Industrial Environmental Management;

                      An Annotated Bibliography of Practical Sources
                                      Second Edition
                                        August 1989
                                       Prepared by:

                                      Todd C.  Edwards

                      United States Environmental Protection Agency
                           Regulatory Innovations Staff (PM-223)
                                   Washington, DC 20460
                                     WASHINGTON, D£Z0460


                 This  report  was  prepared  by  Todd  C.   Edwards,  doctoral
            candidate in  the psychology program  of the  Claremont Graduate
            School,   under  the  summer  employment  program  of  the  U.  S.
            Environmental   Protection Agency.     The  report  reflects  the
            findings  and conclusions  of  the author and not necessarily those
            of EPA or any other government entity.   Mention of  any company
            names,  products,   or   processes  does   not  constitute   1PA


  Annotated Bibliorahy on Industrial Environmental Management
I.  Purpose

     This bibliography identifies selected published or available
written materials relevant to  the design  and effective operation
of  industrial  environmental  compliance  and   risk  management
programs.    Materials  were  chosen  for  emphasis  on  practical
environmental  management  issues  from  the  perspective  of  the
regulated  organization  as  opposed  to that of  the  regulator.
Selections  offer  a  range  of  viewpoints  and  should  not  be
construed as prescriptive.

II.  Content And Format

     This  bibliography  contains  a  variety  of  materials —
including journal articles, academic theses, reports, books, and
conference  proceedings — and  is  organized  into  the  following
categories :

III.  Comments Or Questions

     Any  suggestions  regarding  future  editions  or  questions
regarding  this  bibliography can be directed to  the Regulatory
Innovations  Staff,  U.S.  EPA   (PM-223) , Washington,  DC  20460 or
(202) 382-2726.

American Public Power Association  (1988).  A Manual  For Electric
     Utilities;   Environmental  Compliance.     Available   from:
     American  Public  Power  Association,   2301  M  Street,  NW,
     Washington,  DC 20037.

     This  manual  is intended  as a  practical tool  for electric
utilities  of  all  sizes  to  use  in assessing,  attaining, and
maintaining  compliance  with  federal   environmental   laws and
regulations.  It is designed primarily as a desktop reference for
line personnel who run the utility on a  day-to-day basis.   It  is
also  useful as  a  reference  for  management  in  setting  up  an
environmental compliance program.
Andersen,  G.  H.,  Smith,  A.  C.,   &  Daigle,  L.  T.  (1989).    An
     approach  to  occupational  health  risk  management  for  a
     diversified international  corporation.   American Industrial
     Hygiene Association Journal.  5fi(4), pp. 224-228.

     A risk management program is presented which is effective in
handling occupational health risks in a diversified multinational
corporation.   The  three-step program  of plant review involves
initial  assessment visits designed  to determine  the compliance
status and degree of  sophistication of  the  occupational health
program.   These assessments are followed by more formal assurance
reviews   which  include  consultation,   training,  and  program
support.    Finally,  formal surveillance reviews  p.re  conducted to
verify compliance  with respect to company  and regulatory agency
requirements.    Each   type   of  review  requires  planning  and
adherence to a standardized process to allow comparability of the
information  generated.    Critical  elements  of  this  approach
include  senior  management   support,   knowledge  of  applicable
regulations, and communication  of results.   Reporting is done on
several   levels   and   is  designed  to   communicate  relevant
information to management from line supervisors to  the board of

Arthur  D.  Little,   Inc.   (1981).    A  Survey  of  Environmental
     fanning.  Available from:  Arthur D.  Little Inc.,  Center  for
     Environmental Assurance,  Acorn Park,  Cambridge,  MA  02140-

     This   report  characterizes  the  diversity   of   practices
identified in a  16 company survey,  and  emphasizes  those planning
features  found to be exemplary, innovative, or  interesting.   It
identifies  six  characteristics   of   environmental  planning
activities performed by the "cutting-edge"  companies:   1.)  long-
range  planning   horizons;    2.) planning for  risk as well  as
compliance;    3.)   a  clear and   direct  linkage  between  the
environmental, safety, and health  planning process and the CEO;
4.)  strong interaction  between corporate  and  division  staffs;
5.}  a  formal channel  through which the  corporate environmental
group contributes to the'strategic planning process;  6.) driving
forces which  extend  beyond compliance  to social responsibility,
preventative  environmental  policy,   and   a   recognition  that
economic benefits can be realized.
Arthur D. Little, Inc. (1988).   Environmentalf  Health, and Safety
     Policies;  Current  practices and  future trends.   Available
     from:  Arthur  D.  Little,   Inc.,  Center  for  Environmental
     Assurance, Acorn Park, Cambridge, MA 02140-2390.

     This  is  a  survey  of environmental,  health,  and  safety
policies  of   28  major   corporations.     T*iis  information  was
augmented by a general knowledge of the policies in place at more
than 50 other  companies.   The goal  of this report was to analyze
these policies  in terms  of their development and implementation.
A diverse range of companies were represented in order to present
findings about  the range  of policies  as  well as some conclusions
about their commonalities.

