'- i 3
United States
Environmental Protection
Policy, Planning,
And Evaluation
June 1994
Sustainable Industry:
Promoting Strategic
Environmental Protection
In The Industrial Sector

Phase 1 Report
Photoimaging Industry
                     IJiJ EPA FffiocJquarters Librai
                     401WSt.,SW  (3404)
                     Washington, DC 20460
                                   Printed on Recycled Paper


                      UJ5* Environmental Protection Agency

                     Pollution Prevention and Toxics Branch
                     Office of Policy, Planning and Evaluation
                            401 M Street, SW (2125)
                            Washington, D.C 20460
                        (202-260-8661 • Fax 202-260-0174)
Robert S. Benson

James E. Casey

Julie B. Frieder

Jerry L. Newsome

Lucille Preston
Chief, Pollution Prevention and Toxics Branch
                   Overall Project Manager
       Metal Finishing Industry Team Leader

           Thermoset Plastics Industry Team
                Administrative Coordinator

        Photoimaging Industry Team Leader

    Thermoset Plastics Industry Team Leader

                   Administrative Assistant
       Hie EPA Project Team gratefully acknowledges the valuable contributions
                  of tne following non-EPA project team members:
James Cummings-Saxton

Mary E. Compton

Nancy H. Hammett

David H. Haury

Margaret CH. Kelly

Fan-on W. Levy

Patrick B. Marshall

Andrew M. Schwarz

Stuart W. Staley
                 Non-EPA Project Manager
           Thermoset Plastics Industry Team

               Photoimaging Industry Team

                    General Issues Analysis
               Photoimaging Industry Team

             Metal Finishing Industry Team

           Thennoset Plastics Industry Team

                         Research Analyst

                         Research Analyst

             Metal Finishing Industry Team



                            TABLE OF CONTENTS

      1.1     Historical Context	  1-1
      12     Project Goal	  1-3
      13     Report Organization	  1-4


      2.1     Introduction 	  2-1
      2.2     Initial Research on Industry Decision-making  	  2-1
      2.3     Taking an Industry-Specific Approach	  2-4
      2.4     Using a Backward  Mapping Analytical Method	  2-5
      2.5     Selecting Three Industries for Study  	  2-6
      2.6     Identifying Drivers, Barriers, and Policy Options 	2-10
      2.7     Building Peer Review and Stakeholder Networks	2-11
      2.8     Next Steps  	2-12


      3.1     Introduction 	  3-1
      3.2     Approach to Analysis  	  3-1
      3.2.1   Scope	  3-1
      3.2.2   Overview of Industry	  3-3
      3.23   Information Gathering and Panel Meetings	  3-4
      33     Major Findings	  3-7
      33.1   Industry Characteristics	  3-7
      33.2   Drivers and Barriers	3-18
      333   Possible Policy Options	3-29

      Chapter Appendices:

      3.A     Bibliography	3-A-l
      3.B     All Suggested Policy Options	3-B-l
      3.C     Contacts To Date	3-C-l



      EPA's traditional programs have  focused on end-of-pipe  pollution  controls
implemented largely through command-and-control regulations.  These programs were
effective in addressing many industrial sector pollution problems of the 1970's and 1980*5.
However, these approaches may not work as well in the 1990's and beyond, as environ-
mental problems become difficult to identify and prioritize and environmental priorities shift
toward pollution prevention and waste minimization.

      In addition, current and future pollution problems will have to be addressed within
an economic climate that demands cost-effective policies and business practices, a focus on
sustainable growth, and long-term  technological development

      Given the environmental and economic challenges of the 1990's, the Agency believes
it is increasingly important to achieve broad private sector commitment and investment in
strategic, economically-based approaches to environmental management - approaches that
will  move  individual  firms  beyond baseline  compliance.   For these firms,  strategic
environmental management will  require the  permanent integration of environmental
management functions into the basic, profit-oriented activities of the organization.

      Firms taking this approach  will seek cost-effective pollution prevention and waste
minimization opportunities as part of their overall commitment to develop innovative new
products, improve product and process quality, and achieve  economic growth.  For many
firms, this sort of commitment to a more strategic approach to environmental management
represents  a  difficult  adjustment  in corporate  culture, particularly  within the current
economic and regulatory climate.

      In order to effectively promote  industrial culture change of this nature, EPA is
rethinking its traditional approach to regulation  of the industrial sector, with the goal of
harmonizing, to the extent possible, the  Agency's future environmental programs with the
economic goals of society.   EPA's Administrator, Carol Browner, has emphasized this

      President Clinton and Vice  President Gore [want to achieve] real  and
      meaningful environmental protection, and to prove once and for all that such
      protection can exist harmoniously with a growing economy .  .  . . We have
      an opportunity ... to  firmly establish a productive relationship between
      environmental and economic policies.

      At present,  the  strategies  and  policies to  establish  that  linkage  between
environmental and  economic priorities have  not been fully developed.   However,  the
Administrator has  taken  the lead  in promoting innovative  approaches to deal with
environmental issues facing the industrial sector, both within EPA and under the auspices
of the President's Council on Sustainable Development (PCSD).  Administrator Browner
is committed to the development of EPA policies that promote "cleaner, cheaper, smarter"
environmental performance by industrial firms of all  types and sizes.

      The Sustainable Industry Project is one of the Agency's new industrial sector eco-
efficiency initiatives, focusing specifically on  corporate decision-making issues that  are
crucial to long-term sustainable development policies for the industrial sector. In developing
this project, EPA's Office of Policy, Planning and Evaluation (OPPE)  is  seeking to
complement the Agency's traditional emphasis on media-specific regulatory/enforcement
programs and recent emphasis on voluntary programs and technology transfer.

      For example,  pollution  prevention is a  critical component  of  any  strategic
environmental management program,  and thus should be a major component of EPA's
policy agenda for the 1990's. However, the principal focus of pollution prevention programs
at EPA has been  on technical and outreach issues relating  to the implementation of
pollution prevention in the industrial sector.  While such work is of considerable value,
relatively little has been^done to evaluate the economic basis upon which firms may choose
to pursue pollution  prevention options, or to identify and assess incentive  approaches to
promote  cost-effective pollution prevention by industry sub-sectors  or individual firms.
Analysis of these types of issues is crucial to the development of effective  environmental
policies and programs for the industrial sector.

      OPPE initiated the Sustainable Industry Project with the intent of establishing a
strong information and analytic base on which to build an  industrial sector  environmental
program  for the 1990's.   In order to accomplish the widespread adoption of strategic
environmental protection throughout U.S. industry, companies will have to permanently
integrate environmental management functions into the basic, profit-oriented activities of
their organizations.  These innovative new approaches will be embodied in industrial sector
policies and programs that recognize the need for U.S. industry to remain competitive, while
also fostering a move toward sustainable production strategies through  continual and
systematic improvements in environmental performance.


      The primary goal of the Sustainable Industry Project is to develop, test, and
      implement industry-specific policy recommendations that will remove barriers to
      innovation and promote strategic environmental protection in the selected
      industries.  The recommended policies and programs should promote a culture
      change throughout the industrial sector, among firms of all types and sizes, in the
      form  of long-term corporate commitment to achieve cleaner,  cheaper, and
      smarter environmental performance. The Agency's sustainable industry policies
      and programs should be achieved with a reduced reliance by EPA on command
      and control regulations.  The recommended policies and programs should be
      widely implementable and acceptable to all  relevant stakeholders (e.g., EPA,
      states, industry, and NGOs).

      This goal statement is in keeping with the Clinton Administration's commitment to
the concept of sustainable  development,  which  has been defined by  the  Bnintland
Commission and the PCSD as "meeting the needs of the present without compromising the
ability of future generations to meet their own needs."  In the  context of wealthy nations,
sustainable  development involves  "maintaining economic  growth while  producing the
absolute minimum of new pollution, repairing the environmental damages of the past, using
far  fewer non-renewable resources,  producing  much less waste,  and  extending the
opportunity  to live in  a pleasant  and healthy environment to the  whole population".
Achieving sustainable development in developed economies requires promoting  "eco-
efficiency" - becoming more efficient, using  less energy and material, producing less waste
and pollution, and destroying less  natural habitat per unit of economic growth  - in all
economic sectors, including industry.

      Achieving eco-efficiency in U.S. industry will require companies to build strategic
environmental  protection into their  business decisions.   By strategic  environmental
protection we mean long-term planning and investment by companies to develop the  most
cost-effective and innovative environmental management approaches, starting with pollution
prevention.  We want to encourage and enable companies to link those approaches to
ongoing efforts to improve product quality, process efficiency, financial performance, and
overall competitiveness.  Over the long term, we seek to enhance their environmental and
economic performance and reduce  unnecessary conflicts between these two priorities.  In
so doing, we will demonstrate how sustainable economic growth can be compatible with
innovative environmental protection in the industrial sector.
      President's Council on Sustainable Development, Task Force on Principles, Goals
and Definitions, Discussion Paper (final draft), October 1, 1993, p. 2.

   2 Mi-, p. 3.

   3 Ibid., pp. 2-3.



      This version of the report focuses on the photoimaging industry, one of the three
industries studied during the first phase of the Sustainable Industry Project. The remainder
of this report is organized in two chapters. Chapter 2 presents the methodology employed
in the first phase of the study.   Chapter 3  presents the first phase  results  for the
photoimaging industry; it describes the approach used in the initial analysis of that industry,
and the major findings  with regard to industry characteristics, key drivers and barriers
affecting environmental performance, and possible policy options  for EPA to  explore


       Chapter 2 provides an in-depth discussion of the methodology and approach.  The chapter
covers issues that are general to the entire study.  Information on the methodology used that is
specific to the three selected industries is provided in the chapters that follow.

       A key early task in the project was to gather economic and environmental data on the full
range of manufacturing industries, as a basis for selecting three industries for detailed study.  This
in turn required that we first identify characteristics of industries that we thought would be relevant
to factors that drive environmental performance.  Once we had  selected the three industries for
initial study,  this framework was also important in guiding our industry-specific research and the
topics we addressed in interviews with industry contacts.

       We conducted an initial literature search to review what other studies had said about factors
that influence environmental performance. This literature review used a broad brush, including all
factors (economic, cultural, regulatory, and other) that might drive environmental practices. While
there is a large  and growing literature on this topic, there does not yet exist a predictive model of
firms' environmental decision-making that is in any sense rigorous or quantifiable. In part, this is
because of two  factors:

       o      It is difficult to develop quantifiable decision-making models that provide
             valid comparisons across firms and facilities.4
    4  OPPE and other EPA  offices  have been conducting research into ways of measuring
environmental performance, that may yield more quantifiable measures in the future.  See, for
example, Industrial Economics, Inc., Pollution Prevention Frontiers fPPFl and Other Approaches
to Pollution Prevention Assessment:  Comparison Based on ftfew Jersey Materials Accounting Data.
prepared for the U.S. EPA, Office of Policy, Planning and Evaluation, Pollution Prevention and
Toxics Branch, June 1994.


               Many of the factors that are believed to influence environmental decision-
               making are "fuzzy" and not readily measured ~ such as various  aspects of
               firm culture and internal structure.
        In  addition, much of the information on sustainable performance in industry  and on
 industrial  environmental  performance is anecdotal  in  nature and incomplete.  The literature
 describes exemplary practices and programs, but does not provide clear evidence on why some firms
 are taking these proactive measures and others in the same industry are not.

        While we did not  find an explicit model of industrial environmental decision-making, we
 were able to compile a list of variables influencing firms' environmental  decisions. Exhibit 2-1 lists
 the factors we identified from the literature and that we used as a checklist of characteristics for

        Business decisions of industry are often analyzed using a profit-maximization model. While
 many factors influence business decisions, it is useful  as a starting point to assume that businesses
 will act in ways that maximize profits (by reducing costs and/or increasing revenues) and will choose
 their least-cost option, other things being equal. Of course, other things are not always equal, and
 different businesses choose different business strategies in  the same markets.5

        For example, one firm may take a high-quality strategy to product design or customer service
 that results in both higher revenues and higher costs than another competitor that chooses a low-cost
 approach to allow competing on price.  Any market may offer room for different competitive
 strategies.  However, assuming initially that businesses will act to minimise costs provides a useful
 first approximation of industry responses to policies that affect costs.  A major task in analyzing
 industry responses is therefore to understand how environmental policies affect their costs, revenues,
 and profits.

        More broadly, a number of factors affect industry  environmental  and economic decision-
 making. These factors include federal and state regulation, changes in production technologies, and
 foreign competition. Industry structure (e.g., is the industry highly-competitive or characterized by
 concentrated market power?) may reflect barriers to entry such as patent ownership, economies of
 scale, and  substantial customer  brand loyalty.  These characteristics  are relevant to predicting
 environmental performance, both because  they  affect  the  resources  available to  invest in
 environmental improvements (profits) and the ability to recover the costs of environmental
 improvements from customers.

       Other factors that are likely to affect both environmental and economic performance include
 the nature  and capital intensity of production technologies, the size of firms, die availability of in-
 house technical expertise, the baseline rate of innovation in products and production processes, the
availability of substitutes for manufacturing inputs, and the price sensitivity of demand  for the
industry's products. Identifying a list of factors that might influence environmental decision-making
was only a preliminary step in our analysis, providing some overarching information to support our
 industry-specific analysis.
    5 Michael Porter's work provides a framework for understanding the strategies of different firms
as the matching of firm competencies to the demands of the target market See Michael E. Porter,
Competitive Strategy: Techniques for Analyzing Industries and Competitors. 1980, and Competitive
Advantage:  Creating and Sustaining Superior Performance. 1985.


                        Exhibit 2-1
       1.     Social Variables

              Employee Recruitment
              Employment Morale
              Media Treatment
              Corporate Reputation
              Community Relations
              Plant Siting

       2.     Market Variables

              Growth Markets
              Product Image
              Customer Loyalty
              Product Certification
              Competitive Advantage
              Industry Standards

       3.     Financial  Variables

              Liability Exposure
              Insurance Coverage
              Damage Compensation
              Credit Quality
              Capital Access
              Investor Relations

       4.     Regulatory Variables

              Government Relations
              Raw Materials Costs
              Operating Costs
              Litigation Costs
              International Competitiveness
Source: National Wildlife Federation Corporate Conservation
       Council "SYNERGY '92" Conference, January, 1992.


       As stated previously,  the overall goal of the Sustainable Industry Project is to develop
 policies that foster the permanent integration of environmental protection functions into the basic
 profit-oriented activities of industrial firms. To accomplish this goal, EPA needs to understand the
 factors that motivate or impede a firm's behavior with respect to investment in projects that result
 in improved environmental performance. We believe that the best way to understand these factors
 is to study the behavior of firms within the context of the industry of which they are a part.

       EPA's traditional one-size-fits-all  approach to policy-making, often  dictated by statute,
 establishes requirements and programs that are applicable to many industries.  This approach does
 not take into account differences among industries, such as available resources, prevailing corporate
 culture, market trends, and corporate decision-making factors in different industries. A one-size-fits-
 all approach for the industrial sector therefore may  result in programs that effectively achieve
 environmental goals in some industries, but fail to do so (or even impose  barriers to effective
 environmental performance) in others.

