vyEPA
              United States
              Environmental Protection
              Agency
              Office Of
              The Administrator
              (1102)
EPA 100-R-96-001a
June 1996
Interview Results
Prototype Study Of Industry
Motivation For Pollution Prevention

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            INTERVIEW RESULTS
                   FOR THE
     PROTOTYPE STUDY OF INDUSTRY
MOTIVATION FOR POLLUTION PREVENTION
                       by
                   Ohad Jehassi
                Deborah Milecofsky
                   Susan Peck
                   Manik Roy
                Final Production by

           Laura J. McWhirter, Capt, USAF
        U.S. Environmental Protection Agency
          Pollution Prevention Policy Staff
             Office of the Administrator

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                TABLE OF CONTENTS
PREFACE	m



GLOSSARY OF ACRONYMS	v



APPENDIX E: FACILITIES	El



APPENDIX F: FACTORS THAT LED RESPONDENTS TO BEGIN
          INVESTIGATING POLLUTION PREVENTION	Fl



APPENDIX G: FACTORS THAT INFLUENCED THE MEANS BY WHICH
          RESPONDENTS LEARNED OF POLLUTION PREVENTION OPTIONS...Gl



APPENDIX H: FACTORS THAT INFLUENCED RESPONDENTS' CHOICES OF
          POLLUTION PREVENTION PROJECTS	HI



APPENDDC I: POLLUTION PREVENTION MOTIVATORS MATRLX -
         INDUSTRIAL FACILITIES	II
                              ii

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                                      PREFACE
       This document provides the interview results on which the Prototype Study of Industry
Motivation for Pollution Prevention was based. The primary objective of the study was to
improve not only EPA's understanding of what motivates industrial pollution prevention, but to
allow EPA's stakeholders to advance their understanding as well. EPA recognizes that it does
not have a monopoly on the ability to interpret reports of what motivates pollution prevention.

       For this reason, EPA is publishing in this document the raw data on which the study was
based for anybody who has the interest and energy to explore it. Because EPA believes such
individuals are a subset of those interested in the study's findings, and in order to avoid the
environmental impact and cost of printing the dozens of following pages unnecessarily, this
document is being published separately, with fewer copies printed.

       We have tried to provide the data here in as raw and undigested a form as possible, and
we ask the reader's indulgence for any difficulty in reading this may create.

       A few words must be added about the organization of this document.  The researchers
sought the opinion of forty-two business respondents of what effect 17 possible motivating
factors had on three stages by which a business may be said to choose a particular approach to
preventing pollution.

       Accordingly, the interview results could have been organized in at least three different
ways. First, the information could have been organized by participating business, resulting
essentially in forty-two separate case studies. Second, the information could have been
organized by motivating factor, resulting, for example in a section reporting respondents'
opinions of first planning requirements, then technical assistance, then voluntary programs, and
so on. Third, the information could have been organized according to the stages by which a
business may be said to prevent pollution  these  stages being, deciding to investigate pollution
prevention, identifying and analyzing pollution prevention options, and lastly, choosing a
particular pollution prevention approach.

       Each of these approaches have their strengths and weaknesses. Because we wanted to
discern patterns of behavior across industry  and because we observed that no one motivating
factor operates in isolation from all the others, we chose to organize by the three stages.

       Accordingly, Appendix F lists respondents' comments on the effect that various
motivating factors had on their business's initial decision to investigate pollution prevention.
Note that such  a decision may not have been made in a formal process, it may have been
decided, forgotten, and decided again, or it may have been decided differently for different parts
of the business.

       Appendix G lists respondents' opinions of how various motivating factors influenced the
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process by which the businesses identified and analyzed the various pollution prevention options
they faced. Again, recognize that this process may have been done in a less than formal way.

       Appendix H lists respondents' opinions of how various motivating factors influenced the
final choice of pollution prevention approach, recognizing that in a dynamic business no decision
is ever literally "final."

       Finally, Appendix I charts the information of the previous three appendices.  The
resulting matrix is very complex, but the researchers found it useful for discerning patterns
across respondents, and include it here for readers who might be interested.

       We hope the insights gained in studying this document will reward the effort invested.
Cover photograph by Meira Jehassi of Eli Laminates Company, New York.
                                            IV

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          GLOSSARY OF ACRONYMS
CFC - chlorofluorocarbon
MEK - methyl ethyl ketone
NaOH - sodium hydroxide
PCE - perchloroethylene
RCRA - Resource Conservation and Recovery Act
SARA - Superfund Amendments and Reauthorization Act
TCE - trichloroethylene
TSDF - treatment, storage, or disposal facility
VOC - volatile organic compound

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                                     APPENDIX E

                                   THE FACILITIES

        This appendix describes the forty-two facilities that were studied in the prototype study.

 Facilities Interviewed on Site

        Staff from the following facilities were interviewed  onsite. These descriptions were
 reviewed and approved by them.

 Facility 1: Wood Furniture Manufacturer. Vermont

        Facility 1 is a manufacturer of primarily knock-down (non-assembled) wooden furniture.
 The facility is privately held and is owned by three principals. The company employs 130
 people at its plant and two people at its retail shop in Vermont. It moved to a new, larger
 location in 1992.

        The company makes furniture for a number of clients and for its own retail store.
 Facility 1 manufactures TV/video units, head and foot boards for beds, bookcases, storage units,
 cribs, dressers, wardrobes, decorative folding screens and kitchen accessories. With the
. exception of their cribs and infant dresser/changers, all the furniture is shipped non-assembled.

        In general, the plant uses a three or four step finishing process that involves staining the
 wood, applying a sealer, and finishing the product with a top coat lacquer. On their own line of
 solid painted pine furniture, the facility uses all water-based sealers and lacquer coatings. On
 their dormitory and institutional style furniture, solvent stain, solvent sealer, arid water-based top
 coats are used.  Of total gross sales, less than 10% of all furniture manufactured at the facility
 has water-based sealer applied. Approximately 50% have water based top coats.

        Prior to moving into its newly built plant in 1992, Facility 1 used all solvent-based
 sealers and lacquers.  The company credits this lack of attention to pollution prevention to a
 general lack of knowledge about how to operate differently and to the space limitations and
 deteriorating quality of its former manufacturing facility. In its former facility, the firm only had
 enough room for three spray booths, which limited the amount of furniture that could be finished
 in any given period of time. The booths operated 24 hours a day, and often there were problems
 with wood dust settling onto finished surfaces during drying.   The building was cold and not
 insulated which, because of the lengthy drying time, prevented the air  drying of products that
 were coated in water-based solutions.

        When the old facility could no longer support the company's expanding client base, the

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owners decided to build a larger, more modern factory.  In doing so, the company went from a
45,000 square foot facility to a 60,000 square foot facility.  This move presented many decisions
about what kinds of sealers and coatings to use on the various product lines, the sort of
machinery to purchase, how to design and place the finishing lines and how to maximize worker
and community safety.

       The firm's initial intent was to eventually move away from using high VOC, solvent-
based coatings to using all water based coatings. Doing so would minimize the need for
respirators, hazardous waste quantities and disposal costs would drop, and the risk of fire would
decrease. Facility 1 involved the local fire inspectors in reviewing its plans in order to construct
a facility that minimized fire hazards posed by storing large quantities of highly flammable
solvents.  The owners also knew that they could decrease their insurance costs by operating with
less dependance on solvent-based materials and replacing them where possible with water-based
solutions.

       Although the original goal was to switch entirely to water-based coatings, the company
believes its applications are limited due to higher production costs and a perception by  customers
of lower product quality.

Facility 2: Dupont Chambers Works. New Jersey

       Dupont Chambers Works is one of the largest and oldest chemical plants in the country.
It employs over 2300 people.  The facility uses over 3000 raw materials and about 1000
intermediates to produce over 600 products. Batch operations account for over half of the
volume of chemicals produced.

       In 1980, a corporate policy was developed to minimize waste to the extent
technologically and economically feasible. The company defines "waste minimization" to
include source reduction and recycling. The corporate policy includes the waste management
hierarchy, which emphasizes source reduction first, then recycling and recovery of by-products,
detoxification and treatment or incineration, and land filling as a last resort. Dupont's mission
statement lists as its first objective the continued improvement in safety, health and
environmental performance as the highest priority. Ways of reducing waste have been sought
and implemented for many years, according to a senior staff member in the facility's
environmental affairs unit, but within the  last five years,  the facility has taken an even more
aggressive stance toward finding and implementing source reduction measures.

       Dupont Chambers Works is organized into separate business units that produce chemicals
for a variety of industries, including textiles, automobiles, agriculture, the building industry,
detergents and intermediates.  The facility ships approximately one billion pounds of product
annually. Almost half of its business is with the firm's other plants that use chemicals produced
at Chambers Works.  The facility is a permitted RCRA treatment, storage and disposal facility.
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Their treatment plant handles a significant percentage of all aqueous manifested waste produced
in New Jersey.

      Dupont Chambers Works is subject to a number of environmental laws, including RCRA,
federal and state Right to Know reporting, the federal Clean Air Act, the federal Clean Water
Act, the Toxics Catastrophe Prevention Act, and the New Jersey Pollution Prevention Act.  In
1993, Dupont Chambers Works reported Toxics Release Inventory (TRI) releases for sixty
chemicals. The facility's projected five year use and nonproduct output reduction goals for
chemicals on the TRI represent 50% of the total statewide use and nonproduct output reduction
goal reported by all facilities in SIC codes 26, 28, 30, 33 and 34 that have developed Pollution
Prevention Plans.

      In 1991, Dupont Chambers Works signed a consent decree with EPA to study several
pollution prevention measures in response to RCRA waste disposal violations involving land ban
restriction interpretations. As part of the consent decree process, Dupont developed a number of
case studies which identify areas for waste minimization and elimination.

      Dupont Chambers Works described a number of pollution prevention measures that
resulted in cost savings. Some of them are described below:

(1)    Chlorinated Aromatic Compounds (CAC) Process - In this process which produces
several chlorinated aromatic compounds in product campaigns ("campaigns" involve the use of
the  same equipment to make different products), the facility formerly used solvents to  clean  the
equipment. These solvent flushes produced about 600,000 pounds of solvent waste per year for
incineration.  In 1990, the facility identified a way to modify their systems to completely
eliminate the solvent flushing. Instead of flushing the equipment with solvent after each
campaign, a mobile collection unit made of a 55 gallon drum secured to a wheeled carriage is
now wheeled around to collect product residue through a drainage valve and then dumping it
into a storage tank where it is held for reprocessing during a future campaign. The amount of
residue in the process equipment after draining is negligible and does not compromise the quality
of the next product batch. An added benefit is that the new drainage system takes less time than
the  old solvent flush, which translates into less downtime between product campaigns and more
time to produce product instead. This low-tech pollution prevention measure cost $10,000 to
implement and is estimated to save the company $2.2 million over 10 years.

(2)    Reusable Tote Bins - Dupont makes more than 500 specialty chemicals which are sold in
small volumes to customers in a variety  of industries.  Formerly, these "small lot" chemicals
were shipped in 55 gallon drums. When emptied, these drums would typically contain about one
pound of chemical residue.  Customers were responsible for the disposal of the residue and of the
drums themselves.  The facility has now shifted away from using the 55 gallon drums to a
returnable 345  gallon metal tote bin. The typical customer now receives a full tote and mounts it
on top of a special dispenser within a production line. When the tote is empty, the customer
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ships it to a third party cleaner located near Facility 2. The clean tote is then shipped back to
Dupont along with the resultant wastewater which goes to the facility's wastewater treatment
plant. The tote bins are specially designed for complete drainage. The volume of residue is a
fraction of what it was in comparable 55 gallon drams.  This reduces the amount of waste from
small lot business. Dupont passes on the savings of this bulk shipping technique to its
customers.

(3)    Polymer Vessel Washout - One process area at Dupont makes several grades of a
polymer.  The process equipment includes a large vessel which must be cleaned periodically to
maintain product quality. During processing, the polymer accumulates on the interior vessel
walls, agitator blades and baffles.  Cleanups are complicated by the vessel's construction which
renders the  cleaning stage complicated and time consuming.  At one time, the vessels were
cleaned by flushing them with a flammable solvent. This produced a waste stream of about
40,000 pounds of solvent for incineration each year.

       In 1991, the facility implemented a system to use high pressure water jets  for cleaning. A
special nozzle is connected to a high pressure water source and inserted through the bottom
flange. A stream of water at 10,000 pounds per square inch blasts the residual polymer from the
interior surfaces. None of the spray escapes the vessel during cleaning. The polymer residue is
currently landfilled but the marketing group is searching for commercial uses of the polymer
residue. The cost of implementation of this pollution prevention method was $125,000. Savings
from the eliminated solvent waste are estimated at $2.7 million over a 10 year period.

(4)    Specialty Aromatic Compounds (SAC) Process - One process area at Dupont
manufactures specialty aromatic compounds. The process consists of a reaction step which
produces the SAC and a distillation step which purifies it. A waste  stream contains large
amounts of SAC product entrapped within a heavy tar which forms as a byproduct of the
reaction step.

       The SAC reaction step produces two types of tar - thermal tar and acid tar.  In 1990, the
raw material process began using a pH meter to monitor pH levels to keep acidity low. This
resulted in an immediate tar reduction downstream at the SAC process.  Moreover, reliable
knowledge  about raw material pH enabled people at the SAC area to implement waste reduction
solutions of their own. Installing the pH meter cost $50,000. The savings from lower
incineration costs  and increased product recovery will total  almost $8 million over 10 years.