Arthur D.  Little,  Inc.  (1989).   Developing  a  Corporate Approach1
     to  Environmental,   Health,   andSafety  Crisis  Management.
     Available  from:     Arthur   D.   Little,   Inc.,   Center  for
     Environmental  Assurance,  Acorn  Park,  Cambridge, MA  02140-

     This  report builds  a case for companies to establish crisis
management  units,   noting  that   only 38%  of  companies in  the
Fortune 1000 have  such units in  place.   The primary objective of
crisis management  planning is to set up standards  for the more
routine aspects  of response in  order to free  decision makers to
focus  on  the  tougher,   unique  aspects  of a  crisis  should  one
occur.  A second objective  is to isolate crisis management from
management of the company's ongoing business.
Barkenbus,  J.  N.,  &  Barkenbus,  B. D.  (July,  1989).   Industrial
     response  to  a  waste  minimization  survey  in  Tennessee.
     Journal of  the Air Pollution Control Association. ££(7)f pp.

     A survey of large Tennessee waste generators was carried out
in  the summer  of 1987.   It  found that  industry has  begun to
implement  a number of waste minimization  practices and that the
overall  attitude  of generators  toward  waste  mimimization was
positive.   There were some statistically significant differences
in  the survey  responses  from  generators of  different volumes.
These  differences are  important and  indicate  that  among  large
waste generators, the larger have taken more significant steps to
date than  have smaller waste generators.

          Boyer,   B.,   Meidinger,  E.,  Thomas,  J.,  &  Singh,   J.   (1987).
               "Theoretical  Perspectives  On  Environmental  Compliance."
               Available  from:  Regulatory  Innovations  staff   (PM-223),
               Office  of  Policy,  Planning,   &  Evaluation,  United States
               Environmental Protection Agency, Washington,  DC 20460.

               The purpose  of  this  paper was  to  identify how  corporate
          compliance behavior may be  affected by factors apart from those
          associated   with  deterrence  theory.     The   limitations  of
          deterrence theory  are discussed,  most notably,  that it  assumes
          all corporate  decisions are made  through  an objective  process
          which  weighs  economic  costs   and benefits  of   all  available
          options.  This view relegates the social  context of regulation to
          the background.   Internal  (e.g., corporate  culture) and external
          (e.g.,  social networks)  social  influences on corporate compliance
          are discussed.
          Brody,  M.  (November 24,  1986).    Listen  to .your, whistleblower.
               Fortune.  pp.  77-78.

f   ,           This article advocates  the  use of a company 'ombudsman'  to
    '      deal with employee complaints and concerns.   This ombudsman would
          be a top  manager  whose sole  function has become troubleshooting
          for the  purpose of  avoiding major organizational and  publicity
          problems.   Although the ombudsman  function  discussed here  is  a
          general  one,   this   concept  could  also be  readily  applied  to
          potential environmental problems.

Brunner, D. L.,  Miller,  W., Stockholm, N.  (1981).   corporations'
     and theEnvironment; Hov Should DecisionsBe Made?   Stanford
     University,  Graduate  School  of  Business:  Committee  on
     Corporate Responsibility.

     Investigates  how businesses in  the  1980s can  deal  most
effectively with difficult economic trade-offs and make decisions
incorporating concern for the environment with a goal of economic
growth.    The  authors  provide  an  overview of approaches  for
addressing the  environmental  dilemmas  businesses face today,  not
only in terms  of their  performance in the past, but  in terms of
their  ability  to function  effectively in the 1980s  and beyond.
Specifically  the  book   addresses:    1.)   systems in  place  for
dealing with   environmental problems  and the  critical role  of
government;   2.) environmental issues facing corporate decision
makers;   3.)  the  future  of environmental decision-making;   and
4.}  the  role  and responsibilities  of  the individual in  the
decision-making process.
Campbell, M.  E.,  & Glenn, W.  M.  (1982).  Profit  From Pollution
     Prevention.  Available  from:  Pollution  Probe Foundation,  12  """"y
     Madison Avenue, Toronto, Ontario, Canada M5R 2S1.           i
                                                                  >v. •
     A  compilation  of industrial  waste reduction  and recycling
methodologies.   Documents hundreds  of success stories  of firms
that have turned waste products  into financial assets.  The book
is divided  into the  following groupings:    1.) waste management
strategy  information;   2.)   pollution prevention  opportunities
(e.g., dry cleaning, electroplating, fly ash, sulphur, paints and
coverings);  and     3.)   technology  descriptions  (e.g.,  waste
recovery   technologies,   waste  treatment  and  disposal
Caris,  C.  S.  (February,  1980).   Environmental  management:  New
     paradigm  for  old  commitments.    Resource  Management  and
     Optimization. 1(1), pp. 77-87.

     Various  aspects of  environmental  management  are explored:
decision-making,  impact  assessment,  cost-benefit analysis, tools
and techniques of management, and implementation of environmental


          DiMento,  J.  F.  (1986).   Environmental Law and American Business-
               Dilemmas of compliance.  New YorJc, NY: Plenum Press.

               This book aims to address the question:  "What policies will
          achieve  the  goal   of  persuading   business   to  comply  with
          environmental  law?"     This  approach  pays  attention  to  the
          development  of regulations  and does  not simply treat  rules as
          inherently deserving of business obedience.  Based on a review of
          the  literature  in many  fields  and on the  results of interviews
          with  corporate managers,  regulatory  officials,  and  members of
          environmental organizations,  the  book makes many recommendations
          for improving compliance.
          DiMento, j. F.  (1989) .  Can social science explain organizational
               noncompliance  with environmental  law?   Journal  of Social
               Issues. H(l) , pp. 109-132.
  ABSTRACT:                                 ....
     Constructs a theoretical  framework  of factors which promote
organizational compliance with environmental laws.  Attributes of
enforcement (e.g., perception  of  fairness),  communication (e.g.,
continuity),   and   the  actors   involved   (e.g.,   the  firm's
perception of the regulator) are  all  discussed as they relate to
compliance.  The author concludes that, "While single factors can
be  influential,  only  in  the  narrowest  band  of  cases will  one
psychological,  organizational,   or   economic  variable  explain
          Ermann,   M.   D.,   &  R.  J.   Lundman  (1987).     Corporate  and
               Governmental  Compliance.    New York, NY:  Oxford University

               This book, through a collection of articles, shows how large
          organizations  may  become  deviant.    Some   articles trace  the
          origins of corporate and governmental deviance, and others detail
          the patterns of deviant actions  such as the knowing release of an
          unsafe product; price  fixing;  and police corruption.  Concluding
          articles examine societal reactions to organizational deviance.