       On the other hand, an industry-specific approach to policy-making offers opportunities to
 design policies that fit the particular characteristics of the industry of interest An understanding
 can be gained of industry-specific decision factors and behavior that can then be used to identify
 incentive (driver) factors or barriers to improved environmental performance.   Since operating
 environments and processes vary a great deal across the industrial sector as a whole, policies that
 are tailored to unique  characteristics of specific  industries  are likely  to be more effective in
 promoting cleaner, cheaper,  smarter environmental  performance  by individual firms in those

       Additional factors support an industry-specific approach.  Although a wide range of firm
 sizes, types and  scales of production processes, and levels of  technical  and  environmental
 sophistication  may coexist within an industry,  the  participating  firms frequently  face  similar
 environmental issues with respect to types of emissions. Development and implementation of EPA
 policy options at an industry level  is thereby simplified because  attention  can be focused on
 promoting improved environmental  performance through  management of a limited number of

       Firms within industries classified at the 4-digit SIC level generally utilize similar technologies
 and production processes, purchase raw materials from the same types of suppliers, and compete
with each other in many of the same markets on the basis of product design and performance, price,
 quality, and service. These upstream and  downstream  relationships can be  very important with
respect to environmental decision-making within an industry.

       Because a relatively limited number of markets are served by a given industry, competitive
 imbalances that may be caused by a specific policy option can be more accurately assessed prior to
implementation of the policy because EPA can more  easily understand the competitive dynamic
occurring among the various firms within an industry than it can assess the effects of controlling a
specific pollutant across many industries. The Agency can use this knowledge of the competitive
dynamic of an industry to identify points within the industry's structure and culture where policies
can have the broadest, long-term impact.

       While it has many advantages, an industry-based approach is not the only method that can
be used to assess policy options. Historically, EPA's efforts to address environmental problems have
employed geographic, industry, and/or chemical-based approaches. While all three approaches have
their place, the industry-based approach has received less attention in recent years. The Sustainable
Industry  Project is founded on the  premise  that the increased tension between  economic  and
environmental objectives in recent years  demands a more sophisticated understanding  of the
interrelationship between these objectives,  and that this understanding can be best achieved via an
industry focus.

       "Backward mapping" is an approach to policy implementation described by Richard Elmore.6
He distinguishes two approaches to implementation analysis:

       o      "Forward-mapping"  begins  by defining a  policy objective,  elaborates
              increasingly specific steps for achieving that objective (starting with the top
              of the implementation hierarchy and working down), and identifies outcomes
              by which success or failure will be measured.   It relies on the implicit
              assumption that policymakers can control the organizational, political, and
              technological processes that determine outcomes.

       o      "Backward-mapping" begins  not with a statement  of policy objectives, but
              with a description of the behaviors that the policy seeks to influence. Only
              when  the behavior creating  the need for a policy is fully understood is a
              policy objective defined and desired outcomes  identified.  The  policy is
              developed by working backward from the most directly involved parties, and
              asking at each  level of the system what would encourage a desired change in
              behavior. This analysis focuses on what incentives and resources each stage
              would need" to make the desired changes.
       As applied to environmental policy, a forward-mapping approach would yield hierarchical,
"command-and-control" policy solutions, with a distrust of discretion at lower levels in the system
and an emphasis on compliance with inflexible standards.  A backward-mapping approach seeks to
capitalize on knowledge and skill at the point of impact to achieve environmental policy objectives,
by creating incentives or removing barriers to the desired behavior.  In Elmore's words, backward
mapping emphasizes "that  it is not the policy of the policymaker  that solves the problem, but
someone with immediate proximity.... Rather than reasoning from top to bottom, trying to discover
how each layer can  control the next, one begins at the point of the  problem and tries to find the
most parsimonious way of reaching it."7
   6 Richard F. Elmore, "Backward Mapping:  Implementation Research and Policy Decisions,"
Political Science Quarterly. Vol. 94, No. 4, Winter 1979-80, pp. 601 ff.
   7 Ibid., p. 612.

       Based on the backward mapping approach, the sustainable industry project emphasizes
 understanding the factors that influence the behavior of different players in each industry, before
 recommending any  policy prescriptions.   We use the concepts of "drivers"  and  "barriers" to
 distinguish factors that encourage or hinder, respectively, improved environmental performance in
 industry.  Drivers and barriers include any variables that influence decision-making with respect to
 environmental performance.  For example, if a firm has to undertake an investment in pollution
 controls to comply with a specific regulation, then the regulation acts as a driver of environmental
 improvements.  If the firm is contemplating an environmental investment but  cannot obtain the
 necessary financing, then financial constraints act as a barrier to environmental  improvements.

       Understanding the factors that influence environmental performance provides the basis for
 designing policies to encourage improved performance.  Starting with a thorough understanding of
 the factors that influence the key  industrial actors gives EPA the  opportunity to align  policy
 objectives with their business objectives. With this insight into the dynamics of the industry, EPA
 has the opportunity to use a broader and potentially more effective set of policy  levers, rather than
 being limited to traditional command-and-control options.


       Our intended scope for this project was to work with a set of two to four industries.  We
 started with a preliminary list of about ten industries, identified by 4-digit Standard Industrial
 Gassification (SIC).  We collected  economic, environmental, regulatory, and other data on the
 original list of industries, and selected three for the first  phase  of  this project:  photographic
 manufacturing and processing (photoimaging), metal  finishing, and  plastics  and  resins.   (We
 subsequently focused on the thermosets subset of the plastics industry.) The types of data and the
 selection criteria are summarized below. A more extensive discussion of the "candidate" industries
 is provided in the Appendix of this report.

       We conducted the industry selection process using Standard Industrial Classifications (SICs),
because most data sources that provide comparable data across industries report data aggregated
by SIC.*  The following measures of economic and financial characteristics were collected for all
 manufacturing SICs:
    *   SICs are two- and four-digit codes that group similar establishments by industry.  An
establishment is a single location: a manufacturing facility, a headquarters location, a retail outlet,
and the like. Most establishments in the manufacturing SICs (SIC 20 through 39) are manufacturing
facilities. The basis for defining SICs varies, and the categories are often not ideally defined for the
purposes of a particular analysis. Some SICs combine industry subscctors that have very different
characteristics, and in other cases a single "industry" (as defined by the markets served or the type
of processes used) includes several SICs.  In addition, establishments report data based on their
primary product, but may produce products associated with other SICs as well.  Therefore, some of
the products or services which define the primary SIC may be produced as secondary products by
establishments in other SICs.  While the SICs provide a useful standardized reporting system for
data, it is important to realize that there may be a discrepancy between an "industry" and the most
closely related SIC.


       o      Number of establishments;

       o      Size distribution of establishments;

       o      Production characteristics (capital versus labor intensive);

       o      Market concentration (based on share of value of shipments);

       o      Geographical concentration; and

       o      Economic performance (using capital utilization  as a proxy).9
       We also collected data on various environmental outcomes as a measure of environmental
performance.  The available data give only a general picture of the environmental characteristics of
an industry, however, and do not reveal the extent to which industry participants have taken full
advantage of all existing methods for improving performance - that is, how many industry players
are operating with state-of-the-art production processes and pollution controls. We used two sources
of environmental data in the industry selection process: Toxics Release Inventory (TRI) releases
and transfers of toxic chemicals (total and by media), and energy consumption (a proxy for emissions
from fuel combustion and potential for energy efficiency improvements).

       Finally, we investigated the current regulatory status of the candidate industries.  For each
industry, we considered the size  of  current  and  historical pollution  abatement  and  control
expenditures, and the extent of current and future EPA regulation (particularly under the Clean Air
Act, the  Clean Water Act, and the Resource Conservation and Recovery Act).

       The selection of the industry sectors for detailed investigation in the first phase of the
Sustainable Industry Project was guided by the following criteria:

       o     We wanted to select industry sectors that present significant opportunities for
              EPA to encourage movement toward sustainable practices.  This criterion
              suggested  that  we  pick   industries  with substantial   releases  to  the
              environment, as reported in the Toxics Releases Inventory.

       o     In addition, we wanted to  select industries that might benefit from use of
              innovative policy approaches that go beyond the traditional command-and-
              control  paradigm.  This goal  encouraged selection of industries (1) with
              multi-media rather than single-medium releases, (2) with significant historical
              expenditures on pollution abatement and control, and (3)  facing significant
              current  and  future regulatory requirements.
    9 Later research on the three selected industries also included other important economic
variables, such as extent of foreign competition, growth rates, and financial characteristics.


       o      Similarly, we were interested in picking industries that would particularly
              benefit from  an  industry-wide,  life-cycle focus.   Therefore, we picked
              industries that appeared to present life-cycle issues, and to present interesting
              relationships among suppliers, manufacturers, downstream businesses, and

       o      We also wanted to select a set of industries that appeared to have different
              characteristics from one another, so that we could learn as much as possible
              about  the applicability of our analytical approach to different  types of
              industries. A more diverse set of industries, in terms of company size, scope
              of environmental issues, and market and product trends will provide us with
              a broader range of experience as we seek to implement the policy options
              developed through this project.

       o      Finally, we wanted the results of the sector studies to provide insights into
              influences on environmental performance and the effects of different policy
              strategies for  other industries as well.  This goal of generalizing results
              required that we pick industries that presented common rather than unique
              environmental issues, and that we pick a set of industries that together would
              cover a range of economic and environmental characteristics.

       The selection of three industries for detailed study was necessarily judgmental.   Other
industry sectors could easily have been chosen, applying the same decision criteria.  Exhibit 2-2
summarizes some of the key data for the three selected industries.

       As a group, these three industries provide us with a variety of economic characteristics which
we expect to influence environmental performance, including establishment size, difference in capital
versus labor intensive production, and more and less concentrated markets. All present multi-media
pollution  problems,  when viewed from a life-cycle perspective, and  are subject to current and
forthcoming regulations at the federal level.

       As for the desired diversity of characteristics, the three selected industries clearly  reflect
different types of companies and issues.  The metal finishing industry includes a  large number of
relatively small operations, often with limited resources and a large set of regulatory requirements
with which to comply. The photoimaging industry is highly concentrated on the manufacturing side
and  widely diffuse  on  the  processor side, with fewer  environmental  issues but  significant
opportunities for cleaner, cheaper, smarter initiatives nonetheless - particularly in view of the highly
technical, innovative  nature  of the industry. The plastics and  resins industry  was selected to
represent a typical huge, widely diverse industry, with many different types of companies, products,
and issues.  Even with the subsequent change in focus to the thermoset plastics  subsector, these
characteristics remain valid.

       As discussed in the industry-specific chapters, further work led us to refine our focus in each
of the three sector studies; we narrowed the scope of our analysis enough to allow us to understand
technical, economic,  management, and environmental issues in detail, and to  identify the key
leverage points for each industry.  Despite these adjustments in focus, the desired variety in issues
and industry characteristics has been retained from the initial selection process.


                                       Exhibit 2-2


1 Total Number of
Number of Establishments by
Employee Size Category:*
1-19 employees
20-249 employees
250+ employees
Concentration Ratios - Share of Value
of Shipments by:*
4 largest companies
8 largest companies
20 largest companies
Ratio of Capital to Labor
Capacity Utilization Rate (1990)***
TRI Releases (1990):
I A*
L Water & POTWs
W Land & Underground
| Offsite Transfers
Pollution Abatement and Control
Expenditures (&. "~
percent of total expenditures)**,"***
Purchased Fuels and Electricity as
Percent of Total Expenditures***
Future Federal Rule-Makings
Equipment A
(SIC 3861)
508 (65%)
242 (31%)
37 (4%)
$157 mill
& Polishing
(SIC 3471)
2,408 (70%)
1,032 (30%)
S236 mill
for surface
Plastics Materials
& Resins
(SIC 2821)
160 (33%)
266 (55%)
54 (11%)
$929 mill
CA: MACT for
individual plastics
& resins
RCRA: solid
waste legislation
affecting end-uses
of plastics
CA: Effluent
P_~~..._U... /CTI"1
mrf-vting (MC
522,000 (>90%)
58,000 (< 10%)
$45 mill
CWA: Effluent
RCRA: Silver
* 1987 Census of Manufactures
** 1991 Annual Survey of Manufactures
*** Current Tndiittris! Renorts_ Survev rsf Plant r!anac»tv 1990
Total expenditures includes capital equipment, labor and materials.
Values for this industry were obtained from the National Association of Photographic Manufacturers
(personal communications) and The Silver Coalition (An Economic Assessment of the Impact Resulting
from Silver Pretreatment Standards. June 26, 1992).


       Once the three industry sectors were selected, our goal was to gather extensive information
 on each industry, including corporate  decision-making factors in the industries, in order to create
 the knowledge base necessary to support policy recommendations that would meet the goal of the
 project. A team of OPPE and  contractor staff from Industrial Economics, Inc. (lEc) was formed
 for each of the industries. The  Phase  1 work for each industry followed the same major steps, but
 each industry  study differed somewhat in the topics emphasized and the results achieved to date.

       The first step of the data-gathering process was to develop a thorough understanding of the
 relevant characteristics of the industries - the industry-specific economic, institutional, cultural,
 technical,  life-cycle,  and regulatory  factors - that may  promote  or  hinder environmental
 improvements. A key aspect of this characterization of the selected industries was the identification
 of the driver  factors  and barriers that influence corporate  decision-making and environmental
 performance.  The drivers and barriers represent the key leverage points for the industries - the
 regulatory, informational, economic, or other factors - that provide the greatest incentives or impose
 the most significant obstacles to improved environmental performance.  Our emphasis here was on
 the identification and prioritization of corporate decision factors, rather than on EPA's traditional
 role of assessing and managing  environmental risks. The driver factors and barriers provided the
 basis for subsequent policy development.

       The next crucial step in the analytical approach of this project was the development of a
 menu of policy options and recommendations that we would anticipate having the greatest long-term
 impact on the  selected industries in terms of achieving the overall goal of the project - to promote
 strategic environmental protection in the industries. The identification of these policy options is
 based on our knowledge of the  industries, their characteristics, unique driver factors, and barriers
 to innovation.  The recommended actions are both regulatory and non-regulatory in nature.10  The
 actions may be taken by EPA headquarters or regions, states and localities, the industries themselves
 or their suppliers or customers,  or other entities.11  Some actions might require statutory changes,
while many are  achievable within existing statutory mandates.12  Our approach was Jo link the
    10 The description of policy options as regulatory or non-regulatory is somewhat arbitrary, and
the line between the two categories is blurred. Strict use of the term "non-regulatory" would include
only those options that rely solely  on incentives to influence behavior, without any mandatory
provisions. In practice, a very wide range of incentives, quasi-regulatory, and regulatory policies are
typically discussed in studies of "non-regulatory" options. For example, deposit-refund systems used
to encourage the return of materials to a central location include both incentives (for the ultimate
customer to return the materials) and regulations (requiring intermediaries to accept the materials
and return them to a central location).  Similarly, marketable rights are typically used within the
context of a regulatory program, e.g., trading of rights to emit criteria air pollutants in a given area,
subject to a regulatory maximum on total emissions or minimum standard for ambient air quality.
In this case, the creation of markets promotes compliance with the regulatory standard at the lowest
aggregate cost to the regulated facilities.

    11 In ail cases, we will identify steps that EPA could take to promote adoption of the best
policies, even if EPA would not be the lead agency  implementing the policy.

    12 However, when evaluating potential difficulties in implementing the options, we will clearly
distinguish options requiring statutory changes from those that do not.


policy options to the key leverage factors for the industries, so as to promote cleaner, cheaper,
smarter environmental outcomes over the long-term future, preferably with less Agency involvement
over time.

       An important aspect of our policy development process was to look at each industry and at
policy options with a broad, holistic perspective. Often, policy strategies are considered only in the
context of a single  rulemaking.   Many regulatory  decisions are highly constrained by  specific
legislative mandates and by the precedents set by earlier rulemakings.  This narrow focus may miss
opportunities to take positive, non-regulatory actions or to coordinate and rationalize regulations
and enforcement across programs.  Also, the general applicability of regulations to many industries
may fail to reflect unique factors that affect environmental performance in specific industrial sectors
or sub-sectors.