(5)    VOC Air Emission Reduction - Dupont conducted stack tests and found ingredients in the
emissions that they did not expect and for which they did not have air permits. The facility's
initial reaction was that the emissions could either be treated or incinerated.  However, they also
felt that if they had more tune and flexibility from the state Department of Environmental
Protection, they could find a pollution prevention solution that was also cost effective. NJDEP
granted Dupont the needed time, in lieu of an air permit change, even though they were in
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violation of their permit. The end result of this grace period was that the facility was able to
eliminate "rogue" emissions at the source. One interviewee claimed that they could have gotten
their air permit limits raised at a lower cost but that the facility's corporate principles and
environmental goals discourage that.

Facility 3: Pharmaceutical Company. New York

       Facility 3 is a subsidiary of an international company headquartered in Europe.  The
parent company operates in the areas of diagnostic imaging contrast agents, pharmaceutical
products and energy. In October 1994, the parent company purchased the facility from a large
chemical company.  The facility is located in New York State and employs 150 people.

       Facility 3 produces an array of bulk active pharmaceuticals and pharmaceutical
intermediates.  Among the bulk active pharmaceuticals are diagnostic imaging agents and
intermediates.  The facility also recovers solvents, reusing what they can in their own processes
and selling the rest.  The applications of these re-sold solvents include methanol for windshield
washer solvent, isopropanol for general cleaning solvent use, acetic acid/anhydride mixture for
concrete etching and manufacturing and toluene for lacquer production.

       The parent company of Facility 3  developed Environmental Health and Safety
Performance Standards for corporate-wide reference and implementation. These standards
became effective January 1, 1995.  Two of these performance standards address waste
minimization and may be summarized as follows:

       Waste Minimization Performance Standard - Each facility shall have a waste
       minimization program with priority given to those wastes which have the greatest
       potential  for adverse health or environmental impact and those with significant volume;
       and

       Wastewater Management Performance Standard - Wastewater discharge shall be
       managed to minimize the volume of water as well as the quantity and hazards of
       discharges.

Facility 4: Metal Plater. Massachusetts

       Facility 4  is a mid-size job shop plater with 35 employees. The firm has separate plating
lines for tin/lead.  The facility has been family owned for four generations.  It moved to its
present location in an industrial park in a suburban city in the Boston metropolitan area in 1972.

       Production at the facility has grown overall by about 20% since 1987. There was a slight
dip between 1987 and the early 1990s, due in part to the costs of installing water pollution
control equipment. However, sales have recovered since then.
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Facility 5: Wood Working. Maine

       Facility 5 is a large woodworking facility located in the center of a small town in rural
Maine. The firm has been at its present location for many years, although it moved to a new
building in 1990 following a major fire that destroyed the original factory.

       Eleven years ago, the present owner/president bought the firm from five absentee owners.
The firm has changed its customer base and has tripled in size since 1984.  The firm estimates a
20% growth rate next year. Facility 5 presently employs 85 people.

       The plant engineer serves as the environmental officer at the facility and is self taught in
environmental matters.  Both the company president and the plant engineer participated in the
interview.

Facility 6: Electroplating. New Hampshire

       Facility 6 is a ten person job shop producing computer component plating for large
manufacturers.  Clients include: General Electric, Moore Business Products, ATT, Wang,
Penicook, and Ford Motor Company.  Facility 6 is involved in plating chrome, nickel, and zinc
as anodizing.

       Sales at the firm have recently rebounded. During the last four years, the firm was barely
able to cover expenses.  The president went without salary during a part of that time in order to
stay in business.

       The company has been in existence since 1929.  It moved to its present location in the
center of a small NH city from Massachusetts in 1972.  At that time it was a captive shop for a
major manufacturer.  In 1972 the present owner bought it from the large manufacturer.

       Until recently, the owner was the sole environmental officer.  However, in the summer of
1995, the company received a free intern from the University of New Hampshire that was
supported through a Supplemental Environmental Project (SEP) paid by another firm. This
individual has been delegated environmental responsibilities. The interview was conducted with
the owner/president.

Facility 7: Metal Working. Rhode Island

       This metal working facility is located in an industrial park in a small city. The firm
makes ball bearing cases in both fully and partially automated processes.

       The firm employs  46 people, is privately owned and growing rapidly.  The firm invests a
great deal of time and money in staff training and equipment updgrades.
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       The interviewee was the full time environmental officer for the facility.  The contact has
been in the environmental, health and safety field for many years and has worked for a number
of different industrial companies throughout the Northeast.

Facility 8: Metal Working. Connecticut

       This facility manufactures precision molded rubber products and brake boots. All metal
finishing is done on site.  The plant is located in a small city in rural Connecticut. The facility is
owned by two individuals who started the firm in the 1960s with seven employees.  It has been at
its present location since that date.

       The facility is growing rapidly, it presently has scheduled three shifts a day, six days a
week and employs 300 people.  Production is expected to grow this year.

       The interviewee was the facility's "regulatory compliance agent". The compliance agent
is employed as a consultant rather than a regular employee. The compliance agent prefers this
arrangement because it minimizes any potential conflict of interest between company profits and
environmental protection. The compliance unit includes three additional staff. The compliance
staff regularly conducts environmental compliance audits.

Facility 9: Anodizing. New Hampshire

       Facility 9 is an anodizing facility located in an industrial park on the outskirts of a small
NH city.  The facility makes heat sinks primarily for the electronics industry.  It is about 95%
automated, although 5% of its business is done by hand.

       Over the past few years, the firm has doubled in size and presently employs  1100 people.
The firm is publicly owned and has had several changes in management over the past fifteen
years. The most recent change took place last year, and the new management is very committed
to pollution prevention and staying in the forefront of product development.

       The interviewee was the chief operator of the anodizing line. This individual is also
responsible for environmental compliance. He is self taught in environmental matters and is
assisted by the plant engineer.

Facilities Interviewed by Telephone

       The project team interviewed the following 33 facilities by telephone:

Facility 10:    Wood Furniture Manufacturer, VT
Facility 11:    Metals, NJ
Facility 12:    Metals, NJ
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Facility 13:
Facility 14:
Facility 15:
Facility 16:
Facility 17:
Facility 18:
Facility 19:
Facility 20:
Facility 21:
Facility 22:
Facility 23:
Facility 24:
Facility 25:
Facility 26:
Facility 27:
Facility 28:
Facility 29:
Facility 30:
Facility 31:
Facility 32:
Facility 33:
Facility 34:
Facility 35:
Facility 36:
Facility 37:
Facility 38:
Facility 39:
Facility 40:
Facility 41:
Facility 42:
Metals, NJ
Metals, NJ
Chemicals, NJ
Chemicals, NJ
Chemicals, NJ
Wood, NY
Metals, NY
Metals, NY
Chemicals, NY
Wood, CT
Metals, CT
Chemicals, CT
Metals, MA
Chemicals, MA
Wood, VT
Wood, VT
Wood, VT
Metals, VT
Metals, NH
Chemicals, NH
Wood, ME
Wood, ME
Metals, NY
Metals, ME
Chemicals, ME
Metals, NH
Metals, NH
Wood, NH
Metals, RI
Wood, NY
       The facilities are referred to by these numbers (sometimes in parenthesis) in the
following appendices.
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                                   APPENDIX F

             FACTORS THAT LED RESPONDENTS TO BEGIN
                INVESTIGATING POLLUTION PREVENTION

       This appendix lists the opinions of respondents as to the factors that led the forty-two
industrial facilities studied to begin investigating pollution prevention.

Regulatory Compliance

State Respondents

       Staff from the CT, MA, ME, NH, and RI regulatory agencies all reported seeing
regulatory compliance as a major motivator that convinced company managers of the value of
pollution prevention. Requests for onsite visits through the NH Pollution Prevention Program
(PPP) increased substantially after the NH Department of Environmental Services (DES) began
referring companies to technical assistance during the inspection process.  Companies referred to
CT Technical Assistance Program (ConnTAP) from CT DEP because of compliance problems
tend to be receptive to pollution prevention. Almost all requests for assistance from the RI  
Narragansett Bay Commission are from companies that have compliance issues.  All of the
Maine onsite visits have been to companies that were subjected to major enforcement actions.
Similarly most requests for assistance for the MA Office of Technical Assistance (OTA) are
from companies referred by the MA Department  of Environmental Protection (DEP).

       One obstacle to pollution prevention cited by both NH and CT state agency  staff is that
firms often do not understand the regulatory requirements they face and at times feel
overwhelmed to the point of inaction.  ConnTAP staff felt that some companies retreated from
even trying to comply because the regulatory language was so confusing.  Respondents from
both state agencies felt that if the regulations were clearer companies would be more likely to
pay attention and then find pollution prevention solutions.

       This broad motivator includes all of the factors related to compliance with environmental
regulations: air pollution control, water pollution control, hazardous waste management, multi or
single media permits, multi or single media compliance inspections, referrals to technical
assistance agencies after inspections, enforcement actions, and supplemental environmental
penalties, and waste site clean-up or remedial actions.

Industry Respondents

       Environmental compliance started a chain of events that reportedly led Facility 8
management to recognize the value of pollution prevention and the company to implement many
pollution prevention projects.  The facility initially hired the environmental compliance director

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to manage a Part B RCRA Facility Closure.  The costs and aggravations entailed in a Part B
closure alerted company management to the importance of assigning a person to environmental
compliance to prevent this sort of problem from happening in the future. Prior to that time,
environmental matters were handled by the plant engineer who had many competing
responsibilities. Once on board, the Part B coordinator began identifying relatively simple
pollution prevention measures that saved the firm a great deal of money. These eventually led
all levels of the facility to embrace pollution prevention.

       The installation of wastewater pretreatment made the general manager of Facility 4 aware
of the importance of the materials conservation portion of pollution prevention as a general
concept. Operating the wastewater plant made him realize the quantities of chemicals and water
that were being discharged to the wastewater treatment plant, where additional chemicals had to
be used to treat them. This realization coincided with TRI reporting, which caused him to
quantify his use.  As a result, a number  of procedures were instituted to preserve rather than
replace the baths.

       A NH DBS inspection and subsequent referral to the NH PPP reportedly led Facility 6 to
contact NH PPP  and the University of New Hampshire to "find out what they were doing
wrong".  As a result of these contacts the firm ultimately received the services of a pollution
prevention intern who is setting up systems to identify and implement numerous pollution
prevention projects.

       In 1991, Facility 2 signed a consent decree with EPA to study several pollution
prevention measures in response to RCRA waste disposal violations involving land ban
restriction interpretations.  The violations resulted in fines of $ 1.8 million, but the company
reported anticipated savings of close to $15 million a year once all improvements were put into
place.  One time  capital improvement costs amounted to $6 million.  Savings were realized in a
number of areas. Among them were: $1.6 million in avoided waste disposal costs,  $2.2 million
in reduced raw materials consumption and utility use, $11 million from process improvements
such as increased capacity, improved quality and increased operating time for production lines.
The changes will ultimately result in a 48% reduction in wastes.

       As part of the process of developing the consent decree, Facility 2 agreed to work jointly
with EPA to study pollution prevention for fifteen processes. Five processes each were selected
from three categories:

       Category 1: Processes which have shown significant progress in waste minimization or
       pollution prevention.

       Category 2: Processes which have shown little or no progress in waste minimization or
       pollution prevention.
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       Category 3: Processes for which no recent waste minimization and/or pollution
       prevention assessment analysis has been performed.
       Many of the fifteen case study measures have already been implemented. For example,
the facility is now using a high-pressure water-jet system to clean polymer reaction vessels,
replacing solvent cleaning that annually produced 40,000 Ibs. of solvent that had to be
incinerated. Installing the new cleaning system cost $125,000 but will save the company
$270,000 annually.

       The installation of a drainage valve in a chlorinated aromatic compounds line at Facility
2 is another example of a cost saving measure. The improvement, costing $10,000, allows
workers to drain the system into a container for reuse during the next production run when
switching to a product variant.  The facility has realized $220,000 in annual savings by
eliminating 600,000 Ibs. of solvent used annually to flush the system along with avoided
incineration costs.  These and other pollution prevention measures were identified and
implemented within the framework of the enforcement consent decree signed with U.S. EPA.

       Although the consent decree cannot take credit for leading the company (which has a
long history of investigating and implementing pollution prevention) to begin investigating
pollution prevention, the consent decree apparently furthered prevention at the facility by
identifying case studies (in some cases) where past prevention efforts were either unsuccessful or
not attempted.

       ANY metals plant respondent (19) cited the combined effect of the NY Hazardous Waste
Reduction Act, NY Solid Waste Reduction Act, SARA rule, and rising CFC taxes as the primary
reason for the firm's drive to  focus on process substitution and greater prevention. The plant's
senior engineer also noted that if not for the government imposed taxes and cease order, the
facility would have continued its use of CFC's.

Staying Ahead of Compliance

       The Facility 26 respondent cited his plant's difficulties with compliance, which
motivated the company to want to stay ahead  of the regulation curve.  The Facility 1.7 respondent
stated that its desire to stay ahead of regulations was a result of wanting to avoid any regulatory
liability.

Mandatory Reporting

State Respondents

       The MA regulatory agency contacts reported seeing  companies that became committed to
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the goal of pollution prevention after they completed their TRI reports, and even more their
Toxics Use Reporting Act (TURA) materials accounting reports.  While materials accounting
reporting in ME is not mandatory, it is encouraged, and ME DEP contacts felt that it had affected
many company's interest in doing pollution prevention.

       The NJ DEP initially began collecting facility level materials accounting and pollution
prevention reporting in 1989 and was complemented by production process level reporting in
1994. The NJ regulatory agency staff reported similar conclusions as the MA agency regarding
the impact of mandatory reporting on facility level prevention efforts.