Fernandez, L. (October 2, 1984).   "More Than A  Passing Idea: The1
     Future  Of  Environmental  Cooperation."     In  proceedings,
     Second   National   Conference  on   Environmental   Dispute
     Resolution.   Available from: Conservation  Foundation,  1717
     Massachusetts Ave. NW,  Washington, DC 20036, pp. 1-9.

     Offers  three proposals  to  strengthen  cooperation  between
industry and environmental  groups.   They  include:   1.) establish
a  forum for  senior  industry and  environmental leaders  to  meet
regularly  but  informally;   2.) get  a  better fix on the  funding
needs of environmental mediators,  on the niches they are  filling,
and on  the mediation  demands they  now are  unable to meet; and
3.) work harder in order to make cooperation the preferred method
of problem solving.
Friedman, F.  B.  (July,  1983).   60s activism and  80s realities-
     We've come a long way.  The Environmental Forum, pp. 8-11.

     The  commitment  by  industry  to  a  strong  environmental
program, according to the author, will build credibility with the   \
government.     Contends  that  management's  commitment  must  bei,
carried  throughout  the  corporation and  corporate environmental   '
protection   staff  must  have   responsibility  for  providing
leadership  in  carrying  out  the  strong  environmental  policy
throughout  the  corporation.   Concludes that today,  experienced
corporate representatives  and corporations  recognize that  good
environmental policy is also good economics.


          Friedman,   F.   B.   (February,   1985).     Managing  and  resolving
               corporate environmental  issues.    The  Environmental Forum.
               pp.  28-32.

               Suggests  that the  importance of environmental, health, and
          safety management  within the  corporation  should  be  reinforced
          through recognition  at  the  highest corporate  levels.     These
          functions   can be  effective  as  the  equivalent  of  a   "profit
          center,"  while ensuring environmental protection.   The  methods
          for achieving  these  goals,  as well  as  the challenges,  involve:
          instituting systems to develop an inventory  of materials  disposed
          of into any media  and then establishing goals for  the reduction
          of those  pollutants; efficiently and  effectively dealing  with
          proposed  legislation and regulations; and reducing operating and
          administrative costs  through  a  systems  approach and  long-range
          planning.                 .
Friedman,  F.  B.   (1988).    Practical  Guide. to  Environmental
     Management.   Available  from:  Environmental  Law Institute,
     1616 P Street NW, Suite 200, Washington, DC 20036.

     Written  from industry's perspective  by the  Vice President
for  Health,  Environment,  and  Safety  of  Occidental  Petroleum
Corporation, this is the first comprehensive guide on the subject
of  industrial  environmental management.   It provides historical
and future perspectives on the field, guidelines for implementing
and conducting programs,  and recommendations  for environmental
managers  on  how  to  deal  with  lawyers,  engineers,  business
managers,  consultants,   federal  and  state  agencies,  citizen
groups, the press, and the public.
          Fromm,  C.  H.,  &  Callahan,  M.  S.,  Freeman, H.  M., Drabkin,  M.
               (September 14,  1987).    Succeeding  at waste  minimization.
               Chemical  Engineering, pp,  91-94.

               This  article  describes  a  step-by-step  auditing  procedure
          which  may  be  used  by  industrial  environmental  managers  and
          engineers  to  decide what waste minimization  options are  best
          given a particular operation.


Glauthier,  T.  J.,  &  Fox,  J.  R.  (July,  1983).   Industry and
     environmental  regulation:  What   are  top  management's
     concerns?  What is it doing?  Environmental Analystf  pp. 11,

     Reviews  survey  of  100  top corporate  officers  of  major
corporations  on two  topics:    1.)  their major concerns  about
environmental  regulations;  and   2.) the  action being taken  to
address those  concerns.   The  issue  about which more  executives
were "very  concerned"  was the  reasonableness  or scientific basis
of regulations.  Other concerns  were the costs  of  compliance and
states  adopting their own  regulations.   The most  frequently
suggested   actions  were:  work   cooperatively   with   regulatory
agencies;  protect   against surprises  by  working  internally  to
anticipate  regulatory  problems;  and make  organizational  changes
to align  responsibility .'with  decision-making on  regulatory and
compliance  issues.
Gray,  B.   (1985).    Conditions  facilitating  interorganizational
     collaboration.  Human Relations. 3_§.(10),  pp. 911-936.

