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<>EPA
United States
Environmental Protection
Agency
Policy, Planning,
And Evaluation
(2125)
EPA230-R-94-007
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
oo
Printed on Recycled Paper
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SUSTAINABLE INDUSTRY PROJECT TEAM
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
Associate
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TABLE OF CONTENTS
EXECUTIVE SUMMARY SEE SEPARATE BOOKLET
1.0 INTRODUCTION CHAPTER 1
1.1 Historical Context 1-1
12 Project Goal 1-3
13 Report Organization 1-4
2.0 PROJECT METHODOLOGY CHAPTER!
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
3.0 PHOTOIMAGING INDUSTRY CHAPTERS
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
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INTRODUCTION
CHAPTER 1
1.1 HISTORICAL CONTEXT
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
objective:
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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.
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12 PROJECT GOAL
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.
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13 REPORT ORGANIZATION
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
further.
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PROJECT METHODOLOGY
CHAPTER2
Zl INTRODUCTION
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.
22. INITIAL RESEARCH ON INDUSTRY DECISION-MAKING
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.
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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
evaluation.
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.
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Exhibit 2-1
EXAMPLES OF CORPORATE VARIABLES INFLUENCING
FIRMS' ENVIRONMENTAL DECISIONS
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
Disclosure/Reporting
International Competitiveness
Source: National Wildlife Federation Corporate Conservation
Council "SYNERGY '92" Conference, January, 1992.
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23 TAKING AN INDUSTRY-SPECIFIC APPROACH
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
industries.
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
processes.
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.
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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.
2.4 USING A BACKWARD MAPPING ANALYTICAL METHOD
"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.
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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.
25 SELECTING THREE INDUSTRIES FOR STUDY
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.
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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.
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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
end-users.
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.
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Exhibit 2-2
KEY CHARACTERISTICS OF SELECTED INDUSTRIES
1 Total Number of
Establishments*
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
Expenditures**
Capacity Utilization Rate (1990)***
TRI Releases (1990):
I A*
L Water & POTWs
W Land & Underground
| Offsite Transfers
Total
Pollution Abatement and Control
Expenditures (&. "~
percent of total expenditures)**,"***
Purchased Fuels and Electricity as
Percent of Total Expenditures***
Future Federal Rule-Makings
Photographic
Equipment A
Supplies
(SIC 3861)
787
508 (65%)
242 (31%)
37 (4%)
77%
84%
90%
30.3
77%
29,968,807
1,153,916
115,244
6,156,799
37,394,766
$157 mill
(1.4%)
1.7%
CA: VOC
limits
RCRA:
Solvents
listings
Electroplating
& Polishing
(SIC 3471)
3,451
2,408 (70%)
1,032 (30%)
11(<1%)
7%
10%
16%
10.0
82%
11,830449
3,963,623
45,252
16,480,193
32319,617
S236 mill
(7.0%)
6.2%
CA:MACT
for surface
coating,
degreasing/
metal
cleaning
RCRA:
Solvents
listing
Plastics Materials
& Resins
(SIC 2821)
480
160 (33%)
266 (55%)
54 (11%)
20%
33%
61%
72.2
96%
102,874,467
16,27,877
4,452^26
39,730,186
163,284,856
$929 mill
(3.9%)
4.4%
CA: MACT for
numerous
individual plastics
& resins
RCRA: solid
waste legislation
affecting end-uses
of plastics
CA: Effluent
guidelines
Photographic
P_~~..._U... /CTI"1
mrf-vting (MC
738447819)"
580,000
522,000 (>90%)
58,000 (< 10%)
0
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
$45 mill
NA
CWA: Effluent
Guidelines
RCRA: Silver
listing
* 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).
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16 IDENTIFYING DRIVERS, BARRIERS, AND POSSIBLE POLICY OPTIONS
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.
2-10
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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.
2.7 BUILDING
REVIEW AND STAKEHOLDER NETWORKS
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.
2-11
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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.
2.8 NEXT STEPS
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.
2-12
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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
industry.
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
management:
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
industry.
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.
2-13
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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.
2-14
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THE PHOTOIMAGING INDUSTRY
CHAPTERS
3.1 INTRODUCTION
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.
32 APPROACH TO ANALYSIS
3.2.1
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.