       Staff at the NJ DEP and CT, NH, and RI technical assistance programs all felt that
mandatory materials accounting reporting would spur many companies toward pollution
prevention. The general sense was that whenever companies focused on what was happening to
their inputs, they took steps to minimize waste.

Industry Respondents

       TRI was reportedly a key motivator for a number of the firms sampled. The refrain of the
majority of those citing TRI was that it raised both facility and community awareness.  However,
companies had different opinions as to TRI's effectiveness at motivating them to do pollution
prevention.

       A pharmaceutical company respondent in NY (3) discussed some of the benefits of TRI
reporting, noting that the requirement for doing facility-rwide reporting on all covered chemicals
helped them understand exactly what they were emitting and where. It has assisted them in
going beyond looking at processes that run all year round to also examining processes that are
run in batches only a few times throughout the year. Management also examines the data each
year to compare emissions numbers from one year to the next and to determine whether or not
they have made reductions.  The company considers changes in production levels when they
make these comparisons.

       The Environmental,  Health and Safety manager at Facility 3 also discussed the impact of
having to report biennial update information to the New York Department of Environmental
Conservation under the state's Hazardous Waste Reduction Act. She stated that having to
compile waste reduction progress and plan update information into one free-standing document
has helped focus management on pollution prevention issues.  She noted that pollution
prevention is only one issue among many that management  considers when making production
related decisions and that having information located in one readable document helps the
production staff state their case about where, why and how additional pollution prevention may
be done.

       The Facility 26 respondent indicated that the firm was listed as a top ten emitter and their
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 desire to get off the list was the principal driver towards prevention.  The Facility 20 respondent
 explained that he did not want to be on the TRI list and that the firm's management wants to see
 yearly reductions, but a respondent from a large chemical plant in New York (21) felt TRI didn't
 provide any incentive, that it simply made more visible how well the company was performing.
 A ME chemical facility respondent (37) felt that although TRI was effective at raising
 awareness, numbers derived from it are misused.  In addition, the respondent felt that a number
 of chemicals either "should or should not be on the (TRI) list."

        A New Hampshire chemical plant respondent (32) felt that TRI "really doesn't do
 anything. [It's] just an exercise we go through.  The numbers change because of changes in the
 product mix and volumes, not because of pollution prevention." A New Jersey metals facility
 respondent (11) also felt that TRI had no direct impact on the plant.  The respondent explained
 that they simply "report statistics to corporate personnel." The respondent did state that TRI
 "helps with goals to get reductions."  A New Hampshire metals facility respondent (3 9) believed
 TRI hindered pollution prevention because of the record keeping burden. The contact felt that
 too much time was spent filling out forms rather than doing pollution prevention.

       While some facilities' respondents felt TRI had little influence on their plant, others had
 a different view.  A Vermont wood-worker (28) cited TRI as the force that "helped better
 understand our emissions.  Never before had we had the data".  A NY metals manufacturer (19)
 was surprised to see the numbers off their first TRI report. The plant manager felt that they were
 throwing money out of the stack. The manager saw the releases as by-products of an inefficient
 operation. In addition, the manager cited the resulting negative publicity surrounding reports
 that the plant was the number one releaser in the area.

       An engineer at a metals plant in NJ (11) simply explained that the Form R question,
 "What pollution prevention activities are you doing", was  the driver that led the firm to
 investigate pollution prevention options. The respondent felt the need to answer the question
 after a few years of leaving it blank.

       A MA specialty chemicals manufacturer (26) cited the Massachusetts Toxics Use
Reduction Act (TURA) requirements as the primary driver of their interest in pollution
prevention. However, it was unclear whether the contact was referring to TURA's reporting
and/or planning requirements.

Mandatory Planning

       Mandatory planning includes pollution prevention planning as mandated by ME, NJ and
MA and waste minimization planning as mandated by NY. The other four states in this study do
not have mandatory pollution prevention or waste minimization planning laws.
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State Respondents

       Both MA and ME regulatory agency staff felt that mandatory planning made companies
pay attention to the values of pollution prevention.  A survey of MA companies that had
completed pollution prevention plans indicated that in many instances environmental staff were
able to use the mandatory planning process to convince company management to pay attention to
inefficiencies in production processes. In addition, a graduate student found that many
companies went into the planning process very skeptical of its value, and came out as believers
in the process. In particular, the options identification and worker notification were viewed as
particularly valuable.

       The NJ DEP's early findings on its mandatory planning requirements indicate similar
results to MA and ME. The NJ agency staff have also found that the materials accounting
approach to facility planning led to other non-pollution prevention benefits such as providing
estimates of production process efficiency measures and the verification of media-specific
emissions.

       Although NH lacks a mandatory pollution prevention law, the state uses RCRA waste
minimization guidance to try to persuade firms to undertake planning on a voluntary basis. State
staff admit that this is a "hard sell". CT, NH, and RI staff all felt that mandatory planning would
be good for some companies because it would force them to find pollution prevention
opportunities.

Industry Respondents

       Respondents with Facilities 4 and 5 had made a great deal of progress in pollution
prevention prior to the date their plans were due. Neither respondent felt that mandatory
planning made them aware of pollution prevention in general. However, mandatory planning
indirectly expanded Facility 4's respondent's awareness of pollution prevention.  The firm's
general manager took the comprehensive course in toxics use reduction planning offered by the
Toxics Use Reduction Institute at the University of Massachusetts at Lowell so that he could
become a licensed toxic use reduction planner and self certify his toxics use reduction plan.

       Mandatory planning reportedly raised the worker's awareness of pollution prevention at
Facility 5. In order to develop their plan, the plant managers held monthly meetings with
workers to discuss pollution prevention opportunities.  The meetings improved communication
between management and workers, made actual production practices clearer to management and
workers, and revealed a number of pollution prevention opportunities.

        The plant engineer at a ME facility (5) felt that TRI and the ME planning requirement
raised the priority of eliminating chemicals and minimizing waste in general. Pollution
prevention opportunities were being missed because management was  so busy with other

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competing activities.

       A CT metals company respondent (8) spoke about the value of the RCRA waste
minimization certification process. The contact mistakenly believed the RCRA waste
minimization requirement to be a mandatory planning program. The contact believed that the
mandatory nature of the certification garnered management support for developing a pollution
prevention team, and moved the company toward the total cost accounting system outlined in a
Federal Register Notice. The compliance manager stated that his position afforded him the time
to identify sources of waste and to research prevention options. He believed that a number of
companies do not have the time and that mandatory planning would force them to investigate
pollution prevention options.

       A respondent from a large NH plating company (6) also felt that mandatory planning
would raise company management's awareness of the value of pollution prevention.  The plant's
chief operator said that a pollution prevention planning law would force the firm to have
someone in each department responsible for learning about actual production practices, and
thinking about pollution prevention opportunities. He had tried unsuccessfully to set up a
pollution prevention team and he thought that a planning mandate would generate management
support for investigating prevention opportunities.

       A respondent at Facility 2 shared his thoughts about the New Jersey Pollution Prevention
Act and the requirement to perform materials accounting for each covered chemical within each
production process (Part I of the planning process.) The law requires that this be done before the
facility targets areas for potential pollution prevention reductions. The respondent reported that
materials accounting data collection under Part I of the planning law was a waste of time and
that he did not need to collect this data to identify where the facility was able to maximize its
pollution prevention efforts. The respondent reported already knowing which waste streams
make up the required 90% of all multi-media waste which is one of three targeting criteria
identified in the Act that facilities may select to decide where to investigate  pollution prevention
options.

       Facility 12 and 14 respondents mentioned that they started looking at pollution
prevention when they learned of the planning requirements. The Facility  12 respondent felt that
although it forced personnel to address pollution prevention, that  it was a waste of time for the
firm.  The respondent felt that they "don't create a lot of pollution to begin  with.  Nothing
changed as a result of planning because we are doing so well to begin with." The respondent
found planning to be expensive and time consuming. A respondent at a metal fabricating plant
in NY (20) also believed planning to be a burden. He saw the time required to complete the plan
as a hindrance because too much time was spent doing paperwork which took time away from
doing pollution prevention.
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Voluntary Programs

       Voluntary programs include governor's or EPA awards, Green Lights, 33/50,
environmental excellence programs, and Responsible Care.

       For a MA plating company (4), mailings from EPA about the 33/50 program increased its
awareness of pollution prevention in general. Although it did not formally participate in the
program, the firm tried to minimize its use of TCE.

       Voluntary programs offered by EPA won high praise from respondents at Facility 2.
When asked what EPA does that helps encourage pollution prevention efforts, interviewees from
this facility responded with resounding praise for the 33/50 program. They liked the fact that it
was voluntary and did not prescribe how facilities had to go about achieving reductions. They
also commended Project XL, a new voluntary EPA program which grants participating facilities
regulatory flexibility in exchange for an enforceable commitment to achieve environmental
results that go beyond compliance. Facility 2 has not submitted a proposal under the Project XL
program but is currently reviewing projects and options. They spoke in favor of programs which
set performance standards and gave industry the flexibility to decide how to meet the standards
without detailed reviews and approvals from government bodies.

       Under its previous parent company, Facility 3 was a participant in the Responsible Care
Program developed by the Chemical Manufacturers Association (CMA).  After being sold, the
facility was no longer a member of CMA and therefore, not an official participant in the
Responsible Care Program. However, the firm continued to embody the principles of the
program in their operations.

       ANJ chemical plant respondent (15) cited 33/50 and Responsible Care as programs
that helped his firm focus on pollution prevention. 33/50 helped his firm focus on reducing its
use of certain chemical families. The respondent also felt that Responsible Care could be
improved if the program communicated about the pollution prevention activities going on at
other firms.

       A respondent from a chemical plant in NY (21) explained that as  part of their
participation in the 33/50 program, company wide use of methylene chloride was reduced by
95%.  This success was cited as providing the incentive for the facility to look at other pollution
prevention measures.

       While some contacts at chemical facilities felt 33/50 to be a good program,  individuals
contacted at some smaller firms believed 33/50 to be of little benefit.  A MA wood  furniture
manufacturer (42) saw 33/50 as a public relations ploy by EPA designed to primarily benefit the
Agency. He felt the program did not address the needs of industry.  The contact also viewed
industry concerns surrounding quality control as being overlooked. A RI metals facility
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respondent (41) saw little benefit from participating.  In addition, the respondent believed the
facility' could not achieve the program's goals.

       A VT wood furniture manufacturer (29) explained that the firm's nomination for a state
governor's award (which it did not win) led him to contact the state pollution prevention office
and inquire about regulations and compliance.

       A ME metal products manufacturer (36) felt that their participation in a voluntary
industry pollution prevention program was not very helpful. The respondent attributed this to
the program's recent launch and that his firm's goals are further ahead of the program's
environmental goals. The Maine Metal Industry Partnership Voluntary Program cited his facility
as a model for environmentally conscious manufacturing.

Government Technical Assistance

       This category includes the many types of assistance offered by state, federal, regional,
local, and university technical assistance programs  onsite visits, seminars and workshops,
conferences, newsletters, hotlines, research grants and loans, interns, literature surveys,
publications, and clearinghouses.

State Respondents

       NH, CT, and RI technical assistance program staff all believed that a successful technical
assistance visit,  or even a telephone call demonstrating support could begin convincing
companies of the benefits of pollution prevention.  Often they have repeat business after they
have found some simple, effective projects that save the company money.

       However, it was sometimes hard to get in  the door.  After trying it for a year, NH staff
found that cold  calls were not successful. ME staff believed that many firms in that state would
never ask for assistance because of a deeply held belief that government could not tell them how
to run their business. NH staff phrased it somewhat differently.  They felt that a belief in
"Yankee ingenuity" made companies believe that they could not benefit from government
assistance.

       Another limitation was the lack of awareness of the technical assistance agencies.  The
NH PPP recently did a survey and found that 60% of the respondents had never heard of the
agency and its services. However NH and CT staff found that conferences, seminars,
newsletters, word of mouth and surveys all served to publicize the technical assistance agencies.
This publicity in turn would lead companies to call for assistance.

       CT and NH staff both felt that the companies  most likely to already be doing technical
assistance, and therefore not need to be convinced of its value were larger, high tech, privately
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owned, profitable companies with an environmental staff. Respondents from the technical
assistance agencies felt they were more likely to open the eyes of smaller privately owned
companies that did not have the time or wherewithal to explore alternatives to their current
production processes.

Industry Respondents

      Industry respondents reported that technical assistance played a role in raising awareness
of pollution prevention. A MA plating company's (4) general manager had begun instituting
material conservation measures in the late 1980's, after installing a waste treatment plant.
However, attendance at the Toxics Use Reduction Planner Training offered by the Toxics Use
Reduction Institute at the University of Massachusetts at Lowell broadened his outlook on
pollution prevention. This course and the associated conversations with  his classmates, opened
his eyes to many additional options.

      A large NH plating company (6) had instituted materials conservation measures in the
1980's. However, seminars put on by the local publicly owned treatment  works (POTW), state
pollution prevention agencies and a visit by the NH PPP broadened its understanding of the
power of pollution prevention and the types of projects that were possible. Company
management also relied extensively on seminars and government publications to learn about the
environmental regulations with which they had to comply.