     The basic  premise of this paper is that there  is a growing
need  to  promote  collaborative problem-solving across  various
sectors of society,  i.e.,  among business,  government,  labor,  and
communities.  Several circumstances have been identified in which
collaborative  problem-solving  among  stockholders is  warranted:
1.)  the  existence of  problems which are bigger than  any simple
organization  acting   alone   can  solve;     2.)   limitations  of
traditional  adversarial methods of resolving conflicts;  and
3.)   increasing  turbulence   which  occurs   when  competing
organizations, acting independently in diverse directions, create
unanticipated  and  dissonant  consequences  for  themselves  and
others.  Organizing  such collaborative efforts requires focusing
on acts of interdependencies which link various stakeholders.


        Gray-Gricar, B.  (1983).   A preliminary theory of compliance with
             OSHA  regulation.   Research  in  Corporate Social Performance
             and Policy. 5, pp. 121-141.

             In  this paper, the  author examines organizational response
        to  Federal regulation  by analyzing the responses of 34 foundries
        to  the Occupational Safety and Health Administration (OSHA).  The
        responses  were  assumed to be a function of the ideological views
        of  top management,  the size of the firm, regulatory uncertainty,
        dependence  on   regulatory  agencies,   and  "boundary  spanning"
        activities aimed  at  keeping up  with  economic,  technological,
        political,  social,  and  regulatory changes.   It was  found that
        ideology,  size  of firm,  and  boundary  spanning were most closely
        associated with company response to OSHA.   Four classifications
        of  adaptive responses  to regulation were  developed:  technical,
        informational, administrative, and environmental management.
Greanias,  G.   C.,  &  Windsor,  D.   (Eds.,  1982}..  The  Changing
     Boardroom - Making Policy and Profits in an Aae of Corporate
     Citizenship.  Houston, TX: Gulf Publishing Company.

     This  book  resulted  from  presentations  at  a  conference
entitled,  "Corporate  Governance in the  '80s" which was  held at
the  Jesse  H.  Jones  Graduate  School  of  Administration,  Rice
University  on   August  8,   1980.     Presenters  were  top-level
executives and  board members  of major corporations.   The major
theme  which  runs  throughout these writings  is that  because of
increasing public scrutiny, corporations must change the way that
they operate so that public welfare becomes a top priority.


Greer, c. R., &  K.  R.  Downey (1982).   Industrial compliance with1
     social  legislation:   Investigation of  decision rationales.
     Academy of Management Review. 2, pp. 488-498.

     To  determine  whether  compliance  decisions are  based  on
normative or calculative criteria and whether such rationales are
individual or organizational in nature, the authors developed a
model  of compliance behavior.    Calculative criteria are  those
that  involve pragmatic responses (such  as net  monetary  benefit)
to a particular situation.  Normative decision criteria are those
that  employ  supraordinate  values in  evaluating the utility  of
compliance.  Normative criteria might call for compliance because
"it  is the  law".    The study  concludes that,  depending on the
legislation, compliance {behavior.is affected by  at  least one of
eight  variables  of normative  and  calculative  behavior.    The
authors state that if companies  (upper management) are to control
the compliance behavior of their members,  they  need  to aim their
compliance efforts at appropriate salient forces.
Hawkins, A. E.  (1989).   Back to basics: Successful environmental
     compliance  inspections.   Pollution Engineering.  21(1),  pp.
     118, 120.

     Undergoing an environmental compliance inspection by a state
or  federal agency  can  be  very  traumatic, but  the consequences
need not be  feareu  if a  number of  steps are taken  before  and
during the  inspection.   Advance preparation should remove nearly
all of  the potential surprises, and  assure  that your company or
business  is not exposed  to serious  legal risk  because of non-
compliance with environmental laws, rules, and regulations.
Hirschorn, J.  S.  (April, 1988).  Cutting production of hazardous
     waste.  Technology  Review. 9.1(3) , pp. 52-61.           :

     The author discusses the advantages of preventing industrial
waste  as  opposed to  dealing with  it after it  occurs.   Namely:
"If less  waste is generated, it  is cheaper to manage, and there
will  be  fewer failures handling  it.   A  commitment  to waste
reduction  is  also  likely  to  contribute  to  improved,  safer
operations,  and  thus  reduce  the  chance  of  accidents  such as
Bhopal" (p.  54) .  The  author also discusses ways to reduce waste
as well as some of the inherent obstacles.     :-


          "How To  Limit The Rising Costs  Of Strict Regulation."  Article
               appearing in Chemical Week.  January 21,  1981,  pp.  36-40.

               Discusses  the  management  of corporate  regulatory affairs
          programs and  describes  how  companies can  save money by closely
          monitoring physical factors  such as  plant emission  levels while
          diligently tracking the formulation of new rules enabling them to
          quickly  spot  new opportunities  for  savings.    Several  corporate
          approaches including DuPont,  Monsanto, and Dow are  highlighted as
          examples.    Describes  the   use  of   computer-based  information
          systems to aid in the management of regulatory affairs programs.
          Huisingh,  D., Martin, L., Hilger,  H.,  & Seldman, N. (1985).
               "Proven Profits From Pollution Prevention."   Available from:
               Institute  for  Local  Self-Reliance,  2425  18th  Street  NW,
               Washington, DC 20009.

            ABSTRACT:                                 . .
               A  compendium  of  case   studies  which  illustrate  that
          industrial  leaders  are  developing and implementing  innovative
 _        ways to reduce  their production of wastes of all types and,  at
{   ,      the same  time,  are increasing their  profits.  The case studies
          also  present  evidence  that  found   industrial management  of
          resources  results  in  simultaneous   economic   and   ecological
          Hunt,  T.  E.  (March,  1987).    Tools to  deter violators.
              Journal.  11(2),  pp.  10-12.