3-1
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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
practices.
1 The terms "photoprocessing," "photofinishing," and "photo developing" are interchangeable.
For consistency, we use the term "photoprocessing" throughout this report
3-2
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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.
3-3
-------
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.
3-4
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Eihibit 3.2-1
CONTACTS AND SOURCES FOR THE PHOTOGRAPHIC INDUSTRY
l^cvsiflififitft
IMMaUUCIll*
Toxics Release
Inventory
Census of
Manufactures
U.S. Industrial
Outlook
Photography
Trade News
Wotfman Report
on the
Photographic
TmmmnsT TnfilMtTV
Photoproceaaing
News.
Incorporated
Industry
Annnatfnm
National Association of
Photographic
Manufacturer!
Photo Marketing
Anocution International
Silver Coalition
Association for
Information »nd Image
Manafrinrfir
rnotograpnic
Manufacturers and
Distributors Association
Printing Industries of
America
Intenutional Precious
Metals Institute
-
•
Industry
MoplimK
mCIULK^IB
C««lman Ifnrfalr Co.
Polaroid Corp.
Fuji Photo Film USA
Fuji Hunt Photographic Chemicals
Konka
3M Company
DuPont
nford
Agfa Division
Mitsubishi International Corp.
Anitec Image
Advanced Photographic
Nobk's Camera
Eckerd Drug Company
Eckerd Express Photo Center
FotoFast
Qualex, Inc.
Wal-Mart Stores, Inc.
ECS Refining
Handy & Harman
TTj^iiaLj m f%wnnli«lw^ 1 tA
fflHtfg.1 ••••iejii
\Mrmm™ i-Tf •
U^-EPA
-Office of Solid
Waste
-Office of Water
Officw o/f Pifkliiitiftti
Prevention and Toxics
-Office of Air Quality
Performance
Standard*
-Office of
Pnff»xiff»nf
-Risk Reduction
Eiujntcrinc L*^1
- Region 1
- Region 4
States
Department of
rMmmrBg
State Pollution
Roundtabk
Pate Alto POTW
Hampton, VA
Sanitation District
US. Geological
Survey
Department of
Veterans' Affairs
Ontario Ministry of
the Environment and
Energy
Noo-
Govenimeotal
f\fmm MLJjaMitJ-LJIIIUl
Enviromnental
Defense Fund
Natural Resources
Defense Counsel
Association of
Metropolitan
Sewerage Agencies
American Hospital
AttrrisTitTtl
Baltimore
Academy of
Natural 'jfifiyn
University of
Wisconsin
^™
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.
3-5
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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
Kodak
Company
Fujifiim USA
KonicaUSA
3M Printing and
Publishing Division
DuPont
Qualex, Inc.
Panel Meeting *2
February 25,1994
National Association of Photographic
Manufacturers
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.
3-6
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33 MAJOR FINDINGS
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
COMPOSITION OF SIC 3861 PRODUCTS
(1987 Census of Manufacture*)
Product
Still cameras (hand-held)
Still picture commercial type
finishing equipment:
processing equipment for
film
processing equipment for
paper
continuous printing _
machines
all other (incl. developing
machines, print washers &
dryers)
Other still picture equipment
Photocopying equipment
Number of Companiet with
Shipment! of
$100,000+
4
13
8
2
5
NA
NA
Value of SKifHnente
(motions)
324.4
124.8
NA
73.9
NA
472.2
5,982^
(continued)
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.
3-7
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Eriubit 33-1
COMPOSITION OF SIC 3861 PRODUCTS
I1OB-I !"...•.« *f V «n,«m**n«M^
T» i .1 H H*
rroouci
Motion picture processing
equipment
Other motion picture
equipment
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
Total
Source: 1967 Census of Manufacti
* Included with value of shipme
Industry representatives maint
1967 Census of Manufacturer!
Number of Companies with
SllMliMtB «f
$100400+
8
NA
NA
5
NA
6
NA
20
24+
9
NA
719"
Value of Shqnnente
(mflbooJ)
24.2
164.4
382.9
1,3573
3,187.9
*
U47.8
538.2
686.6
*
757.0
153243
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
3-8
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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
1987 INDUSTRY STATISTICS BY PRIMARY
PRODUCT CLASS SPECIALIZATION (SIC 3861)
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
Brtabfeh-
ments
64
11
30
21
21
3
42
28
4
787
Vahie of Shipments
(minion $)
Total
8213
(D)
237.4
287.8
7,2643
(D)
1,521.5
622.5
(D)
19,240.5
Average/
Estab.
