U.S. Environmental Protection
U.S. Agency for
International Development
Principles of Pollution
An International
Training Course
Environmental Pollution
Prevention Project
Student Notebook
May 1994

Introduction to the Course
This course is designed to provide experienced trainers with the general
background information and materials they need to teach an introductory pollution
prevention course. It is intended as a train-the-trainer workshop for persons in
government, academia, industry, and non-profit organizations who are responsible for
providing environment-related training, particularly in developing countries. Although
participants are assumed to have an understanding of basic scientific concepts and
industrial processes and an awareness of environmental issues, they need not have
extensive experience in science, engineering, or industry.
This course will not give students a detailed knowledge of pollution prevention
concepts. Rather, it will teach them the basics of pollution prevention and skills for
teaching adults about pollution prevention. At the end of this week-long course,
participants will:
•	have a general understanding of pollution prevention planning, process
characterization, options generation and assessment, financial analysis, and
•	be able to develop and deliver a self-designed, pollution prevention
orientation course for industry, government, or other organizations in
developing countries;
•	be familiar with the materials available to help them prepare and present a
pollution prevention course and know how to access additional resources;
•	have a plan for implementing a pollution prevention training program or
course with the knowledge they have acquired.
Organization of this Notebook
This student manual contains two types of materials: (1) materials that will be
used and discussed as part of this week-long train-the-trainer course and (2) materials
that may be useful to participants in developing their own pollution prevention training
courses. Sections I through III cover the information that will be discussed during this
course: general training techniques; introductory information on pollution prevention;
and the process for pollution prevention planning and facility assessment. Sections IV
through VI contain reference and training materials, such as fact sheets and case studies,
pollution prevention exercises, and a pollution prevention slide show, which can be used
in courses developed by the participants.

Although some of the train-the-trainer materials in the first three sections may be
useful to students in developing their own pollution prevention training sessions, the
course as it is presented in this manual is not designed to be used to train particular
audiences in developing countries. Participants in this train-the-trainer course are
encouraged to use materials from all sections of this notebook to develop training
programs that are tailored to the needs of their audiences.
This manual is intended as an advisory guidance document only. Users are
encouraged to duplicate any portion of this notebook as needed to conduct training or to
implement a pollution prevention program. Any or all parts of this document may be
reproduced or translated as necessary.

Environmental Scientist
Office of Research and Development
401 M St SW 8301
Washington DC 20460
phone(202) 260-2726 fax 260-3861
Deborah Hanlon has over 15 years of professional experience in the
environmental field including 10 yean of concentration in pollution prevention,
hazardous waste management, toxic materials control and emergency response.
Deborah has a Bachelor of Science degree in Microbiology from San Jose State
University, 1975 and a Masters Degree in Political Science from California State
University Consortium, Long Beach, Ca., 1985.
Deborah has extensive experience working for Federal, city, county and state
governmental agencies in the fields of food and water sanitation, recreational
health, sewage disposal and industrial discharge programs, vector control, land
use planning, emergency response planning and preparedness, hazardous waste
RCRA enforcement and management, pollution prevention and hazardous waste
minimization. She has been extremely instrumental during the last ten years, in
developing and implementing waste minimization and pollution prevention
programs for the US EPA, State of California, County of Ventura and the City of
Los Angeles.
International experience includes co-directing a NATO/CCMS Pilot study on
Pollution Prevention for Sustainable Development and working with the UNEP
Cleaner Production Programme Office in Paris on training issues and policy
strategies. She has also helped develop and conduct training programs for the
United States Environmental Training Institute (USETI) and for the International
Conference on Cleaner Production. In 1993, Deborah developed and taught two
environmental courses for US Peace Corps Business Volunteers in Vladovostoc,
Russia and Kiev, Ukraine.
Deborah is currently working in EPA's Office of Research and Development
on the Agency for International Development's Environmental Pollution
Prevention Program (EP3). Her responsibilities in this project include assisting in
the development of the Tunisian EP3 Office and program, the EP3 Information
Clearinghouse, and pollution prevention training and outreach programs.