              The latest tools at  EPA's disposal  for preventing violations
          (e.g.,  environmental  auditing),  streamlining enforcement casework
          (e.g.,  alternative dispute resolution techniques),  and maximizing
          deterrent impact (e.g., contractor listing)  are described.


Kagan, R. A., and Scholz, J. T. (1984).  "The 'Criminology of the1
     Corporation' and Regulatory  Enforcement  Strategies".   In
     K.  Hawkins,  &  J.  Thomas  (Eds.),  Enforcing  Regulation.
     Boston, MA: Kluwer-Nijhoff Publishing, pp.  67-95.

     In this book chapter the authors review three different ways
in which corporate behavior  is  often conceived:   1.)  as amoral
economic  calculator;    2.)  as political  citizen;   and   3.)  as
organizationally  incompetent.   The implications  for enforcement
of  each perspective  are discussed  as well  as  each approach's
strengths  and  weaknesses.     The authors conclude  that:  "One
implication  of  the  diverse  sources  of  noncompliance  is  that
indiscriminate  reliance  on  any single theory of noncompliance is
likely  to be  wrong,  and  when  translated  into an  enforcement
strategy, it is likely to be counterproductive" (p. 85).
Kaminski,  J.  A.  (August  &  September,  1988).    Hazardous waste
     minimization within the Department of Defense  (Parts A & B).
     Journal  of the Air Pollution  Control  Association. H.(8&9),
     pp. 1042-1050, 1174-1185.

     This  article  is a series  of  representative case studies of
Department  of   Defense hazardous  waste  minimization.    Each
Military  Department and  the  Defense Logistics  Agency describe
actual accomplishments.  Areas  covered range from production line
modification  to product specification change.   These efforts are
part  of  a Capartment  of Defense  plan  composed  of  individual
programs  executed  independently by  each  military  service  and
defense  agency.  Part  A deals with  Department of Defense waste
minimization  efforts  in vehicle  repair operations,   explosives
manufacturing,  and abrasive blasting processes.   Part B covers
shipboard  mercury wastes,  industrial chemical  control, solvent
reclamation,  and hazardous property sales efforts.


Leemann, J. E. (June, 1988).  Waste minimization in the  petroleum
     industry.  Journal of the Air Pollution Control Association.
     11(6), pp. 814-823.

     This paper describes the petroleum industry and the products
it  makes  along  with  their  associated  waste  streams.     The
industry's  commitment to  waste minimization  is described with
examples  of specific minimization  projects provided.   Although
the  opportunities  for  minimization  are  limited,  the  economic
incentives for reducing waste disposal costs, not to mention long
term  liability from  improper  disposal  practices,  has put  the
petroleum industry on the road to waste minimization.
Lewis,  D.  A.  (October,  1988).    Waste  minimization  in  the
     pesticide  formulation  industry.    Journal   of   the  Air
     Pollution Control Association. 3JJ(10), pp. 1293-1296.

  ABSTRACT:                                 . -  -•   .
     The  pesticide formulation  industry is  dependent  upon  the
basic   manufacturers  for  the  main   raw   materials.     Waste
minimization efforts  are,  therefore,  limited to process/handling
sources.  The economic incentive for waste reduction has mandated
significant changes  throughout each  facility.  There  are waste
problems, however, that require industry-wide action, e.g., empty
containers.    The  ongoing  regulatory  actions  affecting  this
business will require continuing efforts to maintain operations.
Linder, S.  H.,  & McBride, M.  E.  (1984).  Enforcement  costs and
     regulatory reform: The agency and firm response.  Journal of
     Environmental Economics and Management.  11, pp. 327-346.

     Most of the  models  of optimal  law enforcement have centered
on  either  the Federal  enforcement  agency or  the  firm  and have
largely  ignored  the  decentralized  nature  of  the  enforcement
responsibilities  of  State and  local  government.    This  paper
extends those  results by  modeling  both  the  firm  and  the local
agency.    The  models  are  then evaluated  with  respect to  the
alternative regulatory  options of direct controls  and emissions
taxes.  The paper concludes that the local agency's likelihood of
detecting  noncompliance has  a  greater capacity  to affect  the
firm's behavior  than  does the  level of fines.    Moreover,  the
emission tax  option  rules out  discretion in the  treatment of
firms,  removes   the   opportunity   for  informal  resolution  of
detection mistakes, and increases enforcement costs.


Lovdal, M. L., Bauer, R. A.,  & Treverton,  N.  H.  (May-June,  1977).
     New  standing  committee  plays  active  policy  role  in
     initiating  corporate   responses  to  public  and   social
     pressures.  Harvard Business Review,  pp. 1-8.

     Proposes  that  a public  responsibility committee  may be a
valuable  resource  for a corporation because it enables a  small
group  to deal with  sensitive  issues  in  depth.    The optimal
public  responsibility  committee  is  composed,   primarily,  of
outside directors with  business  and nonbusiness backgrounds.  It
possesses  adequate  funds  for  hiring  outside  expertise,  and
establishes   a  well-defined  range   of  activities.      The
effectiveness  of  a  public responsibility committee  is  dependent
upon  its internal  management and its  management  support.   A
working  guide outlines ten  basic areas  of corporate  activity,
including environmental quality.
Mabbett, A.  N.  (May, 1983).   Developing an  effective interface
     with local,  state,  and regional  environmental authorities.
     Plating and Surface Finishing, pp. 84-86.
     Urges American  business  to place a  priority  on learning to
deal  effectively  with   regulatory  officials.     An  effective
relationship with a regulatory authority includes seven elements:
1.) good  communications    2.)  honest relationship   3.)  periodic
and regular contact  4.)  negotiations from a position of strength
5.) educated employees arid regulatory officials 6.) participation
in the  development  of standards and   7.)  obtaining professional
assistance,  if necessary.