       A NJ metals facility respondent (11) indicated that a course given by the New Jersey
Institute of Technology (NJIT) was what "turned us on to pollution prevention".  NJIT staff then
referred the company to an environmental action class given by the local  utility which eventually
led to an onsite technical assistance visit by EPA.  The facility's director  found the EPA visit to
be "very helpful" and said it "helped us understand how critical the issue was and educated us as
to the next steps".  EPA helped the facility do "what was best for our company".  Another NJ
metals facility respondent also cited discussions with NJIT as a motivating factor.  However, the
firm was too busy and had little tune to work with NJIT face-to-face.  One respondent (17)
indicated that NJ's pollution prevention program administered by NJ DEP was a key motivating
factor at his NJ chemical plant.

Private Technical Assistance

       Private technical assistance takes the form of seminars and newsletters put on by trade
associations, technical and trade journals, environmental consultants, and "onsite visits" and
technical information from equipment and material suppliers and vendors.

State Respondents

       Respondents from the state programs felt that private technical assistance was sometimes
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 effective and sometimes problematic.  CT, NH, RI, MA, and ME staff all invited vendors,
 suppliers, and consultants to present information at pollution prevention conferences and
 seminars. In addition, CT staff gave speeches at trade organization meetings and put information
 in trade organization publications in order to promote awareness of pollution prevention, and the
 availability of their services.

       However, CT and NH staff both cited the problem of vendors selling equipment or
 substances that are not effective. CT staff said that "every company has a piece of equipment in
 the corner that did not work".

 Industry Respondents

       Assistance from the private sector was not reported by industry respondents as a factor
 that first led firms to investigate pollution prevention.

 Costs/Savings

       Several of the industry respondents surveyed  by telephone cited costs and savings as a
 definite factor that motivated them to consider pollution prevention.  Although those interviewed
 were very general about cost as a motivator, typical responses were "economically it makes
 sense", "cost effectiveness has always pushed pollution prevention", "benefits the bottom line",
 and "(we) receive (an) economic benefit from pollution prevention".

       Some respondents that generically cited costs also mentioned issues surrounding the high
 cost of waste treatment/disposal and the potential for future liability.  A NH metal plater (31)
 explained that a primary motivator was his concern with the storage of hazardous material that
 was either waiting to be recycled or disposed. To avoid future liability he felt the need to reduce
 the amount of hazardous material generated as a by-product.

       Respondents mentioned the need to increase yield and plant efficiencies as factors that
 interested them in pollution prevention. Respondents from both a CT (24) and NH chemical
 plant (34) felt that ways to minimize effluent would have to be found  in order to increase product
yields.  In addition, the two plants started investigating pollution prevention when competitive
 pressures were forcing the company to find ways to increase efficiencies and reduce costs.

 Competitiveness Issues

       Industry respondents mentioned the need to increase yield and plant efficiencies as
factors that interested them in pollution prevention.

       An interviewee at a large NJ  chemical company (2) asserted that some of the competitive
pressures within the chemical manufacturing industry have indirectly promoted pollution
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prevention efforts.  He stated that new companies are starting out with a different paradigm than
some of the older companies which historically have turned to waste treatment as a first choice
for managing wastes. Only within the last few years have U.S. companies been actively moving
toward emphasizing pollution prevention over treatment and disposal.

       Respondents at both a CT (24) and NH (32) chemical plant felt that ways to minimize
effluent would have to be found in order to increase product yields.  In addition,  the plants
started investigating pollution prevention when competitive pressures were forcing the
companies to find ways to increase efficiencies and reduce costs.

Management Systems

       Management systems included participation in International Organization for
Standardization (ISO) certification, Total Quality Management (TQM), voluntary materials
accounting, total cost accounting (TCA) systems, voluntary pollution prevention planning,
defined corporate environmental practices, and pollution prevention work teams.

       A CT metals company respondent (23) felt that while ISO and TQM do not influence
pollution prevention directly, they do lend credibility to the types of analyses that one does in
pollution prevention work.  They also result in the establishment of management systems that in
turn support pollution prevention.

       A NJ metals facility respondent (11) reported that the facility's total cost accounting
system was a major factor that led it to begin investigating pollution prevention.  When the
accounting system first isolated the annual cost for compliance, plant management began looking
for ways to lower costs.

Environment, Health and Safety Considerations

       A number of respondents generically indicated that their firm's philosophy was a factor
that led them to investigate pollution prevention options. Respondents mentioned "it's the right
thing to do", that they are "good corporate citizens", or that the company has a pollution
prevention ethic in place and is constantly striving for environmental improvement.  Some
respondents were particularly emotive about their social  or environmental consciousness
believing that "it just makes sense".

       Although most of those mentioning a positive philosophy as a behavior driver cited
altruistic reasons, a number exhibited reasons that reflect an enlightened self-interest. A NJ
metals facility respondent (13) indicated that the company cares about its workers but added that
the plant is located in an "affluent portion of their county and the plant is  in a pristine area, so
it's more obvious" if there is pollution.
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       Some respondents mentioned that the pollution prevention ethic was something they have
practiced for some time and have made it an integral part of doing business. These firms
generally mentioned that it benefitted the bottom line and helped them remain competitive. A
NY wood furniture manufacturer (18) indicated that his plant has been doing pollution
prevention for many years and that it is a by-product of an efficient operation. The respondent
added that the pollution prevention activities going on at the firm were not a result of outside
influences. He felt that government wrongly assumes that firms are doing pollution prevention
as a result of government intervention.                                          -     ..

       A CT wood manufacturer respondent (22) indicated that the company cares about its
workers and does not like using chemicals.  The facility worked with the state technical
assistance program to get out of solvents. A VT wood products facility respondent (29)
indicated concern for employee health and felt that the OSHA regulations were not sufficiently
protective.

       When asked what motivated them to look into  doing pollution prevention, one of the
owners interviewed at a VT furniture manufacturer (1) stated, "I'm a Vermonter".  The
interviewers understood this response to imply that the owner was informed and concerned about
environmental protection by virtue of living in and feeling connected to a  state that has vast
natural resources and beauty. This same individual talked about how he involves his production
workers in seeking out ways of getting the quality of water-based finishes up to an acceptable
standard.  His workers are the critical link between discovering an idea and testing it to
determine its effectiveness and reliability. As such, his production workers are equally
important in their research and development role as they  are in their manufacturing role.

       A VT furniture company respondent (1) noted  that one  of the strongest motivators for
implementing pollution prevention measures was to improve worker safety conditions. The
company's managers recognized that breathing in solvent fumes may have detrimental health
effects in the long run and wanted to minimize the need to use respirators when working around
coating operations. The company's managers also had strong feelings about minimizing the  risk
of fire. When they developed the blueprints for building a new facility, they involved the local
fire inspectors in reviewing their layout and providing feedback on how to maximize safety
while storing large amounts of highly flammable solvent based finishes. This interest in paying
attention to fire safety concerns while designing and constructing their new facility also speaks
to the company's intention to operate as a responsible  corporate citizen within their community.

Public Image

       Some respondents cited their desire not to have the public associate their firms as being
polluters.  A facility in NY (20) received much negative publicity after TRI numbers identified
the facility as being the community's largest toxic emitter. A metal plater in CT (23) explained
that public perception was becoming more important as the area surrounding the plant becomes
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more residential.

       Management at a large NJ chemical company (2) places a good deal of attention on
creating a positive public image as a responsible and environmentally aware company.
Periodically, they publish a document called Safety. Health and Environmental Report for
distribution to the public.  This report highlights the firm's prominent issues and most recent
environmental achievements.  The facility is also involved with a community advisory panel
made up of facility employees and community leaders. The purpose of the panel is to hear
concerns from the surrounding community about the company's operations and to carry those
concerns back to management for response and possible action.

       Facility 2 was also a founding member of a statewide alliance formed in 1993 which
brings together business and environmental leaders to discuss policy and program initiatives for
balancing the state's environmental needs with its economic interests. The alliance focuses on
three areas:  working with the NJ Department of Environmental Protection to strengthen its
ability to sustain the environment and economy, creating opportunities for eco-tourism in the
state, and developing ways to implement the state's redevelopment plan.

       Facility 2 also does a good deal of public outreach to local school  and public interest
organizations.  In 1993, the facility commissioned elementary school students to conduct a
habitat study using money from the facility's Community Initiatives Fund  and employees
donated the proceeds of their Environmental Excellence Award for three local environmental
programs. The site also has a wildlife habitat program which manages 200 acres of wetlands and
is certified by the national Wildlife Habitat Enhancement Council.

Employee Commitment

gtate Respondents

       RI,  CT and NH state agency staff felt that in order to be convinced of the value of
pollution prevention, company management had to be open to it. NH staff cited cases when
employees would say to the NH PPP staff that they would prefer to have  an onsite visit but that
company management would not allow it or felt uncomfortable with an onsite state visit. The
MA OTA solves this problem by gaining management commitment before an onsite visit.

Industry Respondents

       The commitment and beliefs of individual employees sometimes reportedly led entire
companies to an awareness of the benefits of pollution prevention. The pivotal employees
included senior managers, environmental managers, and production line workers.

       The environmental compliance manager of a CT metals company  (8)  convinced both
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management and workers to embrace the goals of pollution prevention. When the environmental
manager was initially hired as a part time consultant to handle a closure of a hazardous waste
site, she believed it was important to identify waste prevention measures that could save the
company money.  She was first employed by the company as a lab technician. While working at
the firm, she had been appalled at the quantities of chemicals being wasted. As she found easy
savings through pollution prevention, she made management aware of the risks of
noncompliance with environmental standards. As the compliance manager informed upper
management of enforcement cases, the firm became increasingly supportive of pollution
prevention.

       The contact at Facility 8 used a scrap rubber disposal problem as an illustration of an
issue used to gain company management attention for pollution prevention. Eighty percent of
the 1.2 million pounds of rubber purchased goes to a dump. The company pays $850,000 to
purchase the rubber that gets thrown away. Management gained a whole new understanding
about the importance of efficient use of material when the contact compared the $850,000 rubber
purchase cost to a $40,000 waste management bill. With a change of management the contact
was hired as a full fledged compliance manager with a staff of three.

       The initial pollution prevention efforts at a large NH plating company (9) were the result
of the anodizing line's chief operator. This individual was self-taught.  He started with a high
school degree as a part sander and worked his way up to becoming the chief operator. The
individual always felt that it was his responsibility not to waste material and money.  As a result,
his initial projects were mostly materials savings.  Recently, he began to take responsibility for
safety and environmental issues. Whenever he raised an issue or a concern, his supervisor
empowered him to handle it. When the wastewater treatment plant was installed, he became the
operator, and began attending seminars on environmental regulatory issues and calling
management attention to matters that needed to be addressed.

       The addition of a pollution prevention intern funded through a penalty paid by another
firm had tremendous impact on a small NH plating company  (6). The intern had the time and
expertise to bring the facility into compliance with all of the various reporting requirements.  In
addition, the intern was charged with materials accounting and outlined process flows on the
production lines.  The intern also implemented a number of operation and maintenance related
waste prevention measures that had been previously identified by the technical assistance
program but never implemented by the facility owner.

       A respondent  at a large metals plant in NY (19) felt that a few employees within the firm
(who he described as  environmentalists)  influenced the firm to look at pollution prevention. The
contact, the head of the plant's engineering department, described a few members in his group as
pollution prevention champions. These individuals have a strong desire to reduce toxic
exposures and do not care if the prevention option requires more work or new knowledge.
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       An environmental manager at a NH metals facility (39) described her environmental staff
as pollution prevention champions.  She believes the staff serve not only to increase awareness
but to promote the pollution prevention ethic among others within the organization.

Customer Acceptance

       CT agency staff reported that concerns about customer acceptance and product quality
prevented some companies from considering any pollution prevention.

Technical Feasibility

       CT agency staff reported that concerns about the technical feasibility of anything other
than the present way of producing a product would prevent some companies from even thinking
about any pollution prevention.

Resource Constraints

       CT and RI agency staff felt that a lack of time, awareness of the regulations, capital, and
cash often prevented firms from being able to embrace pollution prevention as a worthwhile
goal. These companies were often "hanging on by a fingernail" and could not pay attention to
anything other than immediate survival.
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                                  APPENDIX G

         FACTORS THAT INFLUENCED THE MEANS BY WHICH
  RESPONDENTS LEARNED OF POLLUTION PREVENTION OPTIONS
       This appendix discusses factors that respondents reported as important in gathering
information and otherwise investigating pollution prevention options.

Regulatory Compliance

       Some industry respondents reported learning of pollution prevention options from either
state or federal regulations.  A CT metals facility respondent (23) reported learning of pollution
prevention options from OSHA regulations and material safety data sheets (MSDS), while a MA
metal worker (25) reported learning of pollution prevention options from the Massachusetts
Toxics Use Reduction Act (TURA).

       A NY wood manufacturer (42) found a NY state-required multi-media pollution
prevention inspection to be unhelpful in identifying options. The contact cited an example
where state inspectors said his rags with reformulated finishing solution were not hazardous, but
later told him they were not sure and that the company needed to first determine if they were
hazardous. The contact stated that the inspectors failed to provide information that the facility
did not already have.

Staying Ahead of Compliance

        A small CT wood furniture producer (22) with a strong environmental ethic wanted to
reduce his use of solvents as much as possible and remain ahead of the regulatory curve. Facility
management views California regulations as the bellwether for what is to come and continually
adopts the most stringent standards even if they do not apply to facilities in CT.

Mandatory Reporting

       There was a wide range of opinion as to the effectiveness of mandatory reporting in
helping firms generate pollution prevention options.  A VT wood furniture manufacturer (28)
and NJ chemical facility respondent (17) both felt that reporting helped them better understand
their emissions and provided their firms  with guidance to set pollution prevention goals.