12.8
NA
7.9
13.7
345.9
NA
36.2
222
NA
24.4
New Capital
Expenditures
(million $)
27.6
(D)
3.7
6.0
426.6
(D)
55.3
18.3
(D)
681.0
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.
3-9
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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.
Phot
01
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.
3-10
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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
period.
Exhibit 33-3
ESTIMATED MARKET SHARE OF RETAIL Photoprocening
(Share of Rob Proceoed, 1991)
Retail Channel
Drugstore
Stand-Atone Minilab
Camera Store
Discount/Mass
Merchandiser
Supermarket
Mail Order -
Other
Total
Prooeaed by
Wholesale,
Captive, or
MaO Order Labs
MflL
Rob
148.5
4.1
25.0
120.4
82.5
58.6
25J
464.4
%
21.1%
0.6%
3.6%
17.1%
11.8%
83%
3.6%
66.1%
Processed by
Retail Minilab
p/ni Si II M nf
MQL
Rob
28.7
116.0
48.0
17.6
14.8
0.0
12.6
237.7
%
4.1%
16.5%
6.8%
2.5%
2.1%
0.0%
1.8%
33.9%
Total
MO.
Rob
1772
120.0
73.0
138.0
97.4
58.6
38.0
702.1
%
252%
17.1%
10.4%
19.6%
13.9%
85%
5.4%
100.0%
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
achieve.
3-11
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The characteristics of the various types of labs are shown in Exhibit 33-4.
Exhibit 33-4
CHARACTERISTICS OF AMATEUR FILM PROCESSING LABS7
Lab Type
Minilabs
Wholesale Labs (Drug
Stores, Grocery Stores)
Mail Order Labs
Price
Two to Three Times
Higher than Others
Medium
Low
Quality
Lower than Others
Equal to Minilabs
High
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.
3-12
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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.
3-13
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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.
3-14
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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.
3-15
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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
recycled.
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).
3-16
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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
SILVER RECOVERY EQUIPMENT
Technology
Electrolytic
Metallic
Replacement
Ion Exchange
1 Systems
Chemical
Precipitation
Reverse
Osmosis
Evaporation
and
Distillation
EffectiveneB
Removes 90
percent from silver-
rich solutions
Removes 90
percent from silver-
rich solutions
Removes 90
percent from wash
waters
Removes 99
percent from wash
waters
Concentrates silver-
rich solution 40-60
percent
Advantages
No additional
chemicals released;
Equipment
reusable
95 percent removal
with two cartridges
Reduces water
volume
Reduces water
volume
Disadvantages
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
3-17
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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
COMMERCIAL PHOTOFINISHER ENVIRONMENTAL CONTROLS (1991)
Percent Operating Silver
Recovery Systems
Type of Silver Recovery
Systems Used:
. electrolytic recovery
. steel-wool canister
. ion exchange
evaporation/distillation
Percent that Recycle
Water
Percent that Regenerate
Chemistry
Percent of Firms Visited
or Contacted by State or
Local Water Authority in
1991
AB
Specialty
Retailers
ConbBed
80.7%
45,8%
3.6%
2.4%
7.8%
25.8%
Stove with
MiniUb
963%
82.6%
48.9%
0.9%
0.9%
10,2%
19.6%
13.1%
Stand-Aloae
Mmflib
89.5%
81.0%
43.9%
63%
03%
7.2%
28.6%
25.4%
Mailorder,
Wholesale,
and Captive
Late
100.0%
94.7%
57.9%
20.8%
83%
40.9%
86.4%
733%
Portrait
Studio
YTavwM
66.7%
632%
36.8%
2JO%
4.1%
10.0%
2X6%
25.0%
Source: 1991-1992 PMA Industry Trends Report, pp. 69-70.
33.2 Driven
ners
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
appropriate).
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
3-18
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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.
below.
We discuss economic, technology, and regulatory drivers and barriers in separate sections
Economics
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.
3-19
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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
developing.
3-20
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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.
Technology
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
drivers.