Elizabeth S. Marcotte
Program Coordinator, EP3
Elizabeth Marcotte is a Senior Vice President at ICF Incorporated. She has 20 years of
professional experience in policy and program implementation support. Ms. Marcotte has spent
the last 10 years directing projects to increase public awareness about environmental problems and
to involve the public in resolving these problems. Many of these projects have involved planning
and executing training programs and public education campaigns, orchestrating public meetings,
and evaluating alternative approaches to resolving particular problems.
At ICF, Ms. Marcotte has directed a broad range of environmental training design,
development, and delivery projects. These training courses have covered technologies for cleaning
up hazardous waste sites, EPA regulations governing hazardous waste management, Superfund
cleanup procedures, air pollution control requirements, and community relations. Ms. Marcotte
has managed the preparation of guidance, instructional manuals, and publications on environmental
dispute resolution, government program strategic planning, and environmental regulations. She
has assisted in the enhancement of clearinghouses and the development of information banks.
Under a 1991 grant from the U.S. Trade and Development Agency, Ms. Marcotte developed
procedures for the Slovak Ministry of Industry, Czech and Slovak Federal Republic, on
minimizing public objections to the siting of incinerators and other industrial waste treatment
facilities. She trained representatives of Slovak national and local government agencies, industrial
enterprises, and non-governmental organizations on this issue in Bratislava. Ms. Marcotte also
prepared a plan for involving local citizens in decision-making and communicating technical
environmental information to the public regarding the cleanup of dioxin and PCB contamination at
the Spolana Chemical Works in Neratovice, Czech Republic.
She is currently serving as Program Coordinator for USAID's Environmental Pollution
Prevention Project (EP3). As Program Coordinator, she oversees the development and
implementation of information exchange systems, training programs, and the Tunisia country
Ms. Marcotte has a B.A. in economics from the University of Vermont

Dr. Luskin is currently Associate Director of the Toxics Use Reduction Institute at the University
of Massachusetts at Lowell where he is also an adjunct faculty member in the Colleges of
Engineering and Arts and Sciences. He is also Vice President of the Environmental & Nuclear
Resource Group, Inc. Dr. Luskin has been involved in education and training for over 20 years.
His experience includes instruction at all age levels, including children, high school, university
undergraduate and graduate students, and professional engineers and scientists. Subjects that he
has taught include radiation protection, occupational health and safety, and pollution prevention.
Dr. Luskin has directed education and training programs for the U.S. Federal Emergency
Management Agency, U.S. Environmental Protection Agency, U.S. National Institute for
Environmental Health Science, Massachusetts International Chemicals Workers Union, U.S.
Environmental Training Institute, Waste Reduction Institute, and the National Emergency
Training Center.
Dr. Luskin serves or has been a member of the Board of Directors of Environmental & Nuclear
Resource Group, Incx, and the Massachusetts Corporation for Educational Telecommunications.
He is an advisor to the New England Consortium for Hazardous Waste Worker Health and Safety
Training, Source Reduction Advisory Board of the Massachusetts Environmental Trust, and the
Pollution Prevention Training Committee of the U.S. Environmental Protection Agency.
Dr. Luskin has authored journal papers and presents regularly at a variety of professional
conferences. He holds a Masters degree in Education, a second Masters degree in Radiological
Sciences and Protection, and a Doctorate in Training and T /»armng

Jeuli Bartenstein is the Deputy Director of the EPA Institute,
the U.S. Environmental Protection Agency's national program for
training and development. She has been involved in various forms
of teaching, training, and education for twenty years. Ms.
Bartenstein has worked for the last six years with the EPA
Institute, since its inception, as a learning consultant,
facilitator, curriculum designer, change agent, and manager.
Jeuli's formal education has been diverse, both substantively
and geographically. She graduated Phi Beta Kappa from University
of Illinois with a Bachelor's in Speech/Communications; pursued her
Doctoral studies on full academic fellowship in Rhetorical Theory
at University of California, Berkeley; received her Master of
Public Administration at the top of her class from State University
of New York at Albany; and studied design at the Art Institute of
Ms. Bartenstein's professional career has been no less varied.
Her path to EPA was a circuitous one, and included such positions
as instructor of persuasive writing and criticism to pre-law
students; head of the English Department of a vocational college;
technical editor at an engineering company; staff analyst to the
Majority Leader in the New York State Assembly; and budget examiner
in the Office of the Secretary at the U.S. Department of Health and
Human Services.
Outside of work, Jeuli serves as Vice-President of the Board
of Directors for Northern Virginia Reading Is Fundamental (RIF),
volunteers her time in a local elementary school, fundraises for
AIDS research, and is a champion ten-pin bowler.

EP3 Principles of Pollution Prevention
Sunday. May 8
5:00 p.m. • 7:00 p.m.
Monday. May 9
8:30 a.m. - 9:00 a.m.
9:00 a.m. - 9:30 a.m.
9:30 a.m. -10:30 a.m.
10 JO a.m. • 11:00 a.m.
11:00 a.m -12:00 p.m.
12:00 p.m. • 1:30 pjn.
1:30 p.m. - 5:00 p.m.
Tuesday. May 10
9:00 a.m. • 10:00 a.m.
10:00 a.m. -1030 a.m.
10:30 a.m. -12:00 p.m.
12:00 p.m. -130 p.m.
1:30 p.m. - 4:00 p.m.
4:00 p.m. - 5:00 p.m.
Welcoming Reception
Opening Remarks
Student Introductions
Groundrules and Agenda
Learning Theory and Concepts
Learning Theory and Concepts (Continued)
Incentives and Barriers
What is Pollution Prevention?: Discussion and Slide
Introduction to Pollution Prevention Planning and
Process Characterization
Process Characterization
Flow Charts
Materials Counting
Cost of Toxics
Data Collection
Options Generation
Barbecue at Betsy Marcotte's house

