities of process simulation software, and also recommendations for
future features and/or applications.
My work in P2 measurement has focused on exploring the development of a
measurement methodology that industry can use on a prdject-by-project basis. This
type of methodology would allow industry to quantify the P2 accomplishment or
potential of each individual project. The project measurement might then be added
with those from other projects in order to quantify P2 at varying levels, such as a
process or facility level. I am interested in somehow applying process simulation in
this effort.
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WORKSHOP RESULTS
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WORKSHOP QUESTIONS FOR WORK GROUPS
Each workgroup should address the following set of questions around the three main
issues:
1. Best Practices in Pollution Prevention Measurement
-What are the practices?
-Who is doing it?
-What industry/product/process lines is it done for?
-What are the advantages and disadvantages?
-Is a method transferable to other companies/industries?
-How can the method be aggregated to the corporate / industry /regional/national
level?
2. Normalizing Production
- When is normalizing production worthwhile?
- What are effective approaches to normalizing production?
- For each approach, what industries does it work for? Which industries does it
not work for?
- How do you establish a meaningful track record - with rapid product change
(e.g. high tech); with change in product mix (e.g. job shops)?
3. Integrated Pollution Prevention Measurement into Corporate Culture
- How do you overcome the barriers to measuring pollution prevention?
- How do financial/accounting methods need to be changed to reflect or
encourage pollution prevention?
- When are different types of measurement useful or not useful?
Each workgroup should develop recommendations for industry, government
and academia on the following topics:
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1. What action should industry pursue to improve pollution prevention
measurement?
2. What additional analysis or research needs to be done to assist industry?
3. How should the EPA and state agencies proceed on setting pollution .„,
prevention measurement policy?
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WORKGROUPS
Group 1
Group 2
Facilitator: Pojasek
Recorder: Dufresne
Facilitator: Griffon
Recorder: Goldberg
Barkley
Coob
Hearne
Mannion
Olbina
Panco
Rappaport
Williams, G.
Craig
Dambach
Flaherty
Greiner
McEntee
Pfeiffer
Reynolds
Williams, T.
Group 3
Group 4
Facilitator: Hart
Recorder: Spooner
Facilitator: Freeman
Recorder: Allen
Bizzozero
Hirschhorn
lezzi
Moore
Noble
Roque
Ross
Zosel
Bush
Cullen
Hawes
Lizotte
Nagle
Price
Swaine
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CLOSING REMARKS
Jim Craig
US EPA, Office of Pollution Prevention and Toxics
(PM 222B)
401 M Street, SW
Washington, D.C. 20005
PHONE: (602) 250-3838
I appreciate the opportunity to give my view of what has taken place at this
conference. It has been an excellent forum for representatives of government,
industry, and academia to share ideas and experiences. As I stated at the beginning
of the conference, EPA is looking to initiate cooperative efforts between stakeholders
in environmental protection. One thing I've noticed is that we're so used to
disagreeing with one another's views that when we meet in a setting like this, before
we can talk about areas of agreement and potential cooperative efforts, we really want
to argue. Happily, we may be running out of things to argue about.
One area of disagreement that is always near the surface, and that came up
here, is the definition of pollution prevention. Does it include recycling? I've been with
the Agency's prevention program for four and a half years - since I'm disposed to
quantifying things, that's almost 10,000 work hours. I feel like I've spent 8,000 of
those hours on this debate. And it's not one of my primary responsibilities. While this
is an important debate, the argument takes time away from focusing on where and
how we can help each other.
I believe many of the other areas of disagreement that have come up at this
conference are much more fruitful areas for discussion. Moreover, we seem to have
gotten beyond the arguments to discuss some potential collaboration, especially in the
breakout sessions. Some of these areas are:
* What level of aggregation (unit, process, facility) is appropriate for national
(and state) reporting requirements?
* What data elements should be included in the reporting requirements?
* Should industry be required to report progress against goals?
We need to take on areas where we disagree, but we need to do so in a
manner that is constructive and collaborative. George Williams of AT&T talked about
an approach that seems to be very constructive. AT&T is positioning itself for
additional reporting requirements, but more importantly, it meets its own potentially
changing needs. By sharing information on this and other approaches, I think we
have moved an important step toward effectively measuring progress for a company's
own uses and toward resolving some of the many issues that remain.
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Let us recognize what this conference has been about. There is a difference
between the level of information needed by government and that needed by industry.
The focus of this conference has been on approaches industry has taken to meet their
own needs. Much information is available, and each speaker has described a system
that works for each company's needs.
We further need to recognize that there are no right and wrong answers to
meeting companies' individual needs. This conference has been an opportunity for
Information sharing. We can't say one approach is best, but if you use one of them
coupled with a problem solving approach, you will likely improve operations, save
money, and reduce loadings on the environment. I also think attendees will be able td
take back suggestions for changes - large and small - to their measurement systems.