       While some facilities made generic statements that reporting was not helpful, a NJ
chemical company (15)  believed that the time and effort required to report took time away from
the more important task of generating pollution prevention options. This state contact added that
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while the TRI forms were "O.K." to fill out, that NJ State forms were "cumbersome".
Furthermore, he felt that "reporting numbers are subjective, based on how an individual plays
with the numbers." ANY wood furniture company respondent (18) stated that reporting does
not help his facility because company staff are already aware of their emissions and costs. A ME
chemical company respondent (37) felt TRI was not helpful in generating ideas because there are
chemicals that should either be taken offer added to the reporting list.

       A MA metals facility respondent (25) believes the TRI Form R to be a waste of time.
However, the contact believed that the MA TURA and associated reporting requirements were
very effective because it drove industry to look at pollution prevention.  The contact stated that
TURA was more effective than the EPA programs.  A MA chemical company respondent (26)
reported that MA TURA training was the primary way he learned of the pollution prevention
options available to the company.

Mandatory Planning

       A NH chemical company respondent (32) - apparently under the incorrect impression
that pollution prevention planning was required in NH - felt planning hindered the generation of
pollution prevention ideas. The contact explained that the process was both burdensome and
costly. However, some facilities interviewed believed planning to be helpful.  Some respondents
generally characterized the requirement as positive for generating ideas becaus'e it forces the
facility through a planning process.  Responses included: "it helps allocate resources", "makes
you think about options and heads you in the right direction", "it doesn't focus on all emissions,
(rather) it focuses on specific chemicals".

Voluntary Programs

       Respondents from two NJ chemical companies (15, 16) believed EPA's 33/50 program
helped them focus on the chemicals of greatest concern. Facility 16 also believed the
Responsible Care Program achieved a similar result.

       A large NY metals facility (19) participated in EPA's Green Lights program because of
the payback associated with participating. The contact added that the payback was mostly due to
the financial incentive the company received from the local utility.

Government Technical Assistance

State Respondents

       CT, NH, MA, RI and ME, all report using a combination of on-site visits, seminars,
conferences, newsletters, literature, and telephone assistance to provide firms with information
about specific pollution prevention projects that are applicable to individual facilities.

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       Respondents from state technical assistance programs reported being able to identify
 opportunities for waste reduction as well as specific operation and maintenance projects.  None
 of the programs offer engineering services or precise estimates of costs and savings. They also
 generally supply relevant literature about the suggested projects.

       ConnTAP staff felt that it was important to offer a comprehensive set of services. No one
 program could meet all needs.  Some people benefitted most from seminars, others from onsite
 visits. All services were necessary to spread awareness of the availability of help.

       ConnTAP staff also reported helping firms find vendors who could help the firms with
 their particular problems.  Whenever feasible they provide companies with lists of vendors or
 suppliers who could help the firm.

       CT, RI, and NH staff all felt that management support for pollution prevention and a
 pollution prevention champion were needed in order for the company to hear and act on their
 suggestions.  In addition there was general consensus that while they could always find a few
 things in larger, profitable firms with a sophisticated environmental staff, they could offer the
 most help to  smaller, less sophisticated, less profitable companies.

       CT staff also felt that they could offer little assistance to companies that were viewed as
 "cash cows" by absentee corporate owners.

       CT staff also reported that matching grants to explore the feasibility of pollution
 prevention options have been an important source of information for CT companies, and that
 often these results are useful to  other firms as well as the grant recipient.

 Industry Respondents

       Sources of assistance included: U.S. EPA, U.S. Department of Energy, state technical
 assistance programs, state departments of environmental protection, and EPA or state-supported
 university technical assistance programs.  Assistance was provided through onsite visits, written
 literature, seminars, courses, hotlines, and interns provided through university programs.

       Several facilities reported government technical assistance as their primary source for
 pollution prevention ideas. A NJ metal products company (11) participated in an environmental
 action course given by a local utility. The respondent learned what pollution prevention was all
 about. After the course, the contact changed the procedure for handling rags and recycled
 materials.  A NJ metals facility (12) received an onsite visit from the state.  The contact found
the state's planning requirements difficult to understand and asked for assistance. A NY metal
working facility (19) was visited by a third party, state funded technical assistance provider.  The
technical assistance person conducted a pollution prevention audit. The contact stated that the
audit did not reveal anything he  was not already aware of.
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       A CT chemical company respondent (24) raved about his onsite visit from the state
technical assistance program. The contact reported that the state made some very good
suggestions which helped him prevent pollution and increase efficiency. He had called the state
technical assistance program because of recommendations by others in his industry.  A degreaser
in VT (30) received all of his pollution prevention ideas from a retired engineer working with the
VT DEP Pollution Prevention Division.  The degreaser found the engineers' ideas to be useful
and was referred to an interactive televideo conference given by the University of Tennessee. A
NH metal facility respondent (31) raved about the technical assistance he received from the state
of NH. The respondent's feelings toward EPA and state environmental programs became more
positive after the visit. The contact cited this as an example of what the government does well
and should do more of.

       A NH metals facility (38)  engaged in a state supported pollution prevention partnership
with the University of New Hampshire Chemical Engineering Department. The degreaser
reported that a student conducted a cost analysis of new equipment, tested alternative cleaners,
and made recommendations. The contact stated that this was an "excellent program".   A NH
wood facility (40) learned about the state technical assistance program from a state published
newsletter. The respondent learned of pollution prevention options as a result of an on-site visit.
A RI metal plater (41) received onsite technical assistance from the RI DEM, University of RI
Technical Assistance Program, and the local publicly owned sewage treatment works (POTW).
Both DEM and URI recommended several options. The facility implemented some but found
the others not feasible.  The POTW had some new ideas which were helpful. Overall, the
respondent thought the services provided would be best for companies just getting  started in
pollution prevention.

       NH PPP suggested that a large NH plater (9) use soap and water instead of "speedy dry"
to clean up spills. This resulted in a savings of $70,000 in waste disposal costs annually. The
team also identified the waste streams where additional environmental progress could be made.
The chief operator gradually worked his way down the recommendation list and implemented
changes.  Newsletters and seminars from EPA New England about the 33/50 program coupled
with information at trade organizations led a MA plater (4) to consider eliminating PCE. The
general manager had tried various substitutes but none had worked.  The MA Office of
Technical Assistance suggested that the firm change the tallow used to coat the parts.  This
suggestion worked for some applications. The small metal finisher found seminars and
publications unhelpful because people like him have a lack of time.

       In a few instances, respondents reported that technical assistance did not have an
immediate impact on facilities. A small NH plater (6) had onsite visits, but did not have the time
to implement recommendations until the company received a free intern funded through a
 Supplemental Environmental Project imposed on another company.  This individual made it
 possible for the company to implement numerous pollution prevention projects as well as come
 into compliance.  A MA plater (4) has not yet had the time to implement the Massachusetts
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Water Resources Authority (TV1WRA)'recommendations on re-piping the water to their pickling
tanks. The company has not had time to do the work even though it would have an almost
immediate payback. A CT company (8) received a matching research grant to evaluate whether
it could switch from zinc phosphatizing to iron phosphatizing. The grant galvanized
management to provide the resources needed to study the prospects. While the process resulting
from the research was not suitable for the chemical company's product, it will work for firms that
make gaskets and sealers used on interior applications.  A ME woodworker (5) stated that "we
are from Maine and don't take advice real good." His company prefers to develop projects in-
house, although it will rely on insights from members of the Maine Woodworking Council for
Waste Management Practices.

Private Technical Assistance

       Sources of assistance included: suppliers, consultants, trade organizations, utilities,
industry colleagues, and internal corporate  consultants.  Assistance was provided through
journals, trade articles,  seminars, courses, and advertisements.

       Several facilities reported receiving  some form of private technical assistance.  A NJ
metals facility (12) had an environmental consultant analyze production lines and  sources of
hazardous waste streams. A number of options were generated and implemented. A NJ
chemical company (15) receives ideas from activities undertaken at the company's other
facilities. The  respondent, claimed he was too busy to receive technical assistance from other
sources.  A NJ chemical company interviewee (17) responded that he never received technical
assistance.  When probed, the contact said pollution prevention ideas were generated by
environmental  consultants hired by the company and the firm's own internal technical  staff. A
NY metal plater (20) received technical information, case study write-ups and contact and
resource lists from various industry publications.  The contact also calls the Environmental
Compliance Network of Southwest New York, sponsored by his trade association, for additional
information. A large chemical company in NY (21) hired environmental consultants and
contracts with  the firm's in-house environmental group to develop pollution prevention options.

       A VT degreaser (30) believed his chemical suppliers to have expertise that was more up-
to-date than the state technical assistance professionals. The facility uses the state experts for
advice on what should be done but takes advice from their suppliers on how it should be done.
A ME woodworker (34) learned of pollution prevention ideas from industry contacts.  A metals
facility in NY (35) learned of pollution prevention options from literature and advice supplied by
their suppliers, trade associations. The contact also cited advertisements in trade journals as
sources for ideas. A ME chemical company (37) received assistance from equipment suppliers.
The contact found assistance from equipment suppliers to be more reliable because "they have
more at stake for being right and have an incentive for being right because (their)  livelihood is
on the line." The contact also felt that suppliers are "much more qualified" to give technical
information.
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       Some respondents expressed reservations about private technical assistance.  Some
contacts believe that suppliers will try and push the technique or chemical that they represent,
rather than discussing other options that are appropriate.  A VT wood manufacturer (29) reported
being constantly barraged by environmental consultants seeking new business.  The contact
found them to lack the necessary technical expertise. A contact at a NH metals facility (31)
found it difficult to get good pollution prevention ideas from his suppliers. The contact felt that
the suppliers he was working with were not "telling the whole truth" because they were more
interested in making a sale. However, when the correct solution is found, the suppliers were
very quick to respond. A NH metals facility (38) was concerned with the technical assistance
received from suppliers and consultants because he believes "they are primarily out to make a
buck, rather than deliver a good service."

       Respondents also named a number of additional concerns with private technical
assistance. Chemical suppliers often leave product that ultimately has to be disposed of as
hazardous waste.  As a result, a CT metals company (8), two NH platers (6, 9), and a ME
woodworker (5) do not allow salesmen to drop product off without approval and only if vendors
agree to take waste back with them. A Maine woodworker (5) indicated that the suppliers often
do not come out to the "boondocks". The ME woodworker also expressed reservations about
consultants. The ME woodworker felt that the consultants he paid often called the same
government hotlines and information sources that he could call himself. The firm also had an
unfortunate experience with  a consultant hired by the ME Woodworkers Association to develop
a group stormwater discharge permit.  When the work was completed, EPA had changed the
regulations. The company felt that the consultant should have been more in touch with the
regulatory development  process.

Costs/Savings

       Only aNJ metals facility (13) mentioned costs as the generator of pollution prevention
ideas.  After noticing the high cost of waste disposal, the facility realized it would pay for them
to be proactive and reduce the amount of waste generated.

Management Systems

       Some respondents reported that pollution prevention ideas were generated by dedicated
environmental teams or  cross-functional teams that were formed with the specific task of looking
at prevention. To arrive at the best solution, respondents mentioned the importance of involving
members from various groups within the organization.

       A NY wood furniture manufacturer (18) conducted an in-house pollution prevention
review to develop options for waste disposal and reducing the quantity of waste generated.

       Respondents with a NY chemical plant (21) and a NJ chemical plant (15) both cited total
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 cost accounting as tools that helped them identify pollution prevention options.

 Employee Commitment

       Respondents with Facility 1 referred to the involvement of their employees in
 discovering and implementing pollution prevention measures. The workers are responsible for
 testing water-based coatings on new and older products until they "get it right".  "Getting it
 right" in this example means minimizing the amount of raised and rough surface area which
 results from applying water to wood. When the surface rises in spots, the wood feels rough to
 the touch and must be smoothed out by sanding. In contrast, solvent based coatings do not
 produce this effect when applied to wood thereby avoiding any need to add a sanding step to the
 finishing process.

       One respondent, with a large metals plant in NY (19), mentioned the self-initiative of
 employees  as the generator of pollution prevention ideas. The respondent cited instances where
 the engineers or environmental staff would develop ideas on their own time, which in some cases
 resulted in these new systems being patented.  A contact at a NY wood furniture company (18)
 said all pollution prevention ideas are generated as a result of the workforce knowing the
 operation and related systems well.

 Resource  Constraints

       A number of those interviewed were unaware of pollution prevention programs and state
 requirements (if applicable). Respondents simply stated  that they never heard of some programs
 (33/50, governor's awards) or asked the interviewer to explain the program.  Once the programs
were explained, interviewees would sometimes express an interest in the program or state that
they thought the program was a good idea. There were two cases when a respondent asked for
 specific program information to be sent to the facility.

       In some cases, respondents had heard of programs but cited lack of time as a constraint to
participating.  Some individuals noted that they were busy dealing with issues that were more
important to the business.
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                                   APPENDIX H

        FACTORS THAT INFLUENCED RESPONDENTS' CHOICES
                 OF POLLUTION PREVENTION PROJECTS
       The following appendix discusses the factors that respondents reported as influencing
their decision of which pollution prevention projects to implement and the implementation of
them.

Regulatory Compliance

State Respondents

       The MA DEP's analysis of the "Blackstone Project," in which the state used inspectors
trained in pollution prevention to conduct multi-media inspections and referred companies with
violations to the technical assistance agency, indicated that those companies ordered to evaluate
pollution prevention were most likely to find and implement pollution prevention projects. One
MA plater that had been the subject of a multi-media inspection, however, did not mention it as a
factor in the implementation of pollution prevention. A RI metal working company said that
multi-media inspections would be very beneficial, while a ME wood working company felt that
multi-media inspections would not offer any benefits over regular inspections. Several
respondents reported that inspections were very important for promoting pollution prevention 
inspections were the most effective way to learn what was expected of them.