       By contrast,  the  approach used in the Sustainable Industry Project involves  looking at
environmental  issues in  a comprehensive  life-cycle context,  considering all  the environmental
dimensions of industrial products and processes (all media and all important end-points) and  a full
range of policy options.  The broad perspective is necessary to ensure that policies promote true
movement toward sustainability, not just shifting of problems from one medium, source or type of
adverse outcome to another.
       Our initial outreach efforts for this project focused on peer review of our overall concepts,
goal, and intended  approach.  Since early 1993, we have discussed the project with close to 100
individuals in EPA and other federal departments  and agencies, industry, state governments,
acadcmia, the media, and other non-governmental organizations (NGOs). We have actively solicited
suggestions for improving our methodology, and have attempted to be responsive to all comments
about the project as a whole. This peer review effort will continue throughout the life of the project.
       As we moved into the data-gathering phase of the project in mid-1993, we began the
essential process of developing stakeholder networks for each of the three selected industries.  In
view of our intent to focus first on characteristics of the three industries, we made a significant effort
early in Phase 1 to identify and connect with the key individuals and organizations in each industry,
in order to begin to understand the issues as industry perceives them. These interviews with industry
contacts provided an important initial source of information on drivers and barriers.  These early
rounds  of interviews generated a wider  range  of hypotheses about drivers and  barriers  of
environmental performance, which we were able to test in discussions with an expanding set of
stakeholders in later stages of the Phase 1 work.  Major trade associations for each industry were
important sources of contacts in individual companies.  In addition, we had the help of consultants
with expertise in the particular industries.

       In addition to interviews with trade associations and company contacts, we conducted site
visits to manufacturing facilities to enhance our understanding of the manufacturing technologies
and plant-level environmental issues.  We also conducted a review of the trade literature and the
pollution prevention and control literature for each industry.

       During the course of our research and interviews, we began identifying industry and other
contacts who might participate in an expert panel for each industry.  The first set of expert panel
meetings was held in January, 1994.  The primary purpose of these meetings was to verify our
understanding of the economic and environmental characteristics of each industry, and to determine
the key drivers and barriers affecting performance. The initial expert panel discussions of drivers
and barriers provided a preliminary list of policy options that might enhance incentives or reduce
barriers to more sustainable industry practices.

       After the first round of industry expert panel meetings, we began to expand our stakeholder
networks to include other important, non-industry participants.  These non-industry stakeholders
include members of EPA offices that are responsible for programs of particular significance to the
industries; NGO representatives from environmental organizations and other groups with interest
in the industries (e.g., the Association of Metropolitan Sewage Agencies, representing POTWs); and
representatives of  relevant federal, regional, state, and small business interests.

       A second round of expert panel meetings, involving more diverse groups of participants,
occurred in February  and  March of 1994.  The goals of these  meetings were  to verify our
understanding of key industry characteristics,  drivers, and barriers - this time through a dialogue
with a wider set of stakeholders - and to select key policy areas for focus in Phase 2 of the project
       As with our peer review efforts, the development of industry-specific stakeholder networks
is an ongoing process.  We want all interested viewpoints to be represented in our data-gathering
and analytical processes, to_ ensure the accuracy of our substantive findings, to elicit innovative ideas
to the maximum extent possible, and to enable stakeholders with divergent points of view to engage
in constructive  dialogue. Over the long-term future, these networks will  help  to provide a solid
substantive  basis for our  policy  recommendations and  a  broad  participant base  for future
public/private partnerships to implement those policies.

       This report reflects work completed through the second round of expert panel meetings for
each of the three industries, the last of which occurred on March 15,1994. The remaining chapters
of the report provide in-depth discussions of the three industries that were the subject of this study,
including the top policy options identified for each industry.

       The Sustainable Industry Project remains a work in progress. Each of the industry sectors
will need additional investigation to clarify the issues  that have been raised.  More work is also
needed to continue broadening the stakeholder network, and involve some groups whose views have
not yet been adequately represented.

       During  Phase  2 of  this project we will  further  develop and characterize  potential
implementation projects for each industry that will test the environmental and economic impacts of
the industry-specific policy  options identified in Phase 1.  The implementation projects, which are
the logical next step of our backward mapping analytical approach, will be undertaken in Phase 3.
The projects may include implementation and testing of policies on a pilot basis, cooperative efforts
to develop definitions or  information  needed  to  implement  new  policies,  tests  of innovative
compliance and enforcement approaches, and further research on key scientific or technical issues.
We will use the implementation projects to assess whether the specific policy options effectively
address the key drivers  and barriers that  affect long-term environmental performance in each

       We believe that the following tasks will likely be a part of Phase 2, subject to change as we
continue to be responsive  to new information,  input from stakeholders, and the views of EPA

       o      Holding additional meetings with industry/stakeholder expert panels,  and
              interviews with parties involved in each of the policy areas selected for focus,
              to clarify the issues involved and understand what specific actions would be
              required to implement a new policy to address the issues. The project team
              will continue to contact stakeholders whose views have not yet been fully
              represented in the expert panel discussions and interviews.  In particular,
              more involvement by environmental groups,  state regulators, EPA regional
              representatives, and groups  with practical experience  with  various non-
              regulatory policies will be solicited.

       o      Developing EPA cross-office teams to work with OPPE project managers -
              in particular, to review, assess and revise the findings for each industry and
              to comment on the design of useful implementation projects.  These teams
              will include- regulatory, compliance,  and  permitting representatives whose
              selection will be based on the specific issues and options identified for each

       o      Preparing strategic plans for individual implementation projects, along with
              background  materials on the issues motivating consideration of each project,
              for  review by all major stakeholders, including EPA program  offices and
              senior management.  The plans will define the purpose of the projects and
              success measures by which the results can be evaluated.  Dear definition of
              "success" and concrete ways of determining success will be critical to making
              the project results a valid basis for broader policy decisions.
       We anticipate that the implementation stage of the Sustainable Industry Project will require
broad stakeholder participation, with OPPE playing a coordinating and facilitating role, but not
necessarily a leadership role in every implementation  project  The strategic plans,  participants,
resource requirements, timeframe, and success measures of each project will differ based on the
industry-specific driver factors and barriers that are being addressed.

       Once implementation projects are developed and underway, OPPE will assess environmental
and economic results of policy options, to test whether the anticipated payoffs of the recommended
policies are in fact being achieved. On this basis, we can with greater confidence make broad policy
and programmatic recommendations to the Administrator.


       This chapter discusses the background information  and  preliminaiy findings of  the
Sustainable Industry Project's analysis of the photoimaging industry. This introduction outlines the
contents of this chapter.  The approach to  our analysis, including the scope of the  project, an
industry profile, and our information sources are addressed in Section 3.2. Section 3.3 presents our
findings to date, including:

       (1)    Information on the economic characteristics of the industry;

       (2)    Descriptions of key factors that influence environmental performance in this
              industry (drivers and barriers); and

       (3)    A list of policy options that might enhance the drivers and reduce  the
              barriers to improved, more cost-effective environmental performance byjhe
              photoimagmg industry.


       The photographic supplies  and equipment manufacturing  industry is classified under
Standard Industrial Code (SIC) 3861, which includes the manufacture of:

       o     Equipmcqt: still  and motion  picture camera  and projection  apparatus,
             photocopy and microfilm equipment, blueprinting and diazotype (white
             printing)  apparatus,  photocopy and microfilm  equipment,  and  other
             photographic equipment; and

       o     Supplies:  sensitized film, paper, cloth, and plates, and prepared photographic
             chemicals for use in processing sensitized products.

       During our initial analysis of the photographic manufacturing and processing industry, we
identified a number of characteristics which make the photographic processing segment attractive
for in-depth study, compared to those identified for the photographic manufacturing industry which
appeared far more limiting.  As a result of these factors, outlined below, the EPA/IEc project team
decided in Phase 1 of the project to focus on environmental issues in photoprocessing1, though not
to the exclusion of manufacturing issues. Photographic processing is classified under two SICs: SIC
7384, which comprises all photoprocessing except that of motion picture film; and SIC 7819, which
comprises all support operations involved in the production of motion picture films, including the
photoprocessing step.

       The following  are  specific  factors frequently  identified  by both  manufacturers and
photoprocessors which encouraged us to focus on photoprocessing:

       o      There  was   a   high degree  of  industry  interest  in  photoprocessing
              environmental   issues.    This  interest  reflects  the  difficulty  some
              photoprocessors are having complying with local standards, due to their small
              size, lack of capital, and lack of technical expertise, as well as to the
              increasing stringency of some local standards.

       o      According to manufacturers, much of the impetus for their environmental
              innovation originates with their customers, the photoprocessors, who look for
              ease  of  compliance  with  environmental  regulations,  rapid picture
              development, and minimal waste generation.

       o      Innovative policy approaches may have  especially  high payoffs  in  the
              processing sector, which includes large numbers of small dischargers who are
              difficult to monitor for enforcement purposes.

       o      Given the small number of U.S. supplies manufacturers and the variation in
              their products, a focus on manufacturing might provide policy conclusions
              that were applicable to only one or two facilities.  In contrast, similarities in
              products and processes among the numerous photoprocessors will likely lead
              to policies which are applicable  throughout the sector.

Although we decided to focus on environmental issues in photoprocessing, this focus has required
the participation of both manufacturers and processors as the product and process changes and
much of the training that influence photoprocessors' environmental performance come from the
manufacturers. Furthermore, we intend in Phase 2 of the project to conduct additional research into
the barriers to innovation and drivers to environmental improvements  in the manufacturing sector.
We therefore continue to gather information from the manufacturing  sector regarding sustainable
   1 The terms "photoprocessing," "photofinishing," and "photo developing" are interchangeable.
For consistency, we use the term "photoprocessing" throughout this report


       We recognize that other potentially significant environmental issues have  not yet been
explored, and that we have not yet presented a full life-cycle characterization of environmental issues
in this industry.  There is no doubt, however, that the release of silver and other toxics from
photoprocessing is one of the key environmental issues in this industry. Our initial focus on this
issue has allowed us to develop a concrete understanding of environmental performance drivers and
barriers and to begin considering policy options and specific pilot projects. It will be important in
future work to  keep in  mind  our relative  lack  of knowledge of  environmental  issues  in
manufacturing, and to pursue those issues in later stages of the process.
       Overview of Industry

       The two major segments addressed in the scope of the photoimaging industry — sensitized
goods manufacture  and photoprocessing - consist of very different products and processes and are
structurally dissimilar.  The manufacture of sensitized photographic  goods involves, first,  the
preparation of the base, such as film or plates, for coating with a photographic emulsion.  In the
case of film, the material is generally an acetate-base plastic. Other inputs include plastic and metal
for the film canisters and casing, numerous solvents, and the chemical emulsions. The base is then
coated with an emulsion, usually of silver, to prepare it for capturing the image. The film is then
prepared  for sale by cutting and rolling it onto the film canister.  The  degree  to  which these
activities are performed in-house varies with the manufacturer. Kodak, for instance, manufactures
its own acetate film base and conducts emulsion and assembly in the same plant Fuji and Konka,
on the other hand, purchase the base from outside suppliers.

       Production  capacity of the photographic manufacturing industry  is dominated by large
companies, such as Kodak and Fuji. As mentioned, this industry concentration is one of the reasons
behind our current focus on photoprocessors.  The processing industry, in contrast, consists primarily
of small, independently owned  labs; minilabs within retail  stores; and a few larger wholesale and
mail-order processing labs. Most labs are engaged primarily in the processing of amateur pictures.
Others specialize in the development of professional photography.  Larger labs, such asmail-ordcr
labs and professional labs,lend to be more effective in implementing environmental controls, largely
because capital is  more available and the  employees have more expertise in  the field.  The
processing operations within these labs, however, are similar regardless of size and specialty.

       Processing operations begin with the removal of exposed film from its housing canister. The
processor then puts the film through a variety of chemical baths.   First, a hydroquinone solution
serves as the developer of the image; then, if the film being developed is color film, bleach is used
to remove the remaining silver emulsion not contributing to the image; third, ammonium or sodium
thiosulfate solution  is used to fix the silver image to the film base; and finally, one or more washes
remove any remaining chemicals and unexposed silver. As film is passed through the developer,
bleach, and fix, these solutions  are replenished with new solutions to maintain their effectiveness.
The rate of replenishment is a factor in determining the amount of processing chemicals used. The
majority of silver removed from the film base is in the bleach and the fix. Consequently, these two
developing solutions are commonly passed through a recycling system to recover valuable silver.

       Manufacturers and processors have a close relationship in this industry.   Processors rely
heavily on manufacturers for compliance assistance and innovations to address environmental and
regulatory concerns. Manufacturing is driven in  part by the demands placed upon the processors,
both by regulators  and by  the end  consumer.  The result is an industry which is sensitive to
environmental issues that are the focus of regulation at a more local level.

3.23   IpifffBMtiflB OlMifrerinB lild
       In our efforts to fully understand the photoimaging industry as a system, we researched
numerous areas, including the economic and financial characteristics of the industry, the products
and processes involved, environmental issues, and current and future regulatory issues.  Our first
step was to review published documents for data on the size of the industry, the number of players,
market  growth rates, and end-use sectors.  We also contacted the major  trade associations.
Interviews with the trade associations were extremely helpful in providing initial information on
economic and environmental issues in the industry, and in identifying the names of individuals to
contact in the industry itself.

       We then conducted interviews with a number of industry, government, trade association, and
environmental  group contacts.   We  visited Kodak's  major  manufacturing facility  and two
photoprocessors.  Because most photoprocessors discharge their wastewaters to publicly owned
treatment works (POTWs), we also contacted the Association of Metropolitan Sewerage Agencies
(AMSA) and several POTWs.   The  Veterans' Administration  and the American  Hospital
Association provided information on medical uses of photoprocessing. To investigate issues related
to silver recycling, we contacted  the International Precious Metals Institute (IPMI).  We also
contacted researchers with the U.S. Geological  Survey, the University of Wisconsin, and the
Baltimore Academy of Natural Sciences to discuss the scientific evidence regarding the toxicity, fate,
and  transport  of silver in the  environment    Finally, we contacted representatives  of the
Environmental Defense Fund (EOF) and the Natural Resources Defense Counsel (NRDQ to assess
the environmental community's position  on the issues raised.  Throughout this process, we had the
help of Peter Krause, a consultant with extensive experience in the photographic industry. The list
of sources used and organizations contacted is provided in Exhibit 3.2*1. A more detailed list of
documents consulted is provided  in Appendix 3-A,  and the  individuals interviewed are listed in
Appendix 3-C to this chapter.

Eihibit 3.2-1

Toxics Release

Census of

U.S. Industrial

Trade News

Wotfman Report
on the
TmmmnsT TnfilMtTV



National Association of

Photo Marketing
Anocution International

Silver Coalition

Association for
Information »nd Image

Manufacturers and
Distributors Association

Printing Industries of

Intenutional Precious
Metals Institute



C««lman Ifnrfalr Co.

Polaroid Corp.

Fuji Photo Film USA

Fuji Hunt Photographic Chemicals


3M Company



Agfa Division

Mitsubishi International Corp.

Anitec Image

Advanced Photographic
Nobk's Camera
Eckerd Drug Company
Eckerd Express Photo Center


Qualex, Inc.
Wal-Mart Stores, Inc.