Marcus,  A.  A.,  &  Goodman,  R.  S.  (1986).     Compliance   and
     performance:  Toward  a  contingency  theory.    Research  in
     Corporate Social Performance and Policy.  2,  pp,  168-182.

     In  this paper  the  authors critically  review the  existing
literature on corporate  social  policies and  business performance
and postulate that compliance is affected  by  and affects economic
performance  of  the  firm.    They  present the  results  of  two
empirical  studies  that  explore  the   relationship  between
compliance and  performance.   The  first study is an  analysis of
the  effects  of  economic performance  (as defined  by return on
assets,  return  on equity,  and long-term debt) on  the compliance
behavior of  smoke stack industries in and around  Pittsburg,  PA.
The  key variables  are  firm size  and  extent  of the  pollution
problem.  The study concludes that heavy long-term debt and large
pollution problems  have  a negative effect on compliance and that
both small and  large firms  exhibit similiar  compliance behavior.
The second study is an analysis of the effects of compliance with
certain regulatory orders of the Nuclear Regulatory Commission on
performance  of  the  utility  industry (defined as increased safety
and  economic efficiency).    The study concludes  that compliance
has  a  negative  effect on performance, given the  conditions of
staff resistance  to the regulatory order.  The  study finds that
there   is  a   link  between  acceptance  (of   the  order)   and
performance.    The  performance  does  not   improve,  that  is,  the
staff does  not comply  (although  it may  appear to  comply)  with
regulatory orders when it rejects them on ideological grounds.


Miller,  D.   T.   (1985).     "Psychological   Factors   Influencing
     Compliance".   Available  from:  Federal Statutes  Compliance
     Project, Department of Justice, Ottawa, Canada.

     Based  upon a  comprehensive literature  review,  this paper
elucidates  six psychological  principles  involved in  compliance
behavior:   1.)  perceived fairness of the regulation;
2.)  perceived  fairness  of  the  regulation's  enforcement  and
monitoring;   3.)  regulatee knowledge of  the regulation;
4.)  regulatee  commitment  to  the  regulation;    5.)  regulatee
feeling of responsibility for  own compliance record;  and
6.) economic  profit  associated with compliance and economic cost
associated  with  noncompliance.    Means  are   discussed  for
increasing  the  perceived  legitimacy  of   inspectors   so  that
compliance is enhanced.  The author concludes that the purpose of
the paper was to address' the causes rather than the  symptoms of
noncompliance with environmental law, noting  that:  "Bureaucratic
and rule-minded enforcement can lead to a minimalist  attitude on
the  part  of  both  law  enforcement  officials  and  regulatees,
leaving them  unresponsive to  more  serious, but not  technically
illegal situations"  (p. 24).
National   Association   of  Manufacturers   (1989) .     Waste
     Minimization;	Manufacturers'   Strategies   for   Success.
     Report  available from:  Publications Coordinator,  National
     Association  of Manufacturers, 1331  Pennsylvania  Ave.,  NW,
     Washington, DC 20004-1703.

     In  this  report,  "waste  minimization"  is defined  as:  "a
method  of  pollution prevention  that  focuses on  reducing  the
generation  and discharge  of hazardous  waste  at  its  source  to
avoid subsequent handling, treatment,  and disposal". Benefits of
waste minimization are described and classified into five primary
categories:  environmental  quality,  economic,  regulatory
compliance,  reduced  liability,   and  community  relations/public
image.   Information is given  on how to  establish  and  implement
waste minimization programs as well as -descriptions of  successful
programs at companies such as DuPont and 3M.  Information is also
given   on  where   to  seek  assistance  resources   for  waste
minimization programs.  Finally,  recommended  publications on the
subject of waste minimization are listed.


           Oman,  O.  E.   (July,  1988).    Waste minimization  in the foundry
                industry.  Journalofthe Air Pollution Control Association,
                31(7),  pp.  932-940.

                The foundry industry is a major consumer of  waste materials
           (scrap}.  Unfortunately,  the  recycling of these  waste materials
           can result  in the generation  of hazardous  wastes  that must be
           properly managed at a  significant cost.  This article focuses on
           two  waste  streams  in the  foundry  industry;   calcium carbide
           desulfurization slag  and  melt emission  control residuals.  The
           author  presents an  overview  of how  foundries  have  evaluated
           different waste management  options with  the  ultimate  goal of
           minimizing the generation  of  hazardous  waste.
           Pizzi,  F. P.  (October,  1983).   Create an effective  information
                system.   Hydrocarbon Processing,  pp.  81-82.

             ABSTRACT:                                . •• -
                This article  addresses  the growing  need  to  retrieve  and
           evaluate information about the  environment.   As  regulations  and
           reporting requirements have increased, there is  a great need  for
 f         efficient information management.    An  effective  computerized
   J      environmental  information management system  provides  help  in
           three key areas:   1.)  managing environmental information;
           2.)   monitoring compliance;  and    3.)  evaluating  environmental
           programs.  The article comments  on types of  uses  and project cost
           and  time requirements.
           Plaut,  J. (Spring, 1984).  Hazardous waste  control and industry.
                Toxic Substances Journal,  pp.  251-260.