Finally, I would like to mention some of the observations or suggestions that
have been made at the conference.
* Put things in terms decision-makers can understand. Just as everyone puts
systems in terms appropriate for their own company, the same ideas may
need to be presented in different ways depending on who is making the
decisions. Also recognize that there may be multiple decision-makers from
different organizations - your boss, upper management, government,
vendors, clients, academia, and the public.
* Continuous improvement in environmental protection is more important than
measurement. But I suggest designing measurement systems that not only
leave resources for environmental improvement, but encourage continued
environmental improvement over time.
* We have a lot to learn from state requirements and experiences. Many
states have detailed information collection and facility planning requirements.
National requirements will not need to reinvent the wheel if we learn from
state experiences.
* Finally, firms differ, especially, small ones. They have differing capabilities
and resources to bring to collaborative efforts and to use in meeting
regulatory requirements.
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SUMMARY OF DISCUSSIONS
The main points of interest concerning measuring progress in pollution
prevention considered by workgroups were the following:
* application of system analysis,
* system inputs and outputs definition,
* databases, simulation and information systems application,
* pollution prevention measurement types and normalization,
* financial aspects,
* management practice.
System Analysis
A system of industrial production has to be defined and boundaries of that
dynamic system have to be determined ("black box"). A time of system observation
has to be considered. A flow diagram representing material balance is the usual
approach of quantifying parameter relationships in an industrial production system.
System Inputs and Outputs Definitions ;
System inputs (raw and other materials) entering into industrial production
process as well as system outputs (products, by-products, process losses, waste,
emissions, discharges, nonproduct outputs, releases) should be precisely defined.
Databases. Simulation and Information Systems
To collect, organize, handle and process data on inputs and outputs
characterizing any industrial production system, a computerized supported database
has to be created. These databases will allow establishment of tracking system for bill
of materials, shop production, and product routing. A computerized system will
provide material accounting, inventory control (for purchasing minimal quantities of raw
materials) as well as computerized integrated manufacturing (CIM). Computer
supported simulation could allow direct observation of a system behavior under a
variety of conditions, while optimization allows scheduling of resources in such a way
that the overall efficiency of the system could be optimized.
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Pollution Prevention Measurement Types and Normalization
A material balance is usually applied to measure pollution prevention in
industry. Terms such as inventory of production and emissions, purchase records,
material inventory, product records and specifications are also being used. Some
companies have developed tracking matrices while others use input, byproduct and
emission reduction indexes, as well as so called point loss measurement.
Normalization of data to present more meaningful pollution prevention
measurement has been used in many different ways. Some practical application
showed industries compare data on system inputs and outputs with previous year data
and adjust for production, while others use material use efficiency expressed in
percentage or economic efficiency. Absolute and normalized pollution levels as well
as absolute and normalized pollution reduction are also used in practice. A statistical
processing of data using normalization factors (independent variables), regression
theory and autocorrelation are applied. The quantity of waste generated is presented
per unit of product. Production index and normalization per unit of product at each
step of production, is used.
Rnancial Aspects
The workgroups agreed that the financial aspects of pollution prevention
measurement are very important. Cost analysis has to serve as a basis for pollution
prevention project selection. Activity based costs (ABC) and/or economic feasibility
analysis have to be determined. In industry, placement of environmental costs have
to be made into separate accounts and it can serve as a powerful tool for resource
optimization.
Management Practice
Total Quality Management - zero losses or 100% efficiency is only a different
name for introduction of pollution prevention practice in industrial production.
Effectiveness is measured by the ratio of waste reduction and production. Important
considerations for industrial management (concerning introduction of pollution
prevention measurement) are time frame, costs, priorities and implementation period.
Material accounting could therefore be considered as a standard management
procedure.
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RECOMMENDATIONS OF THE WORKSHOP
There are different approaches to measurement'of pollution prevention progress
for different conditions. However, measurement has to be quantifiable and repeatable.
A system's units and boundaries have to be defined. Normalization has to be related
to toxicity and to units of production. System analysis approaches should be applied
in handling environmental data which should be organized and centralized. Studies
should be expanded beyond chemical processing sectors. R&D should be directed to
develop systems to make Life Cycle Analyssis (LCA) cost-effective. To achieve these
goals, top-down management commitment should be provided.
The government should maintain maximum flexibility in applying legislation and
regulations related to pollution prevention measurement. It should minimize the
burden of reporting by developing consistent formats and adapt regulations to improve
environmental practices. It should also establish funding for pollution prevention
measurement pilot studies and provide "soft landings" for innovative companies. The
role of government should be a "giant facilitator". It should try to help solve the
problems not to dictate how they should be solved.
*-U.S.COVER>MENT PRINTING OFFICE 1993.750-00?, 80256
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