ECS Refining

Handy & Harman

TTj^iiaLj m f%wnnli«lw^ 1 tA

fflHtfg.1 ••••iejii
\Mrmm™ i-Tf •

-Office of Solid
-Office of Water
Officw o/f Pifkliiitiftti
Prevention and Toxics
-Office of Air Quality
-Office of
-Risk Reduction
Eiujntcrinc L*^1
- Region 1
- Region 4


Department of

State Pollution
Pate Alto POTW
Hampton, VA
Sanitation District

US. Geological
Department of
Veterans' Affairs

Ontario Ministry of
the Environment and

f\fmm MLJjaMitJ-LJIIIUl

Defense Fund

Natural Resources
Defense Counsel

Association of
Sewerage Agencies

American Hospital

Academy of
Natural 'jfifiyn

University of


       On January 13,1994, we held the first of two expert panel meetings for this sector study.
This meeting included only industry participants and experts. At this meeting, industry participants
assisted us in identifying the drivers  and barriers to improved  environmental performance in the
industry, and in determining potential arenas for environmental improvements. They also identified
stakeholders in the photoimaging industry that we had not yet contacted.

       The second expert panel meeting was held on February 25,1994. This meeting included
 representatives from various U.S. EPA offices involved with the industry, POTWs, photoprocessors,
 and trade associations.2  The objectives  of this second panel meeting were to confirm our
 characterization of the industry, and to identify policy options with potential to promote improved
 environmental performance. At this meeting, the participants identified four policy areas as high
 priorities for work in Phase 2 of the project.

       The organizations attending the first and second panel meetings are listed in Exhibit 3.2-2;
 each organization's representative is identified in Appendix 3-B.
                                       Exhibit 32-2
                           PANEL MEETING PARTICIPANTS
           Panel Meeting *1
            January 13,1994
        Fujifiim USA
        3M Printing and
        Publishing Division
        Qualex, Inc.
               Panel Meeting *2
               February 25,1994
National Association of Photographic
Photo Marketing Association
The Silver Coalition
Noble's Camera (minilab)
Association of Metropolitan Sewerage Agencies
International Precious Metals Institute
U.S. Department of Veterans' Affairs
US. EPA Office of Water
U.S. EPA Office of Solid Waste
U.S. EPA Office of Enforcement
U.S. EPA Office of Research and Development
       Additional interviews are still required to obtain the views of all key stakeholders.  In
particular, we have had only limited contact with environmental groups, state regulators, and end-
user representatives (especially non-medical). The project team will continue to solicit input from
these and other experts and stakeholders as the project proceeds.
   2 Representatives from two environmental groups were invited to ibis meeting and accepted the
invitation. Neither representative was able to attend, however, due to last minute conflicts.



33.1   Industiy Characteristics

Industry Size and Structure
       Establishments in SIC 3861 produce a wide variety of products, only some of which directly
relate to photoprocessing.  Therefore, SIC-level data provide only an imprecise picture of economic
trends in this industry. Exhibit 33-1 shows the composition of all products classified as SIC 3861
"Photographic Equipment and Supplies":3
Eihi* 33-1
(1987 Census of Manufacture*)
Still cameras (hand-held)
Still picture commercial type
finishing equipment:
processing equipment for
processing equipment for
continuous printing _
all other (incl. developing
machines, print washers &
Other still picture equipment
Photocopying equipment
Number of Companiet with
Shipment! of
Value of SKifHnente
   3 Of the total value of shipments of SIC 3861 products ($153243 million), 98 percent ($15,052.0
million) is produced by establishments whose primary products are classified in SIC 3861. That is,
only a small part of the production of these products is accounted for by establishments primarily
in other industries. Therefore, SIC 3861 captures virtually all of the products of interest, but covets
other products as well.



Eriubit 33-1

I1OB-I !"...•.« *f V «n,«m**n«M^

T» i .1 H H*
Motion picture processing
Other motion picture
Microfilming, blueprinting, and
whiteprintmg equipment
Photographic sensitized film
and plates, silver halide type
(except X-ray):
still picture film
. other film, plates and slides
Sensitized photographic paper
and cloth, silver halide type
Sensitized photographic film,
plates, paper and cloth, other
than silver halide type
Prepared photographic
chemicals* ~"
office copy toner
. other
X-ray film and plates
Other photographic equipment
and supplies
Source: 1967 Census of Manufacti
* Included with value of shipme
Industry representatives maint
1967 Census of Manufacturer!

Number of Companies with
SllMliMtB «f

Value of Shqnnente
ires, Industry Series MC87-I-38B, Table 6a-l.
nts for photocopying equipment.
ain that all SIC 3861 companies have shipments over $100,000; the
lists this total number of companies in a separate table.
Exhibit 33-1 shows that nearly half of the 1987 value of shipments (VOS) in this SIC relate to
photocopying, microfilming, and motion picture equipment unrelated to camera picture-taking and
processing.  Another eight percent of the VOS are cameras  and other non-processing related
equipment and supplies.  Approximately 33 percent or $5,092 million in VOS is related to silver


halide sensitized film, plates and paper, and processing equipment supplies ~ items relevant to our
analysis. Of these, $547.3 million are shipments of processing equipment, and $4,545.2 million are
shipments of supplies (e.g., film and paper).4

       Exhibit 3.3-2 shows the distribution of establishments by their primary product.
Exhibit 33-2
Piimaiy Product Class
Still picture equipment
Photocopying equipment
Motion picture equipment
Microfilming, blueprinting, and
whiteprinting equipment
Sensitized photographic film and
plates, silver halide type
Sensitized photographic paper
and cloth, silver halide type
Sensitized photographic film,
paper, and doth other than silver
halide type _
Prepared photographic chemicals
X-ray film and plates
Total SIC 3861
Number of
Vahie of Shipments
(minion $)
New Capital
(million $)
Source: 1987 Census of Manufactures, Industry Series MC87-I-38B, Table 5a.
(D) — withheld to avoid disclosing individual facility information.
    4 VOS for X-iay film and plates, and silver halide sensitized paper and cloth axe combined with
values from other SICs and cannot be separated; therefore, these figures understate the VOS for
products covered by the scope of this study.

Exhibit 33-2 shows that 21 establishments produce sitver-halide-sensitized film and plates, and
another 3 produce silver-halide-sensitized paper and cloth as primary products. Exhibit 3.3-2 also
shows that the 21 establishments producing silver-halidc film and plates are larger on average than
the establishments producing other products in this SIC, and account for a substantial portion of the
industry's new capital expenditures.

        Manufacturers with significant operations in the United States include:
              O      E***m»" Kodak C'-nrnpany,
              o      Polaroid Corporation,
              o      3M Corporation,
              o      Xerox,
              o      nford (owned by International Paper), and
              o      Anitec Image (also owned by International Paper).

Kodak is by far the largest U.S.  manufacturer.5 Polaroid Corporation is the second largest U.S.
manufacturer, but their primary film product is instant film. Given our focus on photoprocessing
issues, we excluded instant photography from our scope.  Several foreign companies, such as Fuji
and Konica, have established operations in the United States, but conduct the majority of their
production operations abroad. The major foreign manufacturers include Fuji, Agfa (owned by Miles
Incorporated), Konica, and Mitsubishi International Corporation.

       Manufacturers supply processing systems which include both  equipment and supplies to
customers. Photoprocessors do not have to purchase chemical supplies from the same manufacturer
that supplied the processing equipment, but many - especially the smaller minilabs - often do. All
of the  manufacturers have support  systems  to assist the processors with  operations and
environmental  compliance.   Such systems  include instructional  seminars,  facility compliance
evaluations, and compliance kits.
       Cameras and film are sold in a wide variety of retail  establishments, including general
merchandise stores, gas stations, food and drug stores, and specialty camera and photographic supply
stores.6 However, photoprocessing supplies are sold only to the subset of establishments that
perform photoprocessing on-site.  These include commercial photoprocessing labs (wholesale and
retail)  and some camera stores, drug stores, and discount and mass merchandising stores.  In
addition, x-ray processing is done in large numbers of doctors', dentists', and veterinarians' offices
and hospitals.  An estimated total of 500,000 facilities perform some kind of photoprocessing.
   5 For example, the Photo Marketing Association's 1991-1992 Industry Trends Report shows that
Kodak accounts for 71 percent of color paper sales to U.S. amateur processing labs.

   * The  1987 Census of Retail Trade reported 63,723 establishments  as selling photographic
equipment and supplies.  Of these, only 3,791 were specialty camera and photographic supply stores.


       Within commercial photoprocessing, industry sources distinguish between retail minilabs and
larger wholesale, captive, or mail order labs (see Exhibit 3.3-3). The number of minilabs has grown
rapidly over the past decade (from approximately 800 in 1981 to 17,200 in 1991).  In 1991, minilabs
were located in 3,100 camera stores; 7,100 stand-alone minilab outlets; and 2,700 mass-retail stores.
This indicates a significant increase in the number of minilabs in mass-retail stores, which grew from
1,400 in 1989. The number of minilabs in other types of stores declined  slightly over the same
Exhibit 33-3
(Share of Rob Proceoed, 1991)
Retail Channel

Stand-Atone Minilab
Camera Store
Mail Order -
Prooeaed by
Captive, or
MaO Order Labs
Processed by
Retail Minilab
p/ni Si II M nf

       According to industry representatives, the characteristics of large and  small  labs vary
tremendously.  Smaller labs have a limited capital base,  and hence tend to be somewhat less
sophisticated.   Industry points  out  that  there has been a trend toward concentration among
photoprocessing labs over the past several years, largely as a result of restrictive environmental
standards.  They claim that compliance has become prohibitively expensive for small operations to

       The characteristics of the various types of labs are shown in Exhibit 33-4.
Exhibit 33-4
Lab Type
Wholesale Labs (Drug
Stores, Grocery Stores)
Mail Order Labs
Two to Three Times
Higher than Others
Lower than Others
Equal to Minilabs
Praceaong Speed
One Hour
Two to Three Days
One Week
       Photoprocessors vary in size, as follows:

       o      Over 90 percent are small to medium, employ less than ten people, discharge
              less than 10,000 gallons of wastewater per day, and generate less than 100
              gallons of silver-rich solution per week.

       o      About 9 percent are large, discharge 10,000 to 25,000 gallons of wastewater,
              per day and generate 100 to 250 gallons of silver-rich solution per week.

       o      Less than  1  percent are significant industrial users which discharge over
              25,000 gallons of process wastewater per day.  These include most hospitals;
              a few diagnostic clinics, printers, and photoprocessors;  and the major motion
              picture film processors.
       Consumers of Photoproccsong

       The market for photographic services and supplies is divided into three major segments:

       o      Medical applications,
       o      Graphic arts, and
       o      Amateur photography.
Other photoprocessors include labs serving professional photographers, and various government
agencies, such as police departments and the Department of Defense. The product consumed varies
among these segments.
   7 Consumer Reports. November 1993, pp. 711-715.


       Medical users include large hospitals and diagnostic clinics, as well as doctors' offices and
veterinarians.  The largest single user in the medical market is the Veterans' Administration.  The
medical industry purchases developing products for use in processing.  The final consumer, the
patient, is concerned not about the x-ray itself, but about the diagnosis.

       The graphic arts industry consists mainly of printers who are only partially involved in
photoprocessing.  In most cases, photography represents a small part of their business and does not
present their most pressing environmental problems,' These businesses serve an industrial market
through published documents and advertising. The amateur photography sector includes all amateur
photographic processing, whether at minilabs, large wholesale laboratories, or mail order processing
labs.  These labs serve individuals taking pictures to preserve memories.  These consumers are
concerned only about the final picture, not about the process that produces it.

       Industry participants stress the variations among the demands  of the three major market
segments — medical imnging. graphic arts, and amateur photography. These requirements affect the
constraints on process and product improvements.

       o      The graphic arts market requires high quality pictures, but is relatively
              unconcerned with processing speed.

       o      The amateur market tends to be more concerned with speed in processing,
              but demands increasingly higher quality.

       o      The medical market is concerned with rapid and  accurate diagnosis, and
              therefore requires both quality and speed, as well as longevity of the image.

According to industry participants, the compliance burdens  faced by the photoprocessors make the
environmental characteristics of products and processes an important competitive factor in the
industry.  In Phase 2, we will further investigate the extent to which consumer demands act as a
barrier to environmental improvements.

       Photoprocessors compete based on price, quality, convenience, and speed of processing. The
trends in demand for amateur photographs are somewhat cyclic and follow the economic cycles, with
a minimum customer base  below which demand will not fall.  When people become more price
sensitive, as in a recession, they are more willing to sacrifice convenience and speed for lower prices.
Furthermore, in recessionary times, vacations and other leisure activities tend to decline, eliminating
many picture-taking opportunities.

       Commercial photography in the graphic arts industry tends to be even more closely linked
to the economy,  as  much  of this industry is based on advertising and business expenditures.
Applications in the medical field are for x-ray technology, and are therefore driven by  the health
care market.
   * Printers are usually more concerned about hazardous inks and air emissions from solvents
involved in the printing process than about the wastes generated in photoprocessing.


Current Economic Status

       The photoimaging industry  is  continuing  through a  decade-long  restructuring  and
streamlining process.  Manufacturers  have been laying off workers, spinning off secondary
businesses, and forming alliances with other companies to pursue new markets and add expertise
in digital technologies.9 The value of shipments for SIC 3861 products as a whole has shown a
decline since 1991 in constant dollar terms. U.S. photoprocessing sales decreased three percent in
1992, despite modest growth in photoprocessing worldwide. These recent trends reflect the effects
of the recession, both on amateur sales (with reduced travel and leisure activity spending) and on
graphic arts (which follows overall business trends).

       Since the 1950s,  there has been substantial growth in amateur photography, due to
development of higher quality photographs and the advent of user-friendly cameras.  However, the
real price of film and materials has fallen or remained constant over the same time period, mainly
as a result of product and  process improvements, as well as increasing price competition.

       In photoprocessing, there was rapid growth in the number of minilabs in the 1980s.  This
growth has ended recently, except for an increased number of minilabs in mass merchandising and
discount stores.

       Consolidation is occurring in the industry, both from a manufacturing perspective and from
a processing perspective.   Some smaller manufacturers have been  absorbed by the large market
players.   La addition, some  manufacturers are now involved in processing.   Kodak  owns
approximately half of Qualex, Incorporated, which is the largest single photoprocessing company.
Fuji and Konka have also  purchased  photoprocessing labs.   As  a result,  the three  largest
manufacturers are now also fuU or partial owners of the three largest photoprocessing chains.  (We
do not know what portion of the photoprocessing market these three players serve.)
Products and ProccaKs

       Photography is currently dominated by sUver-halide processes - silver being the image-
capturing component of film.   Within  this market,  manufacturers  have made  continuous
improvements, including film with sharper colors, finer grain, and a greater variety of speeds; and
point-and-sboot and single-use cameras. There are, however, some innovations in products and
processes that may reduce the importance of sihrer-halide products in the future.  Most notable is
electronic imaging.

       The role of electronic imaging is becoming increasingly important in the photographic
industry and represents an important area  of potential growth.  Many of the major photographic
manufacturers are planning to add electronic imaging to their product lines. Although the extent
   * U.S. Department of Commerce, U-S. Industrial Outlook 1994. p. 23-1. Total employment for
SIC 3861 as a whole decreased from 88,000 in 1987 to 76,500 in 1991, and to an estimated 75,500
in 1993. A further decline to 75,000 is forecast by the Department of Commerce for 1994.


to which this will affect the market for silver-halide-based materials is unclear,10 siiver-halide imaging
is likely to maintain a significant market share due to the inferior quality of electronic imaging. The
most  likely area of growth in the near future is in hybrid systems,  which combine the image-
manipulating capabilities of electronic imaging with the imaging quality of silver-halide-based output.
       Manufacturers have also been developing films without silver halide, mainly because of the
high price of silver and the regulations affecting it. Xerox recently developed a heat-based film,
which uses selenium rather than silver.  Diazo, vesicular, photopolymer, and electrostatic films also
are undergoing development and improvement The success of these alternatives depends on how
well they meet consumers' demands as disadvantages associated with substitutes can outweigh the
benefits of eliminating silver. For example, alternatives to silver-halide-based x-ray films require that
people receive higher exposures to radiation.