       ME state agency staff felt that compliance with the mandatory reduction law led to a
large number of pollution prevention projects that would not have happened otherwise. ME staff
also felt that compliance with the Clean Air Act as well as the labeling requirements for ozone
depleters has also led firms to implement specific pollution prevention projects.  ConnTAP staff
found that many firms implemented pollution prevention to get out of regulatory oversight
completely.

       In addition, enforcement actions reportedly led several large companies in Maine to
implement pollution prevention projects. Two state Supplemental Enforcement Actions (SEP) in
Massachusetts reportedly have led companies to implement pollution prevention above and
beyond what was required to comply with the law.  In  addition, in one case a firm was able to
comply with water discharge standards without treatment, after hiring a pollution prevention
planner pursuant to an SEP.

       CT, RI, and NH state agency staff said  companies were most likely to  implement specific
pollution prevention projects after being referred to the technical assistance office by regulatory

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agencies. In NH referrals from the POTWs also led firms to adopt pollution prevention.

       CT staff have also found that military specifications and Federal Food and Drug
Administration (FDA) regulations have been obstacles to implementing pollution prevention
projects. It can take several years to obtain FDA's approval of changes in production processes.

Industry Respondents

       Compliance with environmental regulations led companies to implement particular
pollution prevention projects.  Many projects were reportedly implemented specifically to bring
the company into compliance with particular environmental standards.

       In at least one instance, however, a compliance issue led to the implementation of
projects that were not related to achieving compliance.  A letter of deficiency, which contained a
referral to the pollution prevention program, led the president of a small NH plater to contact
both the NH DBS and the University of NH to obtain an onsite technical assistance visit at which
a number of pollution prevention options were identified. Ultimately, the firm received an intern
supported through an SEP imposed on another company. This intern reportedly provided the
expertise and labor needed to implement a number of "housekeeping type" pollution prevention
projects, as well  as improve compliance with environmental regulations in general.

        The need to comply with  environmental standards with or without an enforcement action
was reportedly the determining factor in the decision to implement particular pollution
prevention projects in a number of instances.  An enforcement action based on cyanide discharge
violations led a MA plater (4) to  move to cyanide less plating. The need to comply with water
discharge standards led a CT metals company (8) to apply for a technical assistance matching
grant to determine whether they could use iron instead of zinc phosphate to treat their material;
close loop their cooling lines to comply with the aquatic toxicity standards; and change hang
time to reduce zinc discharges. These measures were instituted instead of treatment just before
their permit was called for renewal.

        A RI metal working company (7) installed a closed loop aqueous degreasing system in
response to violations of the grease and oil discharge standards. This system was designed to
allow the firm to disconnect from the sewer system. A NH plater (6) dropped cyanide plating
and other types of business in response to the need for wastewater pretreatment. The
aggravations and expense of dealing with these materials were not worth the business.  One
reason why a NH plater (9) also  switched from TCE to aqueous degreasing was because of the
costs of compliance with worker health and safety regulations.

        Concerns about past and future remedial actions also led companies to adopt particular
pollution prevention projects and policies.  A Superfund liability was the impetus for a CT metal
facility's (8) prohibition on bringing chemicals in house without the prior approval of the
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environmental compliance manager.  The company had disposed of one drum of a chemical at a
TSDF that subsequently went out of business leaving the firm with a $40,000 bill for their share
of the clean-up costs.  In addition, the firm incurred high costs to dispose of "free samples", left
by vendors, as hazardous waste.

       Some industry respondents reported feeling that Supplemental Environmental Projects
would be useful in promoting pollution prevention. A CT metals company (8) felt that as long as
the economic benefit portion of a penalty was not mitigated, there would be no ethical concerns
about "rewarding" companies that were in violation.

       There were companies and projects, however, in which environmental compliance played
only a peripheral role in the implementation of pollution prevention. For example, the bulk of
the pollution prevention projects implemented by a ME woodworking plant (5) had nothing to do
with environmental compliance. Similarly while compliance issues raised the corporate
consciousness, many of the specific projects at a CT metals company (8), a large NH plater (9),
and a MA plater (4) reportedly had little to do with compliance and more to do with savings or
production issues.

       Facility 1 discussed the effects of the Clean Air  Act on moving away from high VOC
solvent based sealers and coatings to using water based solutions on certain items of furniture.
Under Vermont air regulations, a facility may emit up to 100 tons per year of VOC's without
having to get an air permit. In  1994, they emitted 1TA tons of VOC's into the air. Had they
used no water based coatings at all, the facility estimates that it would have emitted 11 V/z tons of
VOC's into the air, 111A tons over the allowable limit which would have forced them to apply for
a permit. In order to keep their production levels up while continuing to avoid getting an air
permit and paying the associated fees, the company decided to substitute water based coatings
for high VOC coatings where technically possible.

       As a pharmaceutical manufacturer, Facility 3 spoke about the adverse effect of needing
FDA approvals before doing certain types of pollution prevention. Under FDA rules, a facility is
required to gain approval before doing any type of raw  material substitution or process
modification.  Recycling of reaction carrier solvents must also receive prior approval from the
FDA. The review process is lengthy, taking anywhere from 24 to 36 months to receive approval
for such a modification. In their Waste Reduction Plan prepared pursuant to the New York
Waste Reduction Act,  Facility 3 summarizes the issues and concerns that must be addressed as a
pharmaceutical company as it relates to implementing source reduction measures:

       "It must be noted that [Facility 3] is a manufacturer of Pharmaceuticals and as such,
       virtually all manufacturing process components are governed by New Drug Applications
       (NDA) which have been previously approved by the U.S. Food and Drug Administration
       (FDA). In most cases, these governing regulations serve to prevent or severely hamper
       process waste reduction efforts, especially those geared toward source reduction and
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       recycling.  Any material substitutions, or recycling of reaction carrier solvents must first
       receive explicit approval from the FDA.  This approval must be preceded by an NDA
       based upon successful testing compliant with all FDA regulations. The approval process
       often requires a considerable commitment of time and resources for research and quality
       analyses. For this reason, the following source reduction strategies are not applicable for
       reduction of process solvent wastes: change in product composition, raw material
       substitution, raw material modifications,  raw material purifications, return of wastes to
       original process, raw material substitution for another process."

       In general, in order for Facility 3 to decide that filing the paperwork for FDA approval is
worthwhile for a pollution prevention measure, they must decide that there is a positive return on
the investment and the product must be made continuously and year-round.  The company is also
developing a Technology Transfer Document which will outline a process to be followed when
taking a new drug from research and development (R & D) to  production.  This process will
include investigating all sorts of pollution prevention opportunities at the R & D level instead of
down the line  at the production level.  The document will also emphasize that all possible
pollution prevention measures are assessed before applications are filed with the FDA.

       When asked how the government could improve pollution prevention efforts,
interviewees at Facility 2 responded with a discussion about environmental reporting and
compliance in general.  They expressed support for programs that were voluntary, simple,
flexible and performance based. They also stated their frustration over having to  spend time
providing duplicative information to the state and federal government and said information
should be shared instead of placing an added burden on industry to report the same data to more
than one entity. They also felt strongly about EPA developing one list of priority pollutants and
sticking to it instead of making facilities keep track of different lists for different environmental
protection programs.

       A ME law requires that hazardous waste levels and the use of extremely hazardous
chemicals be reduced 20% below 1990 levels.  The law was reportedly the driving factor behind
the ME woodworker's (5) elimination of toluene in its lacquer thinner. The company resents the
idea that they are mandated to reduce by a certain amount, but they recognize that mandatory
planning is beneficial.  Showing progress is particularly difficult for them because they made a
lot of progress before 1990 and because a fire in 1990 destroyed many of their records.

       When a MA metal plater (4) switched to cyanide-less plating he was violating the
military specifications. However, he was able to overcome his customers' concerns by "pulling
the green routine".

       Although several firms simply stated "regs" as a factor in the decision to do pollution
prevention, some stated that "pollution prevention was mandated by the state" or believed that
pollution prevention was necessary to "keep in compliance" with federal and state environmental
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rules.

       A CT furniture manufacturer (22) found some regulations to hamper pollution
prevention.  The respondent cited state toxic air emission rules that imposed constraints on the
firm's ability to use new formulations. The new formulations, although reducing VOC's, would
increase the facility's emissions of hazardous air pollutants (HAP's), some of which are also
VOC's.

Staying Ahead of Compliance

       Some surveyed companies also decided to implement pollution prevention to minimize
the problems related to future environmental compliance.

       The main reason that a RI metal working facility (7) is purchasing a $300,000 enclosed
automatic parts degreaser is to avoid future environmental and occupational health compliance
issues. They believe that this system will comply with any conceivable standards for the next 20
years.  It would be much less expensive to continue with the aqueous degreaser and obtain a
periodic discharge permit  although the environmental manager was not aware of this option.

       The desire to avoid upcoming clean air act regulations on MEK was the decisive factor in
a CT metal facility's (8) decision to participate in 33/50 by developing a solvent-less adhesive
process.

       A NY pharmaceutical company respondent (3) referred back to the company's decision
in the 1970's to stop using chlorinated solvents. Company managers did this before any
government rules came into effect about mandatory phase-outs. They knew that these chemicals
"were not good to use" and in anticipation of future government bans, they wanted to be ahead
of the curve.

       In using all water-based sealers and coatings on their furniture, a VT wood furniture
manufacturer (1) emits low levels of VOC's into the air, far lower than government rules allow.
The decision to use all water-based solutions was driven largely by a concern for minimizing
adverse health affects on the company's workers, not because of any need to meet government
standards for allowable emission levels. In fact, this facility uses coatings that contain
approximately 0.67 pounds of VOC's per gallon while Vermont air rules require that by 1996,
furniture manufacturers must meet or go below a 5 pounds per gallon of VOC emissions.  The
interviewee felt that even these standards were too high and that government should mandate
much lower VOC emission levels for furniture manufacturers. As long as allowable emission
limits remain high, he argued, environmentally conscious manufacturers will be forced to pay
almost double the price for water-based sealers and coatings than for solvent-based coatings.  If
the government were to increase the demand for water-based products by lowering allowable
VOC emissions levels, the price of water-based coatings would be driven down significantly.
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The following statement by the interviewee sums up this sentiment: "We pay through the nose
for something that we feel is the right thing to do. If EPA could lower the allowable VOC
emissions levels, it would be worth the time of this phone call." He qualified this statement by
saying he should not be penalized for being ahead of the curve if the government eventually does
take this action. Under this scenario, he said, businesses who were pro-active should be given
credit for their past achievements.
                     -.
       A VT wood furniture manufacturer (27) switched out of solvents to water-based finishes
in order to "opt out under Title V".  The company goal is to generate less than ten tons of
emissions per year in order to keep under the regulatory requirements.

Mandatory Reporting

       This category included both toxic release inventory reporting and materials accounting or
toxics use reporting. It could also include biennial hazardous waste reporting, although none of
the interviewees mentioned that as a motivator.

       Several companies spontaneously mentioned the importance of reporting requirements in
the implementation of particular projects.

       A RI plater switched to aqueous cleaning (7), and a Maine woodworker (5) switched out
of toluene in part to get out of TRI reporting.

       A MA plater (4) found that TRI helped him to quantify pounds of chemicals wasted - he
knew he  had a problem prior to the reporting requirement. The reporting requirement
established a benchmark for measuring progress.  Use has not gone up and use of one chemical
has been reduced below the reporting threshold since the first reporting year, despite the fact that
business  has increased by  120%.

       The Maine mandatory planning law, and the associated need to do materials accounting
reportedly led the plant engineer at a ME woodworking facility (5) to implement a thorough
inventory tracking program.  The firm complied with TRI by hiring a waste disposal company to
do an initial inventory to determine whether or not the firm was subject to TRI. When the new
Maine program came out, he reviewed the MSDS of every product and computerized the gallons
used and the concentrations of the reportable chemicals. Now all production personnel have to
provide daily logs about how much they use of each product - which he checks against the
inventory.  There has been no resentment because the staff understands that it is for the
environment.

       Facility 5's new inventory control system has been very useful to track progress, comply
with regulations, and to encourage further reductions.  It also has resulted in much better
inventory control and a reduction of "expired" chemicals that need to be shipped as hazardous
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waste. Improved inventory control has been particularly important because production has
increased so much.  Without it, it would have been difficult to keep the right amount of product
in stock.

       Although a NY metals facility respondent (19) reported that "definitely SARA, and state
reporting requirements were factors", a NY chemical manufacturer (21) explained that TRI just
makes "you more visible" but it "didn't provide the incentive" to do pollution prevention.  A NJ
chemical manufacturer (17) stated that "TRI had no direct impact" because they were simply
"statistics that would be reported to corporate personnel".  A NH chemical plant respondent (32)
explained that "TRI really doesn't do anything".

Mandatory Planning

State Respondents

       MA agency staff report that MA DEP data indicates that mandatory planning resulted in
the identification of many pollution prevention projects that might otherwise not have been
found. The percentage of chemical  use that ends up as waste is expected to drop from 11% in
1993 to 8% in 1998  a 25% improvement in efficiency. In addition, a statistically valid sample
of firms that had completed TURA plans indicated that 67% found that planning was helpful in
some way,  and 80% planned to implement some pollution prevention.  ME agency staff also
report that  their data suggests that planning is leading to a great deal of pollution prevention.