                Speech,  presented  at the Conference  on Waste  Management,
           discussing changing societal  perceptions of environmental hazards
           and of industry's  role  in preventing hazardous  waste accidents.
           Suggests   that  good  pollution  control  and  responsible  waste
           handling  should be a key management priority,  not only to comply
           with governmental  regulations  and  avoid litigation,  but also to
           maintain  long-term profitability and competitiveness.


Reiter, W. M. (February, 1986).  Environmental liability control.
     The Environmental Forum, pp. 39-43.

     The author  (Director  of Pollution Control  for Allied Corp.)
first  discusses  the   manifestations  of   corporate  liability:
monetary,  negative  publicity,  and  managerial time.    He  then
describes  components   of   an  environmental   liability  control
system: top  management  recognition  and support,  integration into
business   operations,   adequate   expertise  and  resources,
coordination  with   public  affairs  and  law  departments,   and
corporate oversight  (or enforcement).
Roberts, M.  J.,  & Bluhm,  J.  S.  (1981).   The Choices  of  Power.
     Cambridge, MA: Harvard University Press.

     Discusses the process by which electric utilities have come
to  terms  with growing environmental pressures.   It  provides  a
close look at the way in which six utilities have coped with this
challenge.   The authors  explain  the  systematic  framework they
have developed for analyzing organizational behavior, and show     \
how  to use  this  tool by employing  it in  six  different case  i
studies.                                                           ^
Scholz, J.  T.  (1984).   Cooperation, deterrence,  and the ecology
     of regulatory  enforcement.   Law and Society Review.  18(2).
     pp. 179-223.

     Presents  a  model which  shows that an  enforcement strategy
that  combines  cooperation  and deterrence is  likely to produce
greater net benefits than a single-minded deterrence strategy.


Sproul], L. S. (1981).   Response to regulation: An organizational
     process  framework.   Administrationand Society. Al(4), pp.

     The author proposes an  organizational  process framework for
considering  response  to  regulation.    Its major  elements are
processes by which:  1.) organization attention is captured;  2.)
meaning  about external  stimuli  is constructed;   3.)  response
repertoires  (standard   operating procedures  and  programs)  are
invoked;   and 4.)  behavioral directives  or  guides for action are
conveyed from a  central office  to subunit sites.  Although the
author  has  detailed  the  approach through  one  segment of the
public  sect or--public  education—this framework  is   equally
appropriate  for  analyzing  and   understanding  response to
regulation in private sector organizations.
Stephan, D. G., & Atcheson, J.  (June,  1989).   The EPA's approach
     to pollution prevention.   Chemical Engineering Progress, pp.

     This  article  describes  the  United  States  Environmental
Protection  Agency's  efforts  to  prevent  pollution  before  it
occurs.  As a result of objectives set forth by Congress in 1988,
the EPA created a new  Pollution Prevention Office  (PPO)  within
its Office of  Policy,  Planning, and  Evaluation  (OPPE).   Since
this time, the  underlying theme  which  the EPA  has been trying to
convey  is:  "we, as  a society, must begin to  integrate pollution
prevention into the way we design, build, buy,  and consume11.
Stone,  C.  D.  (Fall,  1975).    Law  and  the  culture  of  the
     corporation.  Business and Society Review. 15. pp. 5-17.

     In this  article the  author discusses how  business culture
affects the degree of law abidance  demonstrated by corporations
and  how  this culture  can  be  changed to  increase  it.    Case
studies  are  used  to  demonstate   points   which  are  raised.
Although  not  directly  applied  to  environmental  law,  the  more
general issue of corporate social responsibility is discussed and
can be easily applied to the environmental realm.


Susskind, L.,  & Weinstein, A.  (January,  1982).  Row  to  resolve
     environmental  disputes out  of court.   Technology  Review.
     pp. 38-40.

     Contends  that  our legal system cannot  handle  environmental
disputes  efficiently  and  advocates  out-of-court  negotiation.
Nine  steps toward  lasting resolution  of mediated  out-of-court
negotiations are  prescribed.   Lastly,  the authors argue  that if
the   out-of-court  bargaining  process  is  to  become  a  real
alternative  to litigation, the  power  of government agencies to
exercise discretion in settling conflict must increase.
U.  S.  Environmental   Protection  Agency  (1984).    Agencywide
     Compliance And  Enforcement Strategy And  Strategy Framework
     For  EPA Compliance  Programs.   Available  from:  Compliance
     Policy  and  Planning Branch,  U.S.  EPA  (LE-133),  Washington,
     DC 20460.

     This  document  discusses EPA's  past,   present,   and  future
enforcement  efforts  and the challenges associated  with  these  "~~\
efforts.                                                          (    1
U. S.  Environmental  Protection Agency (September, 1985).  "Study
     Of   Literature   Concerning  The   Roles  Of  Penalties  in
     Regulatory Enforcement".   Available from: Compliance Policy
     and  Planning  Branch,  U.S.  EPA  (LE-133),  Washington,  DC

     This paper reviews  the literature  on the roles of penalties
in regulatory  enforcement.   It  covers schools of thought on the
matter:  the   Economic  and  the  Behavioral,  the  purposes  of
penalties, the assessment of  penalties  and mitigation criteria,
and  different  types  of  penalty authority  and implementation


          U.  S.  Environmental Protection Agency  (April,  1988).    The  EPA
               Manual  for  Waste  Minimization  Opportunity  Assessments.
               Available   from:   Hazardous  Waste  Engineering  Research
               Laboratory,   Office  of  Research  and  Development,   U.S.
               Environmental Protection Agency, Cincinnati, OH 45268.