       Another significant development in the industry has been the single-use camera, which has
been purchased by 20 percent of U.S. households. Last year, sales increased 60 percent, with an
estimated 20 million units sold world-wide  in  1992.  Currently, single-use cameras account for
approximately 10 percent of the 1.8 billion rolls of film sold annually world-wide.
Environmental Issues

       The photographic manufacturing industry is a significant contributor of releases according
to the Toxics Release Inventory. In 1990, the industry emitted a total of 37,394,766 pounds of TRI
chemicals.  Eighty percent of these toxics were emitted to the air.  The other media for TRI
emissions, in order of decreasing volume, were water and publicly owned treatment works (POTWs);
land and underground applications; and offsite transfers.

       The industry's primary production emissions are volatile organic compounds from solvent
vapors.  According to TRI^the largest component of these releases is methylene chloride, which
represented 25 percent of the industry's total releases in 1990.  Together, five solvents (methylene
chloride, methanol, acetone, toluene, and methyl ethel ketone) accounted for 80 percent of 1990
TRI emissions.

       Outside of the industry's solvent use, several toxic inputs to the manufacturing process have
typically been the target of environmental concerns. These include:

       o      silver,
       o      hydroquinone,
       o      chromium, and
       o      selenium (in Xerox's heat-based film).
    10 The production of electronic images is not a chemical process, though chemicals are used in
manufacturing the equipment.

 Over the past 20 years, the industiy has significantly reduced the content of silver in their products.
 The vast majority of silver in film is not used in the  image and is recovered  from processing
 solutions.  However, the nature of the image formed determines the amount of silver used in that
 image; quality requirements for image and consistency limit the potential for further reduction.

       As a result of the reduction in the silver content in film, the industry has  also reduced the
 amount of hydroquinone in developer. There is a direct relationship between the amount of silver
 on the film base and the amount of hydroquinone required to develop the image. The amount of
 chromium used in the film emulsion has also been substantially reduced, and is currently used only
 in the Kodachrome process.  The elimination of chromium in traditional films was primarily the
 result of regulatory demands  on  processors to eliminate it from their effluent.  In contrast,  the
 concern  about selenium has arisen only recently with Xerox's development of a heat-based film
 which contains the chemical.   Although Xerox is promoting the film on the basis of its silver-free
 nature, many  in the industry claim that selenium is far more toxic than  silver, and that from an
 environmental perspective, the new technology represents a step backward.

       The industry generates solid and hazardous waste during the production process, including
 plastic from film cuttings and cartridges, silver, and various solvents.  For example, emulsion coating
 rejects generated during the coating phase contain silver, and are therefore considered hazardous
 waste. The majority of these materials are recovered,  the silver is removed, and the material

       Solid waste has  also become a concern for photographic manufacturers,  particularly with
 respect  to the single-use camera.   Environmentalists have opposed  the product based on its
 disposability. In response, manufacturers have established an infrastructure for recycling the camera,
 compensating  the processors for each camera returned (generally five cents) and for the shipping
 charges.11 They have also increased the recyclability of the materials used. Many of the camera's
 parts, such as the lens, are reused numerous  times prior  to being  recycled.   In addition,
 manufacturers have established recycling programs for other industiy by-products.  For example,
 photoprocessors  can return  film cartridges,  spools  and returnable chemical drums  to  the
 manufacturer  for recycling."

       Environmental and technical innovations are sometimes developed by the manufacturers in
 response to their customers' needs. At least partially in response to regulations faced by customers,
chemicals in processing solutions and materials have been reduced overall by 30 to 50 percent in the
 last ten years. Chemistry replenishment rates have fallen, and the manufacturers are improving
 recyclable processing solutions. These environmental improvements, particularly with respect to the
reduction in silver content, have produced positive economic returns.  Industry members point out
that source reduction generally produces at least some financial benefit.

       Photoprocessing operations generate four types of wastes:

       o      silver-bearing fix solutions and wastewatcr,
       o      chemical recovery cartridges (CRCs) used to recover silver,
       o      film chips containing silver, and
       o      ferrocyanide sludge.
    11 The 1994 U.S. Industrial  Outlook reports that most larger photo processing labs and more
than one-half of all minilabs participate in recycling programs for single-use cameras (p. 23-2).


       The wastcwater from photoprocessing operations has been a focus of regulation because of
a number of parameters, including toxic metals, toxic chemicals, oxygen demand, ammonia, and bio-
nutrients.  By far the largest environmental concern cited by  the industry is silver.  Close to one
hundred percent of the silver in film and paper is removed during color processing, while 40 to 60
percent is removed from black and white film and paper.  The amount of silver remaining in the
wash water is significant, and many photoprocessing operations have installed equipment designed
to recover silver from spent solutions and wash water. The types of silver recovery equipment, in
order of usage,  are listed in Exhibit 3.3-5.
Exhibit 33-5
Ion Exchange
1 Systems
Removes 90
percent from silver-
rich solutions
Removes 90
percent from silver-
rich solutions
Removes 90
percent from wash
Removes 99
percent from wash

Concentrates silver-
rich solution 40-60
No additional
chemicals released;
95 percent removal
with two cartridges

Reduces water
Reduces water
Will not reach extremely low concentration limits
Efficiency diminishes with use; Iron in effluent
Can not be used for spent fix and bleach-fix
solutions; Costly; Complicated technical
requirements; Adverse environmental impacts
Can not be used for spent fix and bleach-fix
solutions; Costly; Complicated technical
requirements; Requires hazardous chemicals
Requires additional recovery
Requires additional recovery

       Exhibit 3.3-6 provides data on the current use of environmental controls by commercial
 photoprocessors. Similar data are not available for hospitals and other non-commercial processors.
ExhiA 3.3-6

Percent Operating Silver
Recovery Systems
Type of Silver Recovery
Systems Used:
. electrolytic recovery
. steel-wool canister
. ion exchange
Percent that Recycle
Percent that Regenerate
Percent of Firms Visited
or Contacted by State or
Local Water Authority in


Stove with
and Captive
Source: 1991-1992 PMA Industry Trends Report, pp. 69-70.
33.2   Driven
       A wide range of factors was identified in  the interviews and expert panel meetings as
influencing environmental performance in the photoimaging industry. In some cases, these factors
were  explicitly identified  as encouraging environmental improvements or as posing  barriers to
compliance  or environmental progress.  In other cases, a diagnosis  of causes was implicit in
participants' arguments for various policy solutions, but was not explicitly stated.  Of necessity, we
have had to interpret the implications of various comments.  The reader should keep in mind that
not all parties participating would necessarily agree  with our interpretations.  In general, however,
we found substantial agreement about the major environmental issues in this industry among the
parties consulted so far (although not necessarily about what policy responses to those issues are

       As described in Chapter 2, our goal is to determine what factors act as incentives to improve
environmental performance (drivers) and what factors act as barriers or disincentives to improving
environmental  performance.   Currently, environmental improvements  are largely,  though  not

exclusively, driven by federal and state regulation in the photographic industry, as in most industrial
sectors. Much of the discussion in interviews and panel meetings concerned the merits or drawbacks
of specific regulations.  Given the substantial  effort required to comply  with  existing and new
regulations, it is not surprising that many participants in this study were most interested in talking
about the regulatory system and improvements  to it This focus on regulation is only part of the
broad range of issues we hope to address in this study, however.  To maintain this broad focus, we
have supplemented the issues raised by various participants in some cases, to suggest issues that lie
outside the interests of these participants or that  might take on  more importance  once  specific
regulatory concerns are  addressed.

       To the extent possible, we have noted  the specific effect each  barrier  or driver has on
environmental performance in the photoimaging industry. Some of the issues cited as barriers affect
the costs of achieving compliance with regulations or improved performance, rather than the extent
to which such improvements occur.   Reducing these barriers would  not necessarily promote
additional improvements in environmental performance,  but  would reduce the costs of  existing
practices. We included  these issues in our discussion of barriers for three reasons:

       o      First, high compliance costs can  reduce compliance, and  make regulations
              less  effective  in  practice.   Reducing unnecessary costs may encourage
              increased compliance, with the attendant environmental benefits and savings
              in enforcement efforts.

       o      Second, one of the general goals of  the sustainable  development concept is
              to reduce the conflict between environmental and economic goals.  One step
              in that effort is to ensure that regulations  are as cost-effective as possible.
              This  project  therefore  includes   efforts  to  achieve  equal or  better
              environmental performance at less cost.

       o      Third, many of the manufacturers stated that they have a fixed research and
              development budget for environmental performance, including compliance
              expenditures.  If the cost of compliance were lower, these  funds could be
              diverted to innovative environmental improvements.
       We discuss economic, technology, and regulatory drivers and barriers in separate sections

       The economic characteristics of this industry have presented both incentives for and barriers
to improved environmental performance, according to our discussions to date.

       A major barrier to the effective recovery of silver in photoprocessing wastes is the small size
and lack of technical sophistication of many of the photoprocessors.  Processes to remove silver from
wastes require careful  operation and maintenance to achieve their design effectiveness.  Many
photoprocessors, especially the minilabs within drug stores, grocery stores, and department stores,
do not have staff with sufficient training and longevity to operate this equipment effectively. While
manufacturers make  substantial investments in training and guidance, there may be inherent limits
in the ability of these processors to operate silver recovery systems effectively.

       High prices for certain inputs have encouraged reduced use of those inputs over time. In
addition, competition based on product quality has encouraged some environmental improvements.
This congruence between economic and environmental goals was particularly noted with respect to
silver. Past increases in the pike of silver encouraged efforts both to reduce the amount of silver
used  in sensitized products and to increase silver recovery and recycling.12 The extent to which
silver is recycled is sensitive to price, and according to industry participants is currently hampered
by the combination of moderate pikes for silver and the costs of complying with RCRA rules.13
However, actions taken to reduce the amount of silver in sensitized products also had the effect of
improving product quality.14  According to industry contacts, competition based on product quality
has continued to encourage the use of less silver over time, independent of fluctuations in the price
of silver.

       The high costs of replacing in-place photoprocessing  equipment acts as an economic barrier
to improved environmental performance.  Many environmental improvements (e.g., processes that
recycle  photoprocessing chemicals)  are embedded in the  photoprocessing  equipment,  and
replacement of existing equipment is required to  achieve those improvements."  Photoprocessors
are reluctant to replace equipment before the end of its useful life - especially minilabs, for whom
the capital investment can be a substantial burden. While the equipment replacement cycle acts as
some constraint on the speed of environmental improvements, it is not dear that it causes significant
delays. The bask pace of product and process improvement results in a turnover of photoprocessing
equipment in only eight years on average, according to industry experts.

       Photographic product users' needs are also cited by industry contacts as a factor influencing
the pace  and extent of environmental improvements.   As described  earlier, different end-use
segments  present different demands that influence  the nature of changes in photoprocessing
chemistry over time. For example, the market demand for one-hour processing eliminates many
opportunities for reducing the chemical content of processing chemicals.  If chemicals are reduced,
the film must remain in the solution longer, extending the time required for developing. Also, the
accuracy and quality requirements of x-ray film and graphic arts film limit the potential for
alternatives to silver-halide4)ased film.
   12 Incentives to conserve  and recover silver were especially strong in  1980 when the Hunt
Brothers' attempt to comer the market in silver drove prices up to about $50 per troy ounce. Silver
prices declined dramatically after this episode, and are now approximately $5.15 per troy ounce.

   13 The impact of RCRA on incentives to recycle is discussed later in this section.

   14 Using fewer and thinner emulsion layers produces a sharper image, as well as reduces the
amount of silver and other chemicals used.

   15 For example, the Rapid Access color developing process requires less water and less chemicals,
and takes up less space than its predecessor. RA processing is also faster, allowing for one-hour film


       Finally, competition from foreign suppliers is cited as a factor influencing manufacturers'
ability to absorb the costs of environmental compliance.   The industry is becoming increasingly
international in  nature as  the  trade environment  changes  and foreign  companies  begin
manufacturing in the United States.  According to the industry, foreign competitors often face less
stringent or more cost effective environmental regulations than those with which U.S. companies
must comply. To the extent that production by foreign companies in the United States increases,
this cost advantage will narrow. We do not currently know how much of a cost advantage foreign
suppliers actually enjoy, or what the future mix of U.S. versus overseas production is likely to be.

       The nature  of  photographic  equipment  requires  that  the  supplies  be  relatively
interchangeable. According to industry experts, there are quality differences among products and
photoprocessing processes.  However, within product categories (e.g., 35 mm films) there must be
enough consistency in design for products to  be  used in a range of equipment  Similarly, the
processing  chemistries must be consistent to allow development of all brands of film. This results
in a strong  incentive for coordination with regard to technical standards. These technical standards
may either promote or hinder environmental improvements, depending on how they are defined.
More investigation would be needed to determine whether existing standards  act as barriers or as

       Regulation has acted both as an incentive to environmental improvements in photographic
products and  processes and, according to industry participants,  as  a hindrance.   Clearly,  the
regulation  and high price of silver  have encouraged  actions to reduce and recover silver in
photoimaging. However, industry representatives argue that:

       o      The current standards governing silver under the dean Water Act (CWA)
              and the Resource Conservation and Recovery Act (RCRA) are not justified
              by the scientific evidence on the human  health and environmental  impacts
              of silver.

       o      States and localities have in some cases gone well beyond the standards set
              at the federal level, to impose stringent limits on silver in indirect discharges
              to POTWs that (1) are extremely expensive to meet, (2) may encourage
              increased discharge of other toxic chemicals, and (3) discourage water

       o      Regulation of silver-bearing  wastes under RCRA discourages recycling of
The Silver Coalition has requested that EPA acknowledge certain facts and take action as follows:

       o      "... the ionic form of silver, rather than total silver, in waste water discharges
              is the substance that should be regulated.

              ...  during  an interim period,  water  quality criteria for silver [should]  be
              established that is 40 times the current or proposed acute and chronic values
              that are based on the toritity of free silver ion (Ag*).

              ...  a  reasonable time [should] be established for the development of  an
              analytical method to measure the ionic form of silver at very low levels.

              ... silver [should] be deleted from the Tenacity Characteristic (TC) list under
              RCRA... consistent with the action of the Office of Drinking Water, which
              deleted the primary  maximum contaminant level (MCL) for silver, and our
              understanding of other pathways."16
Issues related to the CWA and RCRA are discussed separately below.
       For the purposes of the dean Water Act, there are two types of dischargers of aqueous
waste - those who discharge directly to surface waters and those who discharge indirectly, through
the sewer lines and eventually to a POTW.  Direct dischargers, including the POTW itself, are
regulated under National Pollutant Discharge Elimination System (NPDES) permits. The limits in
these permits are based (for some industries) on national effluent guidelines, and for all dischargers
on Federal Water Quality Standards  and, if required, more stringent  standards specific to the
receiving water body.

       POTWs establish pretreatment standards for indirect dischargers in their service areas to
ensure that after treatment the POTWs effluent will meet its NPDES permit limits and to prevent
disruption of its treatment processes. The pretreatment limits are specified in a pretreatment permit
issued to the source.  In most cases, these are the limits that apply to photoprocessing operations,
since more than 90 percent of photoprocessors are indirect rather than direct dischargers.