Regulations
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
conservation.
o Regulation of silver-bearing wastes under RCRA discourages recycling of
silver.
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.
3-21
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... 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
plants.
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."
3-22
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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.
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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
dilution.
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.
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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.
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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
regulation.
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
waste.
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.
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0
o
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
requirements.
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.
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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
requirements.
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.
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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.
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Eilubit 33-7
POSSIBLE POLICY OPTIONS: INITIAL LIST
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
Recovery
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
Photoprocessors;
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.
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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
sustainability,
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
stakeholders.
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
effects.
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.
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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.
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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,
including:
(1) Education and technical assistance, to support improved compliance with
standards;
(2) Assistance to POTWs and other regulators in understanding silver sources;
and
(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.
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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
sources.
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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.
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Appendix 3-A
BIBLIOGRAPHY FOR THE PHOTOIMAGING INDUSTRY
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Appendix 3-A
BIBLIOGRAPHY FOR THE PHOTOIMAGING INDUSTRY
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,
Mississippi.
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
3-A-l
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Appendix 3-A
(continued)
BIBLIOGRAPHY FOR THE PHOTOIMAGING INDUSTRY
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>
1.
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.
3-A-2
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Appendix 3-B
ALL SUGGESTED POLICY OPTIONS
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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
Photoprocessors;
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
3-B-l
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Appendix 3-B
(continued)
ALL SUGGESTED POLICY OPTIONS
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
3-B-2
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Appendix 3-B
(continued)
AIJL SUGGESTED POI1CY OPTIONS
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
not.
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.
3-B-3
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Appendix 3-B
(continued)
ALL SUGGESTED POLICY OPTIONS
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
recycling.
3-B-4
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Appendix 3-C
PHOTOIMAGING INDUSTOY CONTACTS
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APPENDIX 3-C
Photoimaging Industry Contacts
Mr. Frederick Albrecht
Eastman Kodak Co.
Technical Associate
716-477-1119
Dr. Anderes Andren
University of Wisconsin
Ph.D.
608-262-0905
Mr. Bob April
EPA, Office of Water-
Chief, Ecological Risk Assessment Branch
202-260-6322
Mr. John Auer
Agfa Division
National Technical Manager
201-440-2500
Mr. Guy Aydlett
Assocation of Metropolitan Sewage Agencies (AMSA)
Chair, Pretreatment & Haz. Waste Comm.
804-460-2261
Mr. George Ayers
Envision Compliance
416-790-6845
Mr. Hayes Bell
Eastman Kodak Co.
V.P. and Dir., Corp. H, S, & E
716-722-5036
3-C-l
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APPENDIX 3-C
Photoimaging Industry Contacts
Mr. Phil Bobel
Regional Water Quality Control Plant, Palo Alto,CA
415-329-2598
Mr. Paul Borst
EPA, OSW, Characterization Assessment Division
202-260-6721
Mr. John Bullock
Handy & Barman , Environmental Counsel
Chair of Env. Committee for IPMI
203-757-9231
Mr. Steve Burns
ECS Refining
910-545-0640
Ms. Diane Cameron
Natural Resources Defense Council
Effluent Guidelines Task Force
202-624-9347
Mr. Robert Cappel
Eastman Kodak company
Director, Health and Environment Lab.
716-722-1619
Mr. Peter Connery
Anitech Image
Dir. of ES&H
607-774-3424
3-C-2
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APPENDIX 3-C
Photoimaging Industry contacts
Ms. Mary Ann Curran
EPA RREL
Mr. Tom Dagon
Eastman Kodak Company
Director, Environmental Affairs Services
716-722-4489
Mr. Pierre Danyer
ECS Refining
408-988-4386
Ms. Joanne Dicaro
Ontario Ministry of Envir. and Engery, Poll. Prev.
Project Officer
416-314-3896
Mr. Thomas Dufficy
National Association of Photographic Manufacturers
Executive Vice President
914-698-7603
Mr. Harry Fatkin
Polaroid Corporation
Director, Health, Safety, & Env. Affairs
Mr. Steve Freleigh
National Wildlife Federation
Senior Photo Editor
3-C-3
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APPENDIX 3-C
Photoimaging Industry Contacts
Mr. Stephen Greene
Polaroid Corporation
Corporate Environmental Manager
617-577-4106
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
202-260-6721
Ms. Sussannah Hoppsvallern
American Hospital Association
312-280-5226
Ms. Susan Johnson
Agfa, Environmental Safety Department
Sr. Applications Engineer
Mr. Greg Kearnan
Fuji Hunt Photo Chemicals
Marketing Mgr.