Industry Respondents

       A ME woodworker (5) and a MA plater (4) both felt that planning revealed a few
pollution prevention opportunities that they had overlooked. However, both stated they had
made most of their advances prior to the planning requirement.

       As a result of planning, a ME woodworker (5) prevented pollution by closing containers
and scheduling colors in the painting tumblers so less frequent clean-out was required. In
addition when workers dropped product in the finishing area they began to  clean it off instead of
throwing it away. These strategies were identified during monthly meetings among management
and production staff in each area.

       A MA plater (4) found planning somewhat useful in that it  forced the firm to look at
things in a new way and improved the interaction between management and operators. They did
not discover anything except some O&M related projects.

       A CT metals company respondent (8) also thinks planning and materials accounting is
very useful  in indicating where pollution prevention opportunities are. Materials accounting
forces the firm to put their operations down on paper and actually see what is going on, and
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identify pollution prevention opportunities. The respondent thinks many companies will not do
it unless forced to.

Voluntary Programs

       Voluntary programs include governor's or EPA awards, the 33/50 program,
environmental excellence programs, and Responsible Care.

State Respondents

       Of all the state respondents surveyed, only NY staff felt that voluntary programs such as
33/50 and governor awards led to the implementation of pollution prevention projects. CT and
RI staff felt that some companies, however, like the awards as publicity tools. There was general
consensus that these programs worked best for larger sophisticated firms with strong
environmental staff.

Industry Respondents

       A MA plater (4) and a CT metals company respondent (8) both cited 33/50 as an impetus
toward the implementation of specific pollution prevention projects at their facilities.

       A CT metals company respondent (8) did participate formally in 33/50, and although he
did not know it was a possibility, won an award for developing a solvent-less coating.  33/50
created a challenge that company management wanted to meet.  While the desire to avoid the
need to install air pollution control equipment was the deciding factor in going forward, the
formalized commitment to the program helped the company to continue working on the problem
when obstacles arose. The facility's environmental compliance officer said that awards are
valuable marketing tools because firms can use them to show customers that production
disruptions due to environmental violations are highly unlikely.

       A Maine woodworking company respondent (5) considered participating in the awards
program, but felt that the chances of winning were too low to offset the attention that would
arise.  In addition, he preferred not to draw attention to his company in any way.

       Facility 2 takes part in a corporate awards program which recognizes business units,
teams and individuals for their excellence in creating and promoting sound environmental
practices which also save the company money.  Monetary awards are given to teams who then
select an organization to which they may give it.  In the past, recipients have donated their cash
awards to local environmental and public interest groups to support, for example,  battery
recycling and other educational programs in  schools and riverfront cleanup efforts.

       A NH chemical company respondent (32) reported that the Responsible Care program
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had "no effect" on their decision to do pollution prevention. The respondent explained that they
"simply report activities to Responsible Care. It's easy to make promises because [we are]
already doing those things...on the road already."

Government Technical Assistance

State Respondents

       All of the state technical assistance agencies report having made specific suggestions that
would save money and reduce waste after almost every site visit.  CT agency staff stated that
"the extra pair of eyes can always find something". For example, their staff found one valve in a
large well run facility that was discharging 25,000 gallons of water per year needlessly.

Costs/Savings

State Respondents

       All of the technical assistance program respondents felt that savings caused companies to
implement pollution prevention projects. However, savings alone were not always effective.
ConnTAP has found that some firms only pursue those pollution prevention suggestions that are
directly related to compliance issues, even if some of the other suggestions could save the firm
money.

Industry Respondents

       Costs and savings were a big factor in the implementation of pollution prevention
projects. Firms initiated projects to save hazardous waste management costs, wastewater
treatment costs, solid waste disposal costs, air pollution control costs, raw material costs,
insurance costs, laboratory fees, consulting fees, and labor costs.

       A number of the firms surveyed cited costs as the primary factor in their decision to
prevent pollution. When interviewees were asked to elaborate as to how it was a factor,
responses focused on either an economic return or savings from not having to treat or dispose of
waste. Selected responses follow: "it's cost effective", "it just makes sense", "saved money",
"save money on disposal costs", saw an "economic return", "disposal costs are high",
"financially feasible", "economics made sense", "there was a payback", "justified based on
costs".

       A large NH plater (9) saved hazardous waste management costs by replacing "speedy
dry" with soap and water, closing the loop on the anodizing line, and installing a
purification/reclamation system.   The company used to decant a third of the tank per week as
hazardous waste.  It is also working with consultants to evaluate reclaiming the water from the
                                                                                      H9

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rinse tanks. It is unable to reclaim it all because of the soap contamination.

       A ME woodworking company respondent (5) improved inventory control so that stored
material is not discarded as hazardous waste.   He is very concerned about inventory because he
had a shed foil of miscellaneous drums of material that he had to dispose of as hazardous waste
at tremendous cost.

       A CT metals company (8) eliminated zinc phosphate bath dumping to reduce hazardous
waste disposal costs.  Company staff used to dump 400 gallons 1-2 times per week in order to
prevent iron build-up in the tanks, which caused the loss of corrosion resistance. They are able
to minimize bath dumping by using hydrogen peroxide and water to precipitate out the iron.  The
resulting iron phosphate is almost always a non hazardous waste.  On the few occasions in which
it is contaminated with chrome, the sludge is labeled and disposed of as hazardous waste.
Hazardous waste shipments from this line have dropped to 6-7 drums per year from 40,000 cubic
yards and has resulted in over $100,000 in savings. The peroxide use is minimal - 100
milliliters/tank/week.  The firm sells this technology, which was developed in-house, to other
companies.

       Facility 8 also eliminated cadmium-cured rubber to reduce hazardous waste costs.  The
company simply told customers it would no longer make the product.  The product without
cadmium has a heat tolerance 4 degrees Fahrenheit lower than the rubber with cadmium. When
the company explained to its  customers that the change was for environmental reasons, almost
all accepted it. Company staff also plan to eliminate pumps that use a water soluble oil that
contains one part per million  of cadmium. When oil leaks, as it inevitably does, and they clean
the floor, the entire batch of waste rubber becomes hazardous waste. They have stopped mixing
the cadmium contaminated oil in with the rubber.

       Facility 8 also instituted a policy of not accepting chemicals without the environmental
manager's prior approval because of Superfund liability and the high cost to ship the "free
samples" out as hazardous waste.

       A MA plater (4) eliminated cyanide plating and use of certain substrates such as lead, and
painted material, to avoid the costs and aggravations of wastewater treatment. The company
eliminated cyanide plating by converting to an alkaline system.  The MA plater also plans to re-
pipe pickling rinse water to NaOH rinse tank. This was suggested by the MWRA as a water
conservation measure. Repiping would help neutralize the NaOH so less acid would be needed
in the NaOH rinse tank. (In addition less NaOH would be needed in the wastewater treatment
plant because the acid would have been neutralized during the production process.) MWRA also
suggested installing some conductivity meters. The MA plater is also thinking about installing a
recycling system to use treated waste water for interim rinses.  The company has already cut
water usage in half from reuse and flow control.  This is very important to the company  staff
believe they would not still be in business if these changes were not made, due to their high
 mo

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water and sewer bills.

       A CT metals company (8) found that it was less expensive to comply with the aquatic
toxicity discharge standards by spending $15,000 to close the loop in the press room cooling
water line.  Cooling water always failed aquatic toxicity, but company staff could never figure
out why -the chemical analyses didn't reveal anything that could cause a problem.  The change
greatly reduced sewer bills, but had no effect on water bills because the firm uses its own well
water.

       Companies also reported implementing pollution prevention projects to save raw
materials. A ME woodworking facility (5) reworked rather than burned off-specification pieces
of its major product. Staff believe the product has to be absolutely perfect. Because of the
required precision, they were burning large amounts of the wasted product. The firm began
trying to rework the product and found that it  could be done relatively easily.  Now it has a
whole department to rework products and has greatly reduced wax and wood costs. The
woodworker switched to an automatic fired boiler, which was more energy efficient, reduced
smoke, and was much less costly to operate.

       A large NH plater (9) also took steps to improve materials handling. Workers used to
just scoop out handfuls of chemicals to add to  the baths. Now they weigh out precise amounts.
The company saved $79,000 the first year the interviewee took over operation of the anodizing
line and implemented this policy.

       A respondent at a VT wood furniture manufacturer (1) discussed a number  of cost factors
which propelled the company forward with its  pollution prevention measures.  He cited liability,
waste disposal costs and insurance premiums as strong motivating factors. When this company
decided to move out of its rented building and  construct a new facility, it was confronted with
many decisions about floor design and the types of materials to use to finish furniture.  An
awareness of the fire risks inherent in storing large quantities of solvents led the company to
involve fire inspectors in the early stages of plant design.  Aware of the fact that solvent based
solutions are highly ignitable and water-based solutions are not, the facility committed itself to
begin using water-based sealers and coating solutions wherever technically feasible.

       Using water-based solutions in some of its manufacturing operations has also reduced
Facility 1's generation of hazardous waste for off-site disposal.  When the company coats with
water-based solutions, any residue cleaned up afterwards is disposed of as regular solid waste.
Residue which collects in filters and from dried up stains on the floor after solvent based
coatings are used is segregated for hazardous waste disposal. Although the use of water-based
coatings has reduced the amount of hazardous waste, use of the  new coatings has increased total
production costs. Water-based sealers are more than twice the cost of solvent sealers with an
only thirty percent increase in coverage. Water-based  topcoats cost seventy-five percent more
than the solvent equivalent with only thirty percent more coverage per gallon.  The  wood
                                                                                     Hll

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furniture manufacturer provided the following 1994 figures:

Actual gallons of solvent used	    25,049 gallons
Actual gallons of water-based used	    14,175 gallons
Actual VOC	         77-5 tons
Estimate if no water-based coatings were used	        113.3 tons
Increase finish cost due to use of water-based	   $ 59,202.00/ton
Estimated decrease in hazardous waste cost	   $  9,000.00/ton
Estimated cost of using water-based finishes	   $ 50,202.00/ton
Costperton of VOC reduction	   $  1,402.00/ton

Competitiveness Issues

       The need to increase production, or produce a better product and otherwise respond to
competitive pressures led to the implementation of pollution prevention in some cases. A Maine
woodworker (5) developed a new finish for the firm's major product and purchased more
efficient spray guns and a spray booth in order to speed production.

       ANH plater (6) automated the company's anodizing line and chemical input, and hired a
plant engineer in response to growing production demand and the need for quality control. This
had significant impact on the company's chemical use and waste.

       Conversely, a CT metal company's (8) MEK elimination project, which was done for
pollution prevention reasons, resulted in the unanticipated benefit of faster production processes.
When the company switched to the non-solvent adhesive, staff discovered that the curing time
went from 90 seconds to 45 seconds.

       Similarly the water reclamation project at a large NH plater (9) was initiated as a
pollution prevention project, but it had other benefits as well - when the company filters the
water it has more consistent conditions and better product quality.

       Production issues at a NH plater (6) were also obstacles to pollution prevention.  For
example, increasing "hang time" to  reduce zinc wastewater concentrations lowered production
speed so much that the project was almost derailed.  The environmental manager overcame this
obstacle by working with production staff to identify time savings in other parts of the
production line.

        A VT furniture manufacturer (1) talked about the differences between individual
customer acceptance and acceptance by commercial clients of furniture coated with water based
lacquers.  He suggested that individual purchasers are more responsive to green marketing
claims than larger commercial customers who tend to err on the conservative side and question
whether their customers would purchase furniture that was not finished with solvent coatings.
 H12

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 He has found that individual purchasers, in contrast, are more willing to compromise quality to
 some degree in exchange for a product that was manufactured in an environmentally sound
 manner.

       A NY wood facility respondent (18) explained that the company was not "influenced by
any outside sources" and was doing pollution prevention because of the firm's constant drive
 toward production efficiency.

 Management Systems

       Facility 2 uses nearly a full cost accounting system. One of the interviewees cited this as
 a major driving force for preventing prevention. Previously, the facility "buried" its waste costs
 in a fixed costs category. Now the costs of managing waste associated with a specific product
 are assigned to the cost of producing the product.  This accounting system paints a clearer
 picture of the true costs of producing any one product and assists the company in pricing
 decisions and in assessing the product's profitability.

       A NY pharmaceutical company respondent (3) noted that the company is just beginning
to attach hazardous waste disposal costs directly to its bulk active intermediates sold to third
parties. Passing disposal costs onto customers has not yet been integrated into Facility 3's
pricing structure for all products, but the company is moving in this direction. Environmental
permit fees, however,  are still factored  as expenses for the Environment, Safety and Health
Division and  are not tagged directly to  products.

       Respondents with a NJ chemical plant (16) and a chemical facility in MA (26) cited
company-defined codes of good environmental practices as decision factors. These firms
reported that pollution prevention is an integral part of the firm's daily operation.

       A respondent at a NJ chemical company (16) explained that his facility was regularly
audited for pollution prevention by the  corporate office.

       A NY metal manufacturer's (20) total cost accounting  system plays a significant role in
the decision to implement pollution prevention.  The accounting system is also used to help
select prevention options.

Environment, Health and Safety Considerations

       The importance of being a good citizen leads a large NH metal plater (9) to  quickly
approve any pollution  prevention projects that will pay themselves back. The payback
requirements  are less stringent for pollution prevention projects than for other types of projects.

       Certain companies also implemented particular pollution prevention projects in response
                                                                                     H13

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to worker health and fire and explosion safety concerns, and concerns about chemical spills. For
example, a CT metals company (8) stopped making products that contained ethylene thiourea
because, according to the literature, the chemical has been associated with increased
miscarriages in workers.