       The mam dean Water Act constituent of concern for the photographic industry is silver.
In the 1970s, EPA stated in guidance that photoprocessors should not be regulated as a categorical
industry, because they were already recovering silver due to its economic value. The Agency was
concerned about promoting water conservation and reducing the hydraulic loading to the treatment

       Prior to 1990, the drinking water standard for silver was 50 parts per billion, which was not
problematic for either the manufacturers or the processors.  This acute criterion was based on
hardness, and there were no chronic criteria for silver, as the acute standard was believed to be
adequately protective  of human and aquatic health.  In 1990, EPA proposed chronic criteria for
silver in the Draft Silver Criteria Document This document proposed removing the hardness-based
   * Letter from Thomas J. Dufficy, NAPM, to Richard D. Morgenstern, U.S. EPA, dated June
25, 1992, accompanying a Silver Coalition report on "An Economic Assessment of the Impact
Resulting from Silver Pretreatment Standards."


standard and suggested that fresh water chronic criteria be based on the lowest observed effect level
(LOEL). Shortly thereafter, the National Toxics Rule and the Great Lakes Water Quality Initiative
also proposed numeric chronic silver criteria.

       Although EPA determined that the Draft document should not be finalized and that the
numeric chronic criteria should be removed from both the National Toxics Rule and the Great
Lakes Initiative, twenty-four  states  had already adopted the chronic criteria and  used  them to
establish silver discharge limits for treatment plants.  The POTWs then established pretreatment
limits for industrial dischargers based on these standards.

       Several states eventually followed the EPA guidelines. Arizona, Georgia, and Pennsylvania
have deleted the chronic criteria for silver.  Missouri and New Mexico have proposed that the state
delete the standard, and the chronic standard is under review in Colorado, Florida, Mississippi, New
York, Oklahoma, Rhode Island, and Texas.

       In 1992, the  Office of Science and Technology  at  EPA issued a memo to the  Regions
recommending that states not adopt chronic water quality standards for silver. The  1993 National
Toxics Rule contained only acute water quality standards for silver.

       Industry representatives  argue that the effective  limit on silver established for many
photoprocessors is too stringent  A number of factors contribute to the low effective standards
imposed in many locations:

       o      The federal water quality standard is based  on the toxicity of ionic silver.
              Industry argues that silver discharged  from photoprocessors in the form of
              silver thiosulfate rapidly combines with other naturally occurring substances
              to form compounds that are much less toxic than ionic silver.17

       o      There  are no  reliable analytic procedures to test for ionic silver, so that
              monitoring~and compliance are generally based on total recoverable silver.
              Some studies show that much of this silver may not be biologically available,
              and that the amount of the most toxic ionic silver present is quite low.1*
    17 The federal concentration limit for silver in aqueous effluent is 5 parts of silver per million
parts of water.  This limit is based on tests performed with silver nitrate in laboratory test water,
which decomposes to ionic silver.

    18 In October 1993, EPA's Office of Water Policy issued Technical Guidance on Interpretation
and Implementation of Aquatic  Life  Metals  Criteria,  recommending that dissolved metals
concentrations, rather than total recoverable metals concentrations, be used to set and measure state
water quality standards. However, the majority of states and POTWs continue to set limits based
on  the risk posed by ionic silver, and to require monitoring and measurement based  on total
recoverable silver.


              Limits on indirect dischargers are based on an allocation model used by the
              POTW. Some commenters argue that the limits imposed on photoprocessors
              are lower because limits cannot be imposed on households and other non-
              photo sources that are difficult to control.19
       Industry representatives argue that the extremely low silver limits applied in some localities
impose high costs that are not justified by the environmental benefits, and result in increased
discharges of other toxic compounds.

       o      In some areas, the limits are so low as to preclude discharge of any kind, and
              processors must have their solution hauled off-site. The cost of having spent,
              silver-rich solutions hauled off-site for recovery typically runs between $2.00
              and $6.00 per gallon within a 25-mile radius of the central facility.

       o      The implementation of extremely low concentration limits for silver requires
              processors to use more advanced recovery techniques.  One of these is ion
              exchange, which, according to industry requires the use of sulfuric acid and
              sodium hydroxide, both of which are extremely  toxic.   The use of these
              chemicals results in the processors' being regulated under Title HI of the
              Emergency Planning and Community Right to Know Act (EPCRA).

       o      Another  option for reaching  very low concentration  limits  is metallic
              replacement with several cartridges.  These cartridges deposit iron in the
              effluent  According to the industry, to reach very low limits, the cartridges
              must be replaced  at 20 to 40 percent capacity, rather than the 80 percent
              capacity typically  recommended by manufacturers.   This results in  more
              cartridges being used, more  iron  in  the  effluent,  and more frequent
              transportation of the cartridges to silver recyders.
       Industry representatives also stated that regulation of silver in wastewater discharges may
discourage water conservation.10  Because most  pretreatment permit limits are expressed on a
concentration rather than mass basis, they argue that photoprocessors are discouraged from adopting
water-saving  measures.  For example, use of concentration-based limits is said to  discourage
photoprocessors from adopting Vashless" technologies or otherwise reducing water use (e.g., by
increasing the number of stabilization tanks and using countercurrent rinsing).  One source even
described situations in which photoprocessors that were not able to meet very low local limits were
encouraged by regulators to increase their water discharges to meet their concentration limit through
    19 It has been estimated that large photoprocessors such as hospitals, diagnostic clinics, motion
picture film developers, and large printers and photofinishers account for approximately 10 to 25
percent of silver loadings to POTWs.  Small photoprocessors account for another 25 to 50 percent
A large portion of the remainder comes from domestic sources - e.g., from washing of silverware.

    20 One source stated  that reducing water use  is the area with the greatest potential  for
environmental improvement in this industry.


       The CWA regulations allow the use of either mass-based or concentration-based  limits.
Presumably, a concentration-based limit could be changed if flow were to change, to achieve the
same limit on mass loadings.  However, various parties argued that POTWs are reluctant  to use
mass-based limits for indirect dischargers, or to adjust concentration-based limits to encourage water
conservation.  A variety of reasons were cited for this reluctance, including:

       o      Greater inherent difficulty in monitoring mass-based limits;

       o      Lack of familiarity with mass-based limits on the part of POTWs and/or the
              states who oversee the POTWs' compliance with their own permits;

       o      Concern on the part of POTWs that they will have compliance problems and
              be subject to state enforcement actions if they attempt to make changes to
              their current systems; and

       o      Current use of computer databases and monitoring systems set up to track
              concentration limits, that would require software changes if mass-based limits
              were used instead.
More investigation would be needed to understand the relative importance of different barriers to
the use  of mass-based limits (or more flexible application of concentration-based  limits)  to
encourage water conservation.

       Industry representatives acknowledge that current evidence on the fate and transport of silver
in the environment is not adequate, and industry participants are currently sponsoring a number of
scientific studies in cooperation with EPA. A POTW representative on the expert panel urged EPA
and the photographic industry representatives to include studies of the fate of silver in the sewers,
while a representative of the  Natural Resources Defense Counsel expressed concern tfcat further
studies be conducted to account for possible cumulative biological effects.

        Resource Conservation aj|j Rc^ivery Act (RCRA)

        Wastes containing silver are regulated as hazardous under Subtitle C of RCRA if they exhibit
 the toxicity characteristic for silver.21 However, the Subtitle C requirements that apply to these and
 other "precious metals" wastes when they are recycled are less stringent than the requirements that
 apply to other hazardous wastes. In addition, generators of hazardous wastes in quantities less than
 100 kg/month  (including all  their hazardous  wastes)  are  largely exempt  from  the  Subtitle C
 requirements.22 Virtually all photoprocessors except individual doctors'  and dentists' offices and
 some very small minilabs are likely to generate wastes exceeding the Small Quantity Generator
 (SQG) limit

        According to industry participants, the regulatory status of different forms of silver-bearing
 materials varies, and  there is some  confusion about what materials are potentially subject  to
 regulation as hazardous wastes. In general, industry contacts said that:

        o       Rinsing electrolytic flake generates a hazardous wastewater.

        o       The electrolytic flake itself is considered a product and not subject  to

        o       The silver-saver cartridge from metallic  replacement recovery is not a
               hazardous waste if it is property rinsed and does  not exhibit the toxicity
               characteristic for silver.
       The following requirements apply to silver-bearing wastes sent off-site for treatment:

       o      Generators must notify EPA that they are generating a hazardous waste and
              obtain an EPA ID number.
    21 The toxicity characteristic (TQ is one part of the "definition of hazardous waste" (40 CFR
261), and silver is one of 40 toxic chemicals currently included in the TC  Wastes exhibit the
characteristic for silver if they generate a leachate that contains more than 5.0 mg/liter of silver. The
regulation specifies the test procedure to be used to generate the leachate from the waste (the
Toxicity Characteristic Leaching Procedure or TCLP) and analytical methods for testing for silver.
For liquid wastes (e.g., wastewaters), the waste itself, rather than a  leachate from the waste, is
subject to the silver concentration characteristic. Generators of wastes are not required to actually
analyze the waste or leachate for concentration levels.  They must "determine" whether the waste
exhibits the characteristic by testing pi by applying their knowledge of the processes generating the

    22 These "small quantity generators" (SQGs) must send their wastes only to facilities that are
regulated as Treatment, Storage and Disposal Facilities (TSDFs), that are authorized by the State
to handle such wastes, or  that recycle the wastes. There are limits on the amount of waste SQGs
may accumulate without losing their exemption.  Off-site facilities that receive wastes only from
SQGs are also exempt from the RCRA requirements. It is unlikely, however, that any off-site silver
recyclers handle only wastes from SQGs.


Wastes must be transported using licensed hazardous waste carriers, which
adds to the cost of transportation.

Generators and transporters must comply with Department of Transportation
rules for transportation of hazardous materials.

Generators must prepare a manifest for each shipment, maintain records, and
submit "exception reports" if not notified that  wastes are received at the
intended destination; transporters and the receiving facilities must comply
with the  tracking requirements of the manifest system.

Generators must keep certain records and submit a "Biennial Report"

Transporters are required to clean up and mitigate any releases of the wastes
during transport23

Storage of the wastes prior to shipment off-site  is limited to 90 days before
the storer becomes  subject to extensive TSDF requirements.  Such "short-
term"  storage  (less than  90  days)  is subject  to contingency planning,
preparedness and prevention, and personnel training requirements.  In
addition, storage  must be in containers or  tanks that meet certain technical
In addition, the central treatment facility receiving the wastes is subject to an extensive set of
requirements for Treatment, Storage, and Disposal Facilities" (TSDFs).

       Generators of silver-bearing wastes destined for recycling, and facilities that recycle these
wastes,  are exempt  from most of the requirements that apply to wastes that are treated  or
disposed.2* Generators must notify EPA and obtain an ID number, and generators,  transporters
and recycling facilities must comply with the manifest requirements.  Recyclers must keep records
to show that sufficient amounts of the material are being recycled.29
    23 Under Department of Transportation rules for hazardous materials transport, transporters are
required to report spills and releases but not necessarily to clean up or mitigate the damages.

    24 Only "spent materials" are subject to requirements when reclaimed. Other types of silver-
bearing wastes ("sludges" and "by-products") are not regulated as hazardous under RCRA when
recycled. "Sludges" are defined as solid, semi-solid, or liquid wastes generated by water treatment
or air pollution controls.  In the case of photoprocessing, wastewater treatment residuals are not
subject to the precious metals recycling requirements when recycled, but other silver-bearing wastes
may be regulated when recycled (e.g., spent processing solutions).  In addition, silver-bearing wastes
that are regulated when reclaimed are subject to the reduced requirements for "Resource Materials
Utilized for Precious  Metal Recovery" in 40 CFR 266 Subpazt F, rather than the more extensive
requirements that apply to other hazardous wastes.

    25 That is,  they must demonstrate that the materials are not being "accumulated speculatively"
rather than being recycled.


       Regulation of silver-bearing wastes under  RCRA subjects more of these wastes to the
Department  of Transportation hazardous  materials transportation requirements than would
otherwise be regulated.  The DOT rules include a variety of packaging, placarding, and transport
practice requirements that depend on the mode of transport and the type of hazard posed by the
waste.  The DOT hazardous materials requirements apply automatically to any waste that is subject
to the  RCRA hazardous waste manifest If silver-bearing wastes were not subject to the RCRA
manifest requirement, they would be subject to the DOT rules only if they contained the specific
forms of silver listed in the DOT hazardous materials table and if shipped in quantities exceeding
their "Reportable Quantities." In addition, transporters would not have to comply with Subtitle C
storage facility requirements if they stored the wastes for more than 10 days in transit, and would
not automatically have to clean up or mitigate spills during transport. The effect of regulation under
RCRA, then, is to apply the DOT requirements to a larger  set of silver-bearing wastes and to
impose some additional requirements on generators and transporters.

       Wastes discharged  to the sewers or under a NPDES permit are not subject to any RCRA
requirements, unless they are stored prior to discharge. Wastewater treatment tanks used to treat
wastes  prior to discharge are also exempt  from  RCRA  TSDF requirements.   Therefore,
photoprocessors can avoid  RCRA regulation by treating and discharging their wastes in compliance
with Clean Water Act requirements.

       Industry participants argue that regulation of silver-bearing wastes as hazardous - even with
the reduced requirements for wastes that are recycled for precious metals - discourages recycling.
They cite the example of silver-coated plastic film, which is generally chemically treated or burned
for silver recovery, since it has sufficient economic value to be worth recycling.  In contrast, other
than spent fix and bleach-fix, photoprocessug solutions do not generally contain enough silver to
be recycled economically, given the costs imposed by hazardous waste regulations.  Packaging and
transportation under DOT rules, using a licensed  transporter, and complying with the manifest
requirements are the main sources of added cost

       In addition, some industry participants expressed concern about additional liability for the
wastes  sent off-site, due to tfieir definition as hazardous under RCRA. This concern may arise from
the added transporter responsibility to dean up spills  imposed by RCRA, or may refer to added
liability under the Superfund program. Technically,  definition of a waste as hazardous has no direct
bearing on a generator's liability for clean-up  costs if the wastes end up at a Superfund site. In
practice, however, the generator may be more liable for wastes regulated as hazardous, because the
wastes  can be  more  easily traced to then* source due  to the RCRA manifest and labelling

       RCRA regulation also discourages the development of centralized treatment facilities, other
than POTWs. Photoprocessors are subject to the requirements for short-term storage if they store
wastes  prior to shipment off-site for treatment rather than recycling - and to more extensive storage
facility requirements if they store for more  than 90 days.  The centralized treatment facility itself
would be subject to permitting and to the full Subtitle C requirements for treatment and storage
facilities.  Absent such regulation, shipping wastes to centralized facilities for treatment might be
more economical and more effective in reducing risks than treatment on-site - especially for the
smaller processors that lack the  skills, space, and capital to treat  wastes extensively. For example,
industry representatives said that small processors might send their wastes for treatment in  more
cost-effective equipment at larger processors'  facilities.   More investigation would be needed,
however, to determine under what circumstances centralized treatment would be more effective and
less costly.


       Industry representatives said  that some states define recovery of silver or silver-bearing
wastes in the on-site process  as treatment, subjecting the processors themselves to the TSDF
standards. Further investigation is needed to determine the basis for this regulation. The minimum
national standards established by RCRA exempt "totally enclosed treatment units" from regulation
as TSDFs. Some states may have applied more stringent standards, or there may be disagreements
about whether photoprocessing processes qualify as totally enclosed treatment units.

       In general, then, industry representatives argue that regulation of silver-bearing wastes as
hazardous under RCRA encourages the discharge of wastes to POTWs and discourages recycling.
This results in added loadings to POTWs, especially from small dischargers that are unlikely to be
subject to POTW and local enforcement scrutiny. Larger photoprocessors, who are subject to more
scrutiny and more effective enforcement of pretreatmcnt requirements, incur higher costs overall
because the costs of recycling, centralized treatment, and in some cases on-site recovery of silver are
inflated by the RCRA requirements.