201-967-7849
Mr. Ron Koch
Eckerd Drug Company
Vice President, Photoprocessing
813-399-6306
J-C-4
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APPENDIX 3-C
Photoimaging Industry Contacts
Mr. Peter Krause
Imaging Technology/Markets, Inc.
Partner and Vice President
914-276-2377
Mr. Ed Lange
Department of Veteran Affairs
Silver Recovery
Mr. Amy Leaberry
EPA, Office of Water
Ms. Linda Liszewski
Eastman Kodak Co.
Corporate Environment
716-477-1182
Haines Lockhart
Eastman Kodak Co.
Corp. Env. Dir.
716-722-2877
Mr. John Lounsbury
National Rountable of State Poll. Prev. Program
Executive Director
301-495-9278
Mr. Sam Luoma
United States Geological Survey (USGS)
415-853-8300
3-C-5
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APPENDIX 3-C
Photoimaging Industry Contacts
Mr. Jeffrey Mathews
Eastman Kodak Co.
Env. Program Mgr.
716-722-0692
Mr. Warren Mauzy
Ilford
Manager Environment Science & Technology
201-265-6000
Mr. Greg McCoy
Mitsubishi International Corp.
Technical Services
212-605-2352
Ms. Nancy Neely
Fuji Photo Film
Environmental Specialist
914-789-8100
Mr. Bob Nelson
Department of Veteran Affairs
Chief, Quality Assurance Division
908-707-4339
Ms. Tammy Nelson
Konica USA, Inc.
Manager, Environmental Services
407-696-5111
Dr. Norman Newman
3M Company
Division Scientist
612-733-7120
3-C-6
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APPENDIX 3-C
Photoimaging Industry Contacts
Mr. Brian Noble
Noble's Camera
617-749-5565
Mr. Jim Noller
Eckerd Express Photo Ctr.
Technical Specialist
813-399-6350
Mr. Dave Pasquini
Konica
Manager Health, Safety, and Environment
919-449-8000
Mr. John Peterson
FotoFast
303-534-4700
Mr. Richard Poduska
Eastman Kodak Company
Dir. Health,Safety,Environmental Affairs
716-722-0693
Mr. Tom Purcell
Printer's Industries of America
703-519-8100
Mr* David Richardson
Eastman Kodak Co.
Occupational and Health Services
716-722-5200
3-C-7
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APPENDIX 3-C
Photoimaging Industry Contacts
Mr. Manik Roy
Environmental Defense Fund
Pollution Prevention Specialist
202-387-3500
Mr. Dave Salman
EPA, OAQPS, Standards Development Branch
919-541-0859
Mr. Jim Sanders
Baltimore Academy of Natural Sciences
301-274-3134
Mr. Bernie Saydlowski
DuPont
Representative to NAPM
302-992-3519
Mr. Eric Schaeffer
EPA, Office of Enforcement & Compliance Assurance
Deputy Director, Office of Compliance
202-260-8636
Mr. Paul Shapiro
EPA, Office of Research and Development
Mr. Don Spring
PMA Canada
Director of Canadian Affairs
705-789-8885
3-C-8
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APPENDIX 3-C
Photoimaging Industry Contacts
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Mr. Scott Summers
Eastman Kodak Company
Health and Environment Laboratory
716-722-1311
Mr. Al Taylor
U.S. Dept. of V.A.
Inventory Mgmt. Specialist
202-233-3759
Mr. Joe Vitalis
EPA, Office of Water
Ms. Lisa Weatherford
Photo Marketing Association, USA
Manager, Environmental Activities
800-762-9287
Mr. Ron Willson
Photo Marketing Association, USA
Director, Environmental Activities
800-762-9287
Mr. Mike Wissel
Wal-Mart Stores, Inc.
Quality Assurance Mgr.
501-277-6442
Mr. Richard Woolley
Qualex
Regulatory Compliance Specialist
919-382-6478
3-C-9
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