               By following the procedures outlined in this manual, a waste
          generator can:   1.) save money by  reducing  waste treatment and
          disposal  costs,   raw material  purchases,  and  other  operating
          costs;   2.)  meet  state  and national waste  minimization policy
          goals;   3.)  reduce potential  environmental  liabilities;    4.)
          protect public  health  and  worker health and  safety;    and 5.)
          protect the environment.
U. S. Environmental Protection Agency  (May 8, 1989).   "Corporate
     Environmental Management Training — Two workshops co-hosted
     by  U.S.   Environmental  Protection   Agency:   Regulatory
     Innovations  staff  and   occidental  Petroleum  Corporation".
     Report   available   from:   Jim  Hayes   (project  manager),
     Regulatory Innovations Staff,  U.S.  EPA  (PM-223), Washington,
     DC 20460.

     This is a report of the discussion agenda from two workshops
on  Environmental Management  Training,   hosted  by  the U.S. EPA
Regulatory Innovations Staff and Occidental Petroleum,  which were
held in November and December, 1988.  The workshops, held in Los
Angeles, CA and Washington, DC,  brought together senior corporate
level  environmental   managers,  academic representatives  from
university  programs   in  environmental management  training,
consultants,  State   regulatory   agency representatives,  and
interested parties  from  the  EPA Office  of Policy,  Planning, and
Evaluation  (OPPE)   to  discuss  their collective  experience and
identify   the  industry  needs,   resource  requirements,  and
management  systems   requirements  for   effective  training   of
corporate environmental managers.


U.  S.  Environmental  Protection  Agency   (1989).    "Fostering
     Effective Environmental Management".  Report available from:
     Regulatory Innovations Staff,  U.S.  EPA  (PM-223), Washington,
     DC 20460.

     In  this report,  the  role  of  environmental  management  is
defined and  the needs of environmental managers  are discussed.
Specifically,  an   integrated  approach   toward   environmental
management is advocated in which human resources, technology, and
environmental management  practices interact.    It  is forecasted
that  an  environmental  management  profession  will  eventually
develop  with minimum training  and  certification requirements
VNO  Federation  of  Netherlands  Industry  and  NCW  Netherlands
     Christian   Employers.  Federation   (October,   1987).
     "Environmental  protection  in  companies:  Guide  to  the
     organisation of corporate environmental, protection systems."
     Brochure   available  from:   Attache  for  Health  and
     Environmental  Protection, Royal  Netherlands  Embassy, 4200
     Linnean Ave. NW, Washington,  DC 20008.

     This  brochure is  intended as  a practical guide for both
large  and small  firms that  wish to  organise  an environmental
protection system  or develop one further.   The system described
is expressly  intended only as a detailed schematic example, not
as  a blueprint.   Practical  situations  differ in  almost every
company;  therefore,  the particular  system  must be tailor-made.
However,  if  one genuinely  wishes  to be  able to  refer  to an
adequate  internal  corporate  environmental protection system, the
necessary  basic  elements will  have  to be  present in  a more or
less highly developed form.


         Wasserman,  C.   (1985).     "Improving  the   Efficiency   and
              Effectiveness  of  Compliance  Monitoring and Enforcement of
              Environmental  Policies  - United States: A National Review."
              Conference  paper prepared for The Organization for Economic
              Co-operation   and  Development,  Environment  Directorate.
              Available  from:  Compliance Policy and Planning Branch,  U.S.
              EPA (LE-133),  Washington,  DC 20460

              In  this  paper  the  author  considers  the  theoretical
         foundations of  compliance motivation and then  discusses ways to
         increase levels of compliance.  It  is  stated that,  "... the key
         to  a  successful  and   efficient  compliance  promotion  and
         enforcement program  is matching  enforcement approaches  to the
         full  range  of  motivating  factors  that may  be   at  work  for
         individuals and all levels within regulated entities'1 (p. IV-4).
         Ways  of  assessing  an enforcement  program's  effectiveness  and
         efficiency  are  also discussed.  Wasserman works in EPA's Office
         of Enforcement and  Compliance Monitoring  (OECM).
         Wasserman,  C.  (1987) .   "Environmental Compliance And Enforcement:
             Theory,  Practice,   And  The  Challenge  To  Environmental
             Economists.   Conference paper  prepared  for The Association
             of  Environmental  and  Resource  Economists  Workshop  on
             Environmental   Enforcement  and Monitoring,  University  of
             Delaware.   Available  from:  Compliance  Policy  and Planning
             Branch, U.S. EPA  (LE-133), Washington, DC 20460.

             This paper discusses theories of compliance and enforcement,
         ways  of defining and  assessing  enforcement program success, and
         gaps in knowledge which must be  filled in order to increase level
         of  compliance.
         Waste Advantage,  Inc.  (1989).   Industrial Waste Prevention; Guide
              To  Developing An  Effective  Waste  Minimization  Program.
              Available from:   Waste  Advantage,  Inc.,  23077 Greenfield
              Rd.,  Southfield,  MI  48075,  (313)  569-8156.

              This book is short and  to the point for practical plant use.
         It provides  step-by-step  instructions  for developing  an effective
         waste  minimization program.    Most  of  the ideas for  waste
         prevention are relatively inexpensive to  implement and  do not
,_       require any  major changes in plants.