       The Silver Coalition is seeking removal of silver from the RCRA Toxicity Characteristic (TC)
list  Silver was originally placed on the TC list when it was initially promulgated, because the TC
included all toxic chemicals for which there were primary MCLs  in effect. Because  the primary
MCL for silver has been deleted, the Silver Coalition argues that silver should be removed from the
TC as well.  EPA's Office of Solid Waste is considering this request. The OSW representative on
the second expert panel agreed that removal of silver from the MCL is sufficient evidence that silver
should not be included on the TC based on  human  health effects.  Removal from  the TC will
therefore depend on OSWs review of the ecological effects of silver. At this time, however, OSW
is not actively studying this issue and  removal of silver from the TC is low on the Office's priority
list due to lack of resources.1'
3.33   Possible Policy Options

       Our research and discussions with various stakeholders suggested a number of policy options
EPA  or other parties  might take to promote improved environmental performance in the
photoimaging industry.  Exhibit 3.3- 7 provides a list of the ideas that were raised by one or more
participants, or suggested by our research on the industry. The ideas range from specific regulatory
reforms, to education or outreach programs to promote compliance or improved practices, to
cooperative research projects.
    26 It was estimated that even a rule-making that is not controversial would take one full-time
staff person and one-and-one-half years to complete.

                                         Eilubit 33-7
   o EPA Will Provide Training and Flexibility for the Use of Mass-Based limits by POTWs

   o Modify Hazardous Definition of Silver
     1) Flexible Regulation Under Subtitle C
     2) Apply the Special Collection Rule
     3) Take Silver off the Toxitity Characteristic List

   o Regulate Photoprocessors under a Code of Management Practice for Water Effluent and Silver

   o Make FederalState/Local Effluent Guidelines Consistent

   o Monitor for Ionic Silver or Change Pretreatment Limits to Address Total Recoverable Silver

   o Standardize the Permit Application Procedure for Minilabs

   o EPA Participation in Voluntary Standard-Setting Process

   o Develop Institutional Knowledge Base at EPA

   o Develop Life-Cycle Analysis Techniques

   o Recognize Positive Environmental Performance

   o Facilitate Cooperation Among Manufacturers on Recycling Programs         	
       This list was discussed at the second expert panel meeting, and revised to reflect their
comments and additions.  At that meeting, participants selected four areas for focus in Phase 2 of
the project:

       o      Removing RCRA Barriers to Centralized Treatment and Recycling of Silver,

       o      Developing  and  Promoting  a  Code   of  Management Practices  for

       o      Continued research on Silver Speciation, Toritity, Fate and Transport in the
              Environment, and Development of Analytical Methods

       o      Minimizing Inconsistencies in Regulation, Standards,  and Enforcement
              Among the Federal, Regional, State and Local Governments.
These four areas are discussed in detail in this section. Appendix 3-B to this chapter provides brief
discussions of the policy issues and options that were not selected at that meeting for focus in the
next stage of the project As described in Chapter 1, EPA intends to continue investigating the
potential for cooperative pilot projects in the four areas highlighted by the expert panel. Other ideas
for policy actions  and pilot projects may also be pursued as well, depending on the comments
received on this report

       This section first lists the criteria used to evaluate and choose policy options for emphasis,
and then discusses each of the four policy areas selected in the second expert panel meeting.

Criteria for Selecting Policy Options

       In evaluating policy areas, the expert panel favored options that would:

       o      Have a yignificant environmental payoff;
       o      Promote cost-effectiveness;
       o      Be "cleaner, cheaper, and smarter";
       o      Have the capacity to affect  long-term thinking and action toward
       o      Be feasible, considering the length of time required for completion, the
              method  of  implementation, the size of the relevant audience, impact and
              importance, and the effectiveness of EPA as a player; and
       o      Encourage  cooperative involvement  in  the  project among  a variety of
Removing RCRA Barriers to Centralized
Treatment and Recycling of Silver-Bearing Wastes

       As noted earlier, the Silver Coalition is seeking removal of silver from the RCRA toxkity
characteristic list  They point out that the primary MCL for silver that resulted in inclusion of silver
on the TC list in the first place has now been deleted by EPA. They argue, then, that there is no
reason for silver to be on the TC list because it is regulated by water quality standards and is
immobile in soils, and therefore does not appear to be a potential source of adverse ecological

       This action would remove photoprocessors' silver-bearing wastes from any federal regulation
as a hazardous waste. Hazardous waste regulations would still apply under other RCRA sections
addressing secondary refiners and other specific facilities.  The Coalition argues that there would
be no increase in risks to human health and the environment, and that this action would promote
more recycling of silver, resulting in reduced discharges to POTWs.

       Removal of silver from the TC would not automatically result in deregulation of silver wastes
in the RCRA-authorized states.  However, industry representatives  say  that they would have
additional leverage to persuade the states to modify their regulations and legislation.

       Other options short of removing silver from the TC entirely  might also reduce barriers to
recycling.  EPA is currently investigating options for revising the RCRA  regulation of recycled
wastes.  The  Definition of Solid Waste Task  Force is considering a new regulatory strategy for
recycled hazardous wastes, which applies different rules for different types of wastes and recycling
practices.  New provisions that reduce disincentives to recycling silver-bearing wastes might be
considered  in that context   In  addition, photoproces&ing wastes might be  subject to  reduced
requirements under the Special Collection or Universal Waste Rule, which is currently in use for
fluorescent light bulbs and batteries.

       Industry members of the expert panel expressed less interest in these more limited options
than in complete removal of silver from the TC.  They noted that reduced federal regulation rather
than removal from the TC would be less persuasive to the states as evidence that silver does not
require regulation as a hazardous waste.

       The industry's on-going research  on  the ecological  effects of silver will dearly be an
important step toward a decision by EPA about whether to remove silver from the TC The second
expert panel discussed the fact that the decision might  also come more quickly if responsible
environmental groups agreed that deregulation of  silver wastes is appropriate. As mentioned
previously, environmental groups are skeptical and will likely remain so until convinced that there
is no potential for silver to bioaccumulate in organisms.

       This led to discussion about a possible pilot project to test the hypothesis that removal of
silver from the toxicity characteristic list would promote more recycling and reduced discharge to
POTWs.  Such a cooperative industry-EPA project might involve  testing the impact of reduced
regulation in a certain geographic area on shipments to recyders, concentrations of silver in POTW
influent, and the extent of on-site recycling. The project might address deregulation of silver wastes
by removing silver from the TC list, or other more limited actions to reduce RCRA barriers to
recycling as well.  The pilot project might also be extended to address the potential for increased
centralized treatment and recovery, as well as increased recycling.

Developing and Promoting a
Code of Management Practices

       The Silver Coalition, the Association of Metropolitan Sewerage Agencies (AMSA), and the
Water Environment Federation, among others, are currently in the process of developing a Code
of Management Practices for photoprocessors.  The Code is based on the Best Available Technology
Economically Achievable ^BATEA) combined with Best  Management Practices (BMP. s), and is
intended to apply to all sources of photoprocessing waste.  According to the industry, development
of the Code will proceed, regardless of the Agency's participation.  However, the  organizations
involved encourage EPA to promote its use and adoption, in order to provide an impetus for states
and localities to incorporate it into their permitting procedures.

       The Code of Management Practices, currently in draft form, would recommend practices that
vary with the size of the photoprocessor (defined by daily gallons of process wash water and weekly
gallons of silver-rich solution). The practices are defined by a minimum recovery of silver from
silver-rich processing solutions (e.g., 90 percent)  and alternative combinations of recovery methods
that would achieve those recovery rates. Those developing the Code estimate that compliance with
the recommendations would reduce silver loadings to POTWs by 25 to 50 percent.

       According to industry and POTW representatives, the  majority of POTWs do not have the
resources to monitor large numbers of small facilities. Industry daims that if the best treatment
technologies economically achievable and management practices for operations, maintenance, and
testing are identified and implemented, monitoring these facilities will be less resource-intensive.

       The authors intend  the  Code to be  as  simple as possible, and to  ensure  flexibility in
compliance. It assumes that minilabs will be educated in the appropriate maintenance, operation,
and monitoring of the recommended systems. Many labs currently have recovery equipment in place
but do not operate it effectively.  The photographic supplies manufacturers have agreed to provide
this assistance and to distribute the Code.  The industry claims that if labs implement the Code in
its entirety, the large majority of them will be in compliance with the pretreatment limits established
by the POTWs.  According to the Silver Coalition, the Code is not intended to be a substitute for
regulation. They expect its use to result in higher actual compliance with current standards.

       According to the industry, the Code of Management Practices could serve many purposes,

       (1)    Education and technical  assistance, to support improved compliance  with

       (2)    Assistance to POTWs and other regulators in understanding silver sources;

       (3)    As a condition for regulatory variances or permit approval.27

Industry representatives argue that there are sufficient economic incentives to follow the Code of
Management Practices, because of the increase in silver recovery. The Code will make it easier for
photoprocessors to act on this incentive by providing them with the tools and information they need
to do so effectively.

       The Code of Management Practices is currently in draft form;  there has not yet been
agreement among the sponsoring groups on the final document  At this point, we have not fully
explored EPA's role in developing and promoting the Code. However, when the Code is complete,
the Coalition would like EPA to review it and to publicly endorse it  EPA's support would provide
credibility so that states arid localities are more likely to accept it.  Endorsement by EPA~might also
relieve processors of enforcement concerns, inducing them to implement the Code.

       Agency representatives  on the panel  expressed  interest in endorsing  the Code of
Management Practices,  assuming that approval does not result in any reduction in enforcement
authority.  They also suggested a pilot project implementing the Code in a particular locality.  If
measurements demonstrated that the amount of silver recovered rose and the total loadings to the
POTW fell  with the use  of the Code  of  Management Practices, the  Agency (and concerned
environmental groups) might support its wide-spread adoption more actively.

       It was also suggested that state, county, and local technical  assistance groups be included in
the distribution of the document These groups could be helpful in disseminating the  information
in the Code and in assisting POTWs and processors in interpreting its provisions.
   27 For instance, the Coalition would like POTWs to consider implementation of the Code an
effective pretreatment permit if the facility meets the relevant pretreatment standards.


 Silver Spedation; Tenacity; Fate and Transport; Methods

       Currently, the environmental effects of various forms of silver are not clearly understood.
 It is not clear how silver speciates in  natural environments and in sewer systems, how toxic the
 various forms of silver are, how the various forms affect biological organisms, or how to test for the
 many forms of silver. The industry is attempting to resolve these issues, and would like to cooperate
 with EPA in doing so.

       The industry, in cooperation with regulatory agencies, is actively sponsoring research on the
 fate,  transport,  and toxicity of silver, in the hope  that this  research  will address regulators'
 uncertainties about  the  effects of silver in the environment.  The Silver Coalition has  been
 coordinating with the Office of Water  in developing this research plan.

       The second expert panel encouraged continued cooperation in sponsoring this research to
 resolve scientific uncertainties about the effects of silver.  Industry representatives expressed the
 hope that EPA will  respond quickly to the results of the research, when they are complete, by
 reducing or adjusting standards where warranted. A representative for  the POTWs encouraged
 industry and the Agency to  cooperate  in studying the speciation of silver, particularly with regard
 to its changes in form between release  from the processor and arrival at the POTW. The research
 efforts are ongoing, and at the moment development of sediment criteria  is a major focus.  Within
 EPA, there  is  a research plan to address the toxicity of silver  in sediments.   The  Coalition
 representatives urged EPA to fund a portion ($30,000) of the cooperative effort.

       Industry also asked that the Agency keep them informed of the evidence it needs to address
 these issues in a regulatory context, so that they can fund appropriate studies. They also suggested
 that the Agency allocate more travel money to allow then* staff, particularly in OW and OSW, to
 attend industry-sponsored scientific conferences.
Minimize Inconsistencies in Regulation, Standards, •*»«! Enforcement

       According to the industry,  there are many variations in the  setting, interpretation, and
enforcement of regulations, resulting in competitive disadvantages for processors in some areas.
They claim that it is difficult for businesses to predict the actions of regulators, and therefore
compliance is problematic.  It was  frequently noted that some states  and localities impose more
stringent limits than the federal standards.  According  to industry representatives, these more
stringent limits are not justified by the evidence on the risks posed by  silver in the environment.

       A number of suggestions were made for EPA policies that might increase the consistency
and rationality of the standards imposed on photoprocessors. The most extreme suggestion was that
EPA require that states and localities set standards consistent with national standards, unless more
stringent standards are specifically justified by local conditions.  Some panel members noted that
such an intrusion on states' authority would be very unlikely to be adopted.  Water quality standards
are intended to allow for local variations in water quality and usage. A single standard as proposed
by the panel would eliminate this possibility.

       Another way that EPA could promote more consistent standards for silver in effluent would
be to establish national categorical pretreatment limits for the photoprocessing industry, rather than
leaving limits for photoprocessors to be based solely on POTWs' own limits and  their allocation to

       A third suggestion was for EPA to sponsor education and technical guidance  for local
regulators on how to establish a logical silver limit based on scientific evidence.  This  guidance
should include information on the  risks posed by silver and the conservative assumptions used in
setting the federal standards.  The guidance might also clarify the economic and  environmental
effects of extremely stringent concentration standards in effluent guidelines.  Those advocating this
effort argued that most states would be receptive to guidance from Headquarters if it is presented
in a palatable way.  The Association of Metropolitan Sewerage Agencies (the trade  association for
POTWs) should also be involved in this effort.

       Industry representatives also suggested that the Agency advocate the use of mass-based limits
by the states and localities, to promote water conservation and the use of washless technologies.
Although EPA does not have the regulatory authority under current statutes to require that mass-
based limits be used, the Agency could issue guidance to states and POTWs regarding the use of
mass-based standards.  The Agency might also allow temporary exemptions from enforcement for
POTWs transferring to mass-based limits.  A representative of the Environmental  Defense Fund
suggested that the environmental community might support such an effort, if the  focus were on the
use of mass-based limits as a way to promote water conservation.

       Industry representatives encouraged the Agency to  provide  and  practice standardized
monitoring procedures.  Currently, there are a number of uncertainties regarding proper sampling
and testing techniques for effluents from photoprocessors. The industry suggested that EPA train
regulators about the  requirements of various federal  regulations, thereby facilitating universal
understanding and consistent enforcement.

       More specifically, industry members and related parties complained about the inconsistency
of the 40 CFR 136.  3  List  of  Approved Inorganic Test  Procedures,  number  62 for silver.
Representatives from the Office of Water agreed to review the standard.

       According to the industry, there are also inconsistencies hi analytical laboratory procedures.
 The expert panel discussed possible development of a system for accrediting analytical labs. EPA
participants argued that the Agency lacks the resources to establish an accreditation program for
labs, and that the Silver Coalition or an industry trade association might play that role instead.  The
Photo  Marketing Association  is  currently publishing  a  document entitled "How to Select an
Analytical Lab" to help processors  choose reputable testing labs.


                 Appendix 3-A



                                      Appendix 3-A

County  Sanitation Districts of Los  Angeles County.   Photoprocessing:  Pollution  Prevention
       Opportunities Checklist.

Dufficy, Thomas; Cappel, Robert; Summers, Scott M.  "Silver Discharge Regulations Questioned,"
       Water Environment and Technology, Vol. 5 No, 4, April 1993.

Dysart, Joe. "Corporate Environmentalism : Green is Decidedly in Fashion," PTN, Vol. 56 No. 18,
       September 21,1992, pp. 8-9.

"Eye on the Environment," PTN, Vol. 57 No. 6. June 15,1993, pp. 19-20,23.

Institute for Local Self-Reliance. Proven Profits from Pollution Prevention - Case Studies in Resource
       Conservation and Waste Reduction.  Washington, D.C, 1986.