       A ME woodworking plant (Facility 5) switched from solvent to aqueous parts degreasing
in its machine shop, and when aqueous degreasing failed, went to mineral spirits in response to
worker hazards. Concern for worker health and safety contributed to a NH plater's (6) decision
to switch to aqueous degreasing.

       Facility 2 management has made safety and the environment a top priority. This is
outlined in the company's statement of corporate principles which is posted throughout the
facility. One of the interviewees reported that the facility has been taking pollution prevention
very seriously for the last five years. Pollution prevention is also part of their employees'
performance assessment reviews. Environmental, health and safety issues impact employees'
pay raises and bonuses. During the review process, management reviews various statistics and
incident reports regarding environmental releases and injuries.  They also have a metric for
nonproduct output which is factored into employees' evaluations and it also impacts whether and
how much of a raise or bonus is given.

       The respondent at a VT wood furniture manufacturer (1) raised worker health and safety
as a primary motivator for preventing pollution. This furniture manufacturing facility switched
100% to water-based coatings from solvent coatings because of the awareness that working with
water is far healthier than working around large amounts of solvent solutions with a high VOC
content. The facility also emphasized that one of its strongest motivators for switching to water
based coatings from solvent coatings in 1990 was to "do the right thing." The interviewee stated
that "moving away from solvents was just a better way to do things." He proudly reported that
while in 1989 his facility emitted 90 tons of VOC's into the air, he has since doubled his sales
and only emits 6 tons of VOC's per year.  He expressed his concern that he and his  workers had
to breathe large amounts of solvents on a continuous basis, and felt that if there was a way to
reduce these risks, he wanted to do so.

        Respondents cited their desire to be good citizens and concern for the environment,
community, and workforce as decision factors.  A NJ metal works (13) set a corporate goal of
being as close as possible to self-containment. ANJ chemical company's (17) chairman lives in
the same community as the plant.  A large NY metals facility respondent (19) stated that "it's the
right thing to do" and that employees within the firm are environmentalists and are the "driving
force". A CT manufacturer of wood products (22) stated we all "need to do what we can to
reduce pollution".
 H14

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Public Image

       A VT wood furniture manufacturer (1) alluded his concern about being a good
environmental actor and operating in a manner that was proactive and protective of the
environment. In marketing a line of furniture which carries only water-based coatings , the
company explicitly advertises that it uses water-based in place of solvent-based solutions and
that doing so minimizes the emission of hazardous solvents into the environment. This
marketing technique helps it boost sales among buyers who consider environmental safety when
making their purchasing decisions.

Employee Commitment

       In many situations specific projects were reportedly the results of the efforts of individual
employees.

       The initial pollution prevention efforts at a NH plating company (9) were the result of the
commitment of the chief operator of the anodizing line. One of the first things he did when he
became chief operator was to require that chemicals be weighed out rather than scooped.  This
change in production practice saved the company $79,000 that year.

       He also agreed to a request from NH PPP to serve as a pilot training site for the "retired
engineers" who form the backbone of the NH technical assistance program. During this training
exercise, a number of additional pollution prevention measures were identified.  He
systematically went down the list of pollution prevention housekeeping and operation and
maintenance opportunities identified by the NH PPP team, and addressed each one. After the
firm hired production engineers and had a change of senior management, the production
engineers began implementing larger scale pollution prevention projects, such as aqueous
degreasing and water reclamation, largely as cost  savings.

       At a ME  woodworking facility (5), pollution prevention efforts have been initiated by
both the plant engineer and the owner. The owner's projects were generally designed to speed up
production, with a side benefit of pollution prevention.  These included switching the finish on
their main product, as well as purchasing more efficient spray booths and spray guns.   The plant
engineer initiated projects that had prevention or compliance as their main  intent  such as
eliminating toluene from the lacquer thinner  as well as those that saved money, materials or
increased production. In addition, meetings held to comply with the ME planning law led
workers to identify pollution prevention projects.

       The respondent at a NY pharmaceutical company (3) referred to the lack of staff time
allotted to investigating or identifying possible pollution prevention measures. The facility has a
pollution prevention team made up of people from production, research and development and the
warehouse area,  but finding time to meet regularly is problematic.   She reported that people are
                                                                                    IH15

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busy doing their jobs and that getting together to brainstorm or discuss pollution prevention
measures is only one small part of the team's overall workload. She suggested that if the
members of the team were able to meet more often, they could probably identify additional ways
of integrating pollution prevention into their operations.

Worker Acceptance

       Objections to the smell and the time needed to work with the toluene-less solvent at the
ME woodworker (5) were overcome with the help of the worker/management meetings during
the pollution prevention planning exercise.  When workers understood that the switch was
needed because of the environment, they were very accommodating. In addition, after the
meetings, workers began to pick up and re-coat dropped product rather than simply "trash" it.

       Respondents at a NH plating company (9), a MA plating company (4), and a CT metals
company (8) also found that when they explained that the reason for a change was to protect the
environment, workers became more cooperative in the housekeeping-related pollution
prevention projects.

Customer Acceptance

State Respondents

       CT staff found that companies often were fearful of implementing pollution prevention
projects because of concerns about product quality and customer acceptance.

Industry Respondents

       As with worker acceptance, company staff reported that appealing to the customer's
interest in the environment overcame initial customer objections to material and input
substitution. A MA plater (4), small NH plater (6), and CT metal worker (8) all were able to
retain customers by explaining that they were rejecting a certain product or changing their
production processes  in order to protect the environment. Each company lost a few customers,
but they felt it was worth it. The explanation even worked for a MA company (4) that was
worried about military specs.

        A VT furniture manufacturer's (1) relationship with a cabinet company demonstrates
some of the difficulty  involved with competing against other suppliers who use solvent-based
coatings. When Facility 1 opened its doors in 1989, the cabinet company was its only customer.
At the time, all solvent-based sealers and coatings were used. After moving into its new facility
and expanding its customer base, Facility 1 began substituting water-based coatings on the
kitchen cabinet doors that it made for its client. Within a few months, the company canceled its
cabinet door contract with the manufacturer and streamlined its order to kitchen accessories only.
 H16

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When asked why the cabinet company cut its order so drastically, one of the owners responded
that he was convinced it was because the cabinets did not look as good when displayed in a
showroom next to those coated with solvent lacquers. He claimed that when his product was
displayed in a showroom alongside Italian-made cabinets which had solvent based coatings, their
product simply did not look as good or feel as smooth to the touch.  Customers rejected furniture
using water-based coatings. In an attempt to keep the cabinet company's business, Facility 1
offered to go back to using all solvents on the cabinet doors and to even replace their floor
models at no  cost. However,  the client's confidence in Facility 1 was shaken and they rejected
the offer.

Technical Feasibility

       Technical feasibility was reported as an obstacle to pollution prevention . In some
instances it was an obstacle that could not be overcome. A MA plater (4) ran too many different
plating lines to "go closed loop"  each line would each have to be handled separately. In
addition, the substitution of another protective coating on parts instead of tallow, used to
minimize TCE use, only worked on a portion of the product line. A CT metals company ( 8)
received a grant to switch from zinc to iron phosphatizing, but the resulting seal could not stand
up to the external environment (although it would work in an indoor application). A small NH
plater (6) would like to eliminate chromate baths, but does not think it would be technically
feasible.

       Persistence overcame technical feasibility in a number of cases.  For example, at a CT
metals company (8), the aqueous-based adhesive initially resulted in unsightly spots on the
gaskets and they tore easily. After much work, the operators and formulators developed a
cooling process that did not leave spots and tears.

       When it built its new manufacturing plant in 1992, Facility 1 set a goal to eventually stop
using all solvent-based coatings and move to 100% water-based coatings. The facility is moving
in this direction, but has not yet achieved its ultimate goal.  Based on total gross sales, less than
10% of all furniture that the company manufactures uses water-based sealer and approximately
50% has a water-based top coat.

      Not all types of wood and wood products respond well to water-based coatings.  When
water is applied to open grain  woods, such as oak and pine, the grain rises leaving a rough
surface and visible marks. The same effect occurs when water is applied to press board or fiber
board. A consideration of the technical difficulties involved in using water on all surfaces has
made the company decide to intensify marketing efforts for their own line of furniture, which is
produced with 100% water-based coatings, and gradually phase out some of their other
customers.  In the meantime, the company has no intention of stipulating to its customers that
only water-based coatings will be used. This type of drastic announcement would cost the
company a  large share of its business.
                                                                                     H17

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Resource Constraints

State Respondents

       CT and NH agency staffboth said that capital, cash, lack of awareness of regulatory
requirements, and lack of time all prevented companies from implementing pollution prevention
projects.

Industry Respondents

       Capital, time, money, expertise, and awareness were all reported as obstacles to the
implementation of pollution prevention projects. A NH plater (6) lacked access to capital to
"close loop" his shop, and lacked the time to implement pollution prevention projects and to
make himself aware of and gain expertise in environmental regulatory issues.  This changed with
the arrival of the state-funded intern. He also lacked the cash to eliminate chromate plating to
avoid the new testing requirements that go into affect in 1996.

       A VT furniture company (1) referred to a need for more technical assistance regarding
the use of water-based coatings. The facility performs its own research and development, which
is time consuming and costly. The research and development to minimize bumps and rough
spots on the wood diverts employee time and energy from making products.  When asked what
EPA could do to assist them in doing even more pollution prevention, the interviewee spoke in
favor of more specific technical assistance. He said that his efforts could be improved if a
knowledgeable person came to his facility, spent time observing and learning from the
employees, and then set about to test the solutions on different types of wooden furniture. This
type of technical assistance would save time and money that could otherwise be used to produce
saleable products. The contact also noted that coatings manufacturers ultimately use their
customers as a test lab. Even though the coatings producers do some testing on their own, lab
testing cannot simulate the specific needs of each customer's finishing line or product quality
demands.

       A MA plater (4) also did not have the time to implement recommended pollution
prevention projects at his facility, despite the fact that the work would pay itself back in a matter
of weeks. The general manager had been too busy handling other operational issues at the
facility. The manager is concerned about the potential to lose  production time. Similarly, the
plant engineer at the ME woodworking facility was unable to make time to participate in the
33/50 program.

        The compliance manager at a CT metals company (8) felt that one reason the company
was able to make so much progress in pollution prevention was that she had the luxury of time to
assess their operations. The interviewee felt that many small companies lacked the time and
expertise to learn about environmental regulations, evaluate and implement pollution prevention
 HIS

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options.  But she also expressed amazement at the progress some companies with few resources
make and is amazed at how little progress some resource-rich companies seem to make.
                                                                                H19

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      APPENDIX I
POLLUTION PREVENTION
 MOTIVATORS MATRIX

         FOR

 INDUSTRIAL FACILITIES
          ii

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           POLLUTION PREVENTION MOTIVATORS MATRIX
                       FOR INDUSTRIAL FACILITIES
       The "Pollution Prevention Motivators Matrix" is a compilation of raw data designed to
give the user a more complete picture of all the reported factors that motivated a facility to
prevent pollution.  The coded raw data corresponds to a respondent's answers to either the in-
person (facilities 4 - 9) or telephone survey (facilities 10 - 42). Coded raw data from facilities 1 -
3 are not included in this report.

       The top of each table lists information relating to the facility (refer to Appendix E for
more complete facility descriptions) and the question posed to the correspondent. Each question
number refers to answers respondents gave to the following:

       Question 1:   What led you to begin investigating pollution prevention at your facility?

       Question 2:   How did you learn about the pollution prevention options that were
                    available to your facility?

       Question 3:   What made you decide whether or not to implement pollution prevention
                    at your facility?

       Question 4:   Is there anything EPA could do to promote the implementation of
                    pollution prevention at your facility?

       The left side of each table lists all the factors reported as motivating firms to prevent
pollution.  All answers provided in response to each question are listed in code form. Refer to
the following "Code For Matrices" for a description of each answer code.
                                          12

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                              COPE FOR MATRICES
33/50 33/50 Program
F     Factor
M    General Motivator
O     Obstacle
O     Obstacle Overcome
S     State
X     Change Needed
AD   Advertisement
FS    Fire Safety
MA   Materials Accounting
MR   Mandatory Reduction
M2   Multimedia Rules
OS   On-site Visit
P2    Emphasize Pollution Prevention
RC   Responsible Care
TO   Trade Organization
WT   Waste Treatment
Air   Air
AWD Awards
AWR Awareness
CAP  Capital
CHA Pollution Prevention Champion
CON Consultant
CRP  Internal Corporate Assistance
ENF  Enforcement
ENV Care About
Environment/Community
EPA  EPA
EXL  Environmental Excellence
GEP  Good Environmental
Practices/Company Policy
GRA Grant
GRN Green Lights
H20   Water
HOT Telephone Hotline
IND   Industry Program/Contact
INS   Mandatory Inspection
ISO   International Standard Organization
JOU  Journal/Trade Article
LAB  Labor
LIA   Liability
LIT   Written Literature
MRK Pollution Prevention Used as a
      Marketing Advantage
OSH  OSHA Rules
PER  Permitting
PRV  Privately Owned
PUB  Publicly Owned
RCR  Hazardous Waste
SEM  Seminar/Course
SEP  Supplemental Environmental Project
STF  Dedicated Environmental Staff
SUG  Employee Suggestions
SUP  Supplier
TCA  Total Cost Accounting
TEM  Dedicated P2 Teams
TIM  Time
TQM  Total Quality Management
TRI  Toxics Release Inventory Reporting
UNY  University
UTL  Utility
WOR Care About Workforce
                                        13

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