LeBlanc, Gerald A.; Mastone, Joseph D.; Paradice, Arthur P.; Wilson, Brenda F. The Influence
       of Speciation on the Toxicity of Silver to Fathead Minnow," Environmental Technology and
       Chemistry, Vol. 3 1984, pp. 37-46

Neubart, Jack.   "Product  Packaging  Becomes Environmentally  Friendly," PTN, Vol.56 No.18,
       September 21,1992, pp. 9,16.

Neubart, Jack.  Technically Speaking, Today's Color Chemistries are Cleaner and Safer," PTN,
       Vol. 57 No. 6. June 15,1993, pp. 22, 27.

Photo Business,  December  1992, p. 20.

Photo Marketing Association International. ThePMA Industry Trends Report, 1991-1992. Jackson,

Photofinishing News

Photographic Society of America, Inc.  Perspective World Report 1966-1969  of the Photographic
       Industries, Technologies, and Science. Philadelphia.  (Note: this organization no longer exists
       under this name.)

Photography Trade News

Polaroid Report  on the Environment 1991.

RMA Annual Statement Studies 1992.  Robert Morris Associates, Philadelphia.

Toxic Release Inventory

                                     Appendix 3-A

U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufactures Industry Series
       - Medical Instruments; Ophthalmic Goods; Photographic Equipment; Clocks, Watches, and
       Watchcases,  MC87-1-38B.  (Note  that single establishment companies with up to 20
       employees were excluded from the mail portion of the census, and administrative records
       or industry averages were used to compile the data. These facilities account for 4 percent
       of the total value of shipments.)

U.S. Department of Commerce, Bureau of the Census. 1987 Census of Manufactures Subject Series:
       Concentration Ratios in Manufacturing. MC87-S-6.

U.S. Department of Commerce, Bureau of the Census.  Current Industrial Reports: Pollution
       Abatement Costs and Expenditures, 1992.  MA200(91)-1-

US. Department of Commerce, Bureau of the Census. Survey of Plant Capacity, 1990. MQ-C1(90>

U.S. Department of Commerce.  £7.5. Industrial Outlook.

USEPA, Office of Air and Waste Management, Office of Air Quality Planning and Standards.
       Control of Volatile Organic Emissions from Existing Stationary Sources Volume II: Surface
       Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks. EPA 450/2-77-
       008, May 1977.

USEPA, Effluent Guidelines Division.  Development Document for Effluent Limitations JSuidelines
       and Standards for the Photographic Equipment and Supplies Segment of the Photographic Point
       Source Category. EPA 440/1-80/077-a, May 1980.

USEPA, Office of Pollution Prevention.  Pollution Prevention 1991 - Progress on Reducing Industrial
       Pollutants. EPA 21P-3003, October 1991.

USEPA, Office of Solid Waste and Emergency Response. National Biannual RCRA Hazardous
       Waste Report (Based on 1989 data). EPA 530-R-92-027, February 1993.

"U.S. Fine Chemicals Demand," Chemical Week, January 6,1993, p. 34.

U.S. Industrial Outlook 1993, Chapter 23 Photographic Equipment and Supplies.

Wolfman Report on the Photographic and Imaging Industry in the United States, 1989.

Wolfman Report on the Photographic and Imaging Industry in the United States, 1992.

         Appendix 3-B



                                      Appendix 3-B

                          ALL SUGGESTED POLICY OPTIONS

Participants in the photoimaging industry expert panels selected four areas for focus in Phase 2 of
the project:

       o      Removing RCRA Barriers to Centralized Treatment and Recycling of Silver,

       o      Developing  and  Promoting   a Code  of  Management  Practices   for

       o      Continued research on Silver Speciation, Tenacity, Fate and Transport in the
              Environment, and Development of Analytical Methods; and

       o      Minimizing  Inconsistencies in Regulation,  Standards,  and Enforcement
              Among the Federal, Regional, State, and Local Governments.

These four areas are discussed in  detail in Section 33.3.  The following outline provides brief
discussions of the other policy issues and options raised during the panel meetings.

o      EPA Wffl Provide T^ammg  and Flexibility for the Use of Matt-Based Limits by POTWi

       This recommendation grew out of  the  view that use  of concentration-based
       pretreatment limits discourages water conservation, and that POTWs are reluctant
       to use mass-based limits even though authorized to do so. There were mixed views
       in the expert panel meetings about whether use of concentration-based limits is a
       problem. Some participants said  that concentration-based limits were derived from
       mass-based limits, and that permits were renewed every five years.  It was left
       unclear whether the"use of concentration-based limits in the photoprocessors' permits
       does or does not discourage  water conservation.  (A number of industry participants
       argued that it does.) Further, the reasons for POTWs' reluctance to use mass-based
       limits was not fully explored. More investigation of the true effects of concentration
       limits and the reasons for their use is needed before a determination can be made
       about the merits  of pursuing  this issue. Certainly, if use of concentration-based
       limits does discourage conservation of water, this might be a high priority area for
       further work. This idea could be  included in a Best Management Practices plan, as
       part of efforts to minimi™ inconsistencies among  regulations, or in a standardized
       permit application procedure.

o      Monitor for Ionic Silver or Change Pretreatment Limits to Addrcat Total Recoverable Silver

       This was one of many proposals for regulatory change that related to differences in
       the tenacity of different forms of silver, and industry's view that the current regulatory
       limits are unnecessarily stringent The argument for this proposal is that the limits
       imposed in the permit should be consistent with the toxicity assumptions underlying
       the limits - the same form of silver should be the basis for each.  Two factors stand
       in the way of this proposal:  (1) the lack of a reliable analytic method for ionic silver,
       and (2) uncertainty about the relationship between discharges of other forms of silver


                               Appendix 3-B

and the amounts of ionic silver that become bioavailable.  Further consideration of
such policy actions should await the results of the research now being done on silver
speciation, toxicity, and fate and transport, and development of improved analytical
methods.  This research was one of the four areas selected for emphasis by the
expert panel.

                      Appjjf^*i««i PlQOCduiC fOT
This proposal arose from views that the permit application process is too costly and
time-consuming for POTWs to implement, and for photoprocessors to go through,
given the small  size and  large number  of photoprocessors.   One approach to
streamlining the permit process might be to use the Best Management Practices now
being developed as a basis for issuing a permit, or as the condition for a streamlined
process.  The first step is to complete development of the BMP,  and for EPA to
review and possibly endorse it The BMP was another area selected for emphasis by
the expert panel.

EPA Participation in Voluntary Standard-Setting Process

The topic of standard-setting arose in two contexts. First, the NAPM coordinates
the development of voluntary standards for the industry, and invites all interested
parties (including EPA) to participate. These standards cover a wide variety of
topics, and may  in  some cases have  implications  for  the  development of
environmentally-beneficial  products and processes. EPA could begin participating
in future standards^Sevelopment efforts, to help ensure that the standards promote
rather than hinder innovative environmentally-beneficial technologies and products.
The second arena related to standards-setting  is the development  of the ISO 9000
standards.  These are standards developed by the International Organization  for
Standardization to define the elements of an effective quality system. While these
standards are voluntary, they are expected to have a significant effect on firms' ability
to compete in international markets, especially in European  markets.  Discussions
are now underway on how environmental  practice and policies will be reflected in
the standards.  One contact from Polaroid is participating in this work, and argues
that development of the ISO environmental standards should be  a  major area of
interest for EPA and for U.S. industry.

Develop Institutional Knowledge Base at EPA

This suggestion arose from industry's complaint that high staff turnover at EPA (as
well as in the state governments) makes it difficult to conduct effective conversations
about regulatory issues that affect industry. They  argue that much effort is needed
to educate EPA staff about technical, economic,  and environmental issues  in  the
industry, before useful discussions about regulatory policy are possible.  When a

                               Appendix 3-B

contact leaves, this process must begin all over again.   No specific proposal for
addressing this problem was made. However, there was a sentiment for finding ways
to increase EPA's institutional knowledge base concerning this industry - and the
durability of that knowledge base.

Develop life-Cycle Analysis Techniques

There is lack  of  agreement in  a number  of  areas about  what constitutes
environmental improvement or progress toward "sustainabitiry" in the photoimaging
sector. For example, claims about the environmental merits of a new Xerox film that
does not use silver halide are disputed, because it uses selenium - another toxic
chemical. Some industry representatives argued that treating to very low levels of
silver in effluent has perverse environmental effects because the current treatment
methods require the use of chemicals that can be more toxic than silver.   The
environmental and economic effects of centralized treatment of photoprocessing
wastes have not been analyzed. Even with the single-use camera, there are questions
about whether the high rate of recycling and the return of film along with the camera
results  in more or less solid waste disposal than  conventional  cameras.  A
cooperative life-cycle analysis of risks from photoimaging would provide the basis for
judging whether certain trends and policies promote a more sustainable industry or

RjPOTg**"^ Positive Environmental Performance

Firms  that have taken active steps  to improve their  environmental  performance
would benefit from recognition of their efforts by  regulators.  Some industry
participants  argue  that only  negative attention is available now, and that  from
industry's perspective there  is a strong disincentive  to become more  visible to
regulators.  For example, requesting help with compliance or approval to try
something innovative that has the potential to result in environmental improvements
is seen as a risky undertaking.  It is thought that inspectors and regulatory officials
do not give firms positive credit for their efforts (for example, by allowing them  some
flexibility in compliance schedules or immunity from enforcement actions to try
potentially innovative but untested methods).  Rather, "good actors" feel that they
are nonetheless singled out for attention by enforcement staff.  Several commenters
felt that a system  which provided official recognition for positive environmental
actions would give them credibility with enforcement personnel.  Such recognition
would represent a competitive advantage, and perhaps encourage more positive
relations with regulators.   No  specific suggestions  were made for how  such
recognition might be provided.

                              Appendix 3-B

Facilitate Cooperation Among Manufacturers on Recycling Programs

It was suggested that EPA help facilitate and encourage  efforts to increase the
recycling of pbotoimaging wastes.  This might include efforts from encouraging
consumers to return solid wastes  to encouraging  area-wide pickups for  silver

           Appendix 3-C



                          APPENDIX 3-C

                  Photoimaging Industry Contacts
Mr. Frederick Albrecht
Eastman Kodak Co.
Technical Associate
Dr. Anderes Andren
University of Wisconsin
Mr. Bob April
EPA, Office of Water-
Chief, Ecological Risk Assessment Branch
Mr. John Auer
Agfa Division
National Technical Manager
Mr. Guy Aydlett
Assocation of Metropolitan Sewage Agencies (AMSA)
Chair, Pretreatment & Haz. Waste Comm.
Mr. George Ayers
Envision Compliance

Mr. Hayes Bell
Eastman Kodak Co.
V.P. and Dir., Corp. H, S, & E

                          APPENDIX 3-C

                  Photoimaging Industry Contacts
Mr. Phil Bobel
Regional Water Quality Control Plant, Palo Alto,CA

Mr. Paul Borst
EPA, OSW, Characterization Assessment Division

Mr. John Bullock
Handy & Barman , Environmental Counsel
Chair of Env. Committee for IPMI
Mr. Steve Burns
ECS Refining

Ms. Diane Cameron
Natural Resources Defense Council
Effluent Guidelines Task Force
Mr. Robert Cappel
Eastman Kodak company
Director, Health and Environment Lab.
Mr. Peter Connery
Anitech Image
Dir. of ES&H

                          APPENDIX 3-C

                  Photoimaging Industry contacts
Ms. Mary Ann Curran
Mr. Tom Dagon
Eastman Kodak Company
Director, Environmental Affairs Services
Mr. Pierre Danyer
ECS Refining

Ms. Joanne Dicaro
Ontario Ministry of Envir. and Engery, Poll. Prev.
Project Officer
Mr. Thomas Dufficy
National Association of Photographic Manufacturers
Executive Vice President
Mr. Harry Fatkin
Polaroid Corporation
Director, Health, Safety, & Env. Affairs
Mr. Steve Freleigh
National Wildlife Federation
Senior Photo Editor

                          APPENDIX 3-C

                  Photoimaging Industry Contacts
Mr. Stephen Greene
Polaroid Corporation
Corporate Environmental Manager
Ms. Mini Guernica
EPA, Office of Enforcement & Compliance Assurance
Ms. Barbara Haas
National Wildlife Federation
Director, corporate Conservation Council
Mr. Greg Helms
EPA, OSW, Char, and Assess. Div., Waste ID Branch
Ms. Sussannah Hoppsvallern
American Hospital Association

Ms. Susan Johnson
Agfa, Environmental Safety Department
Sr. Applications Engineer
Mr. Greg Kearnan
Fuji Hunt Photo Chemicals
Marketing Mgr.
Mr. Ron Koch
Eckerd Drug Company
Vice President, Photoprocessing

                          APPENDIX 3-C

                  Photoimaging Industry Contacts
Mr. Peter Krause
Imaging Technology/Markets, Inc.
Partner and Vice President
Mr. Ed Lange
Department of Veteran Affairs
Silver Recovery
Mr. Amy Leaberry
EPA, Office of Water
Ms. Linda Liszewski
Eastman Kodak Co.
Corporate Environment
 Haines Lockhart
Eastman Kodak Co.
Corp. Env. Dir.
Mr. John Lounsbury
National Rountable of State Poll. Prev. Program
Executive Director
Mr. Sam Luoma
United States Geological Survey (USGS)


                          APPENDIX 3-C

                  Photoimaging Industry Contacts
Mr. Jeffrey Mathews
Eastman Kodak Co.
Env. Program Mgr.
Mr. Warren Mauzy
Manager Environment Science & Technology
Mr. Greg McCoy
Mitsubishi International Corp.
Technical Services
Ms. Nancy Neely
Fuji Photo Film
Environmental Specialist
Mr. Bob Nelson
Department of Veteran Affairs
Chief, Quality Assurance Division
Ms. Tammy Nelson
Konica USA, Inc.
Manager, Environmental Services
Dr. Norman Newman
3M Company
Division Scientist

                          APPENDIX 3-C

                  Photoimaging Industry Contacts
Mr. Brian Noble
Noble's Camera

Mr. Jim Noller
Eckerd Express Photo Ctr.
Technical Specialist
Mr. Dave Pasquini
Manager Health, Safety, and Environment
Mr. John Peterson

Mr. Richard Poduska
Eastman Kodak Company
Dir. Health,Safety,Environmental Affairs
Mr. Tom Purcell
Printer's Industries of America

Mr* David Richardson
Eastman Kodak Co.
Occupational and Health Services

                          APPENDIX 3-C

                   Photoimaging Industry Contacts
Mr. Manik Roy
Environmental Defense Fund
Pollution Prevention Specialist
Mr. Dave Salman
EPA, OAQPS, Standards Development Branch

Mr. Jim Sanders
Baltimore Academy of Natural Sciences

Mr. Bernie Saydlowski
Representative to NAPM
Mr. Eric Schaeffer
EPA, Office of Enforcement & Compliance Assurance
Deputy Director, Office of Compliance
Mr. Paul Shapiro
EPA, Office of Research and Development
Mr. Don Spring
PMA Canada
Director of Canadian Affairs

                           APPENDIX 3-C

                   Photoimaging Industry Contacts
Mr. Scott Summers
Eastman Kodak  Company
Health and  Environment Laboratory
Mr. Al Taylor
U.S. Dept.  of  V.A.
Inventory Mgmt.  Specialist
Mr. Joe Vitalis
EPA, Office of Water
Ms. Lisa Weatherford
Photo Marketing  Association,  USA
Manager, Environmental Activities
Mr. Ron Willson
Photo Marketing Association,  USA
Director, Environmental Activities
Mr. Mike Wissel
Wal-Mart Stores,  Inc.
Quality Assurance Mgr.
Mr. Richard Woolley
Regulatory Compliance  Specialist