Wednesday. May 11
9:00 a.m. -12:00 p.m.
12:00 p.m. - 1:00 pan.
1:00 p.m. - 5:00 p.m.
Thursday. May 12
9:00 a.m. - 9:30 a.m.
9:30 a.m. -11:00 a.m.
11:00 fl-m- -12:00 p.m.
12:00 p.m. -1:30 p.m.
1:30 p.m. - 3:00 p.m.
3:00 p.m. - 5:00 p.m.
5:00 p.m. • 7:00 p.m.
Friday. Mav 13
9:00 a.m. - 12:00 p.m.
12:00 p.m. - 1:30 p.m.
1:30 p.m. - 3:00 p.m.
3:00 p.m. - 5:00 p.m.
Financial Analysis
Site Visit
Lessons Learned from Site Visit
Options Assessment
Audience Selection and Analysis and Level of Training
Students Prepare for Presentations
EP3 Reception
Student Presentations
Action Plans
Networking and Resources

Principles of Pollution Prevention
Participant Notebook
Table of Contents
Section I Instructor Training Techniques
A.	Adult Learning Concepts
B.	Training Techniques
C Training Activities
Section n Introduction to Pollution Prevention Concepts
A.	Definitions
B.	Incentives and Barriers Student Exercise
C EPA Policy Statement and Strategy
Section m Pollution Prevention Planning and Facility Assessments
A.	Developing a Pollution Prevention Program
B.	Process Characterization Exercise
C Options Generation Exercises
D.	Financial and Technical Considerations
E.	Implementation and Evaluation of the P2 Program
Section IV Case Studies and Fact Sheets
A.	EP3 Fact Sheets
B.	Other Industry Fact Sheets
C EPA Pollution Prevention Fact Sheets
Section V Pollution Prevention Training Materials
A.	EP3 Industrial Group and Best Industrial Practices
B.	Leaders Guide for Conducting Pollution Prevention Orientations
C Creative Approaches to Conducting Pollution Prevention Training
D. Orientation Slide Show and Script
R UNEP Audit Manual
Section VI International Pollution Prevention Resources
A.	Environmental Pollution Prevention Project and Clearinghouse
B.	UNEP Cleaner Production Program and Clearinghouse
\lB	oU

May 9-13,1994

•	Water protection
•	Sewage treatment
•	Lack of regulations and enforcement
•	Lack of environmental awareness and training
•	Wildlife protection
•	Energy production
•	Population growth
•	Air pollution
•	Solid waste
•	Industrial pollution
•	Unrealistic standards
•	Marine pollution
•	Focus on end-of-pipe solutions
•	Environmental health
•	Natural resource protection
•	Broaden knowledge of pollution prevention information needs
•	How to focus on prevention
•	Techniques for promoting awareness
•	Training techniques
•	Learn what works
•	Economics of pollution prevention
•	How to select pollution prevention options
•	How to focus on pollution prevention training
•	Learn from others' experiences

Key Messages of the Training (Day One)
•	Learn by Doing
•	Teach by Example
Criteria for Effective Learning
Group 1
•	Interaction and audience participation
•	Good exercises that involve feedback and reporting
•	All students are encouraged to participate
Group 2
•	Learning by doing
•	Instructor asks for and answers questions
•	Instructor really understands the subject
•	Participants feel a personal connection to the subject
Group 3
•	Both students and instructors are committed to the learning process
•	Students have a need to learn
•	Communication is clear (people who know a lot are not necessarily the best
•	Students have similar levels of knowledge
•	Good materials and audio-visual aids
•	Interaction among participants
Group 4
•	Students have a strong interest in the subject
•	Everyone participates
•	Good materials (e.g., handouts, audio-visuals)
•	Information for all levels is offered
•	Subject matter has practical application
•	Teaching is involved
•	Teacher is experienced and knowledgeable
•	Participants share experiences

•	Gaining trust/confidence of participants (Self-presentation)
•	Not meeting audience needs (Gear structure and design)
•	Non-participation by the audience (Tailor to audience)
•	Looking unprepared
•	Getting "off track"
•	Being evaluated
•	Hostile/disruptive audience
•	Audience members with "hidden agendas"
•	Audience is not interested
•	Audience knows more than the facilitator. Can't answer questions.
•	Shy participants/shy instructor
•	Not comfortable with materials
Why Is This Important?
•	Getting trust of audience
•	Indicates confidence of instructor
•	Motivational means
What Is a "Good" or "Bad" Image or Presentation of Self?
•	Brief, honest, organized introduction of oneself: good image
How Can You Change Your Self-Presentation?
•	Knowing your target audience before the presentation
•	Rehearsing your performance through a video/mirror
What Are Some Examples of Detractors (Annoying Habits)?
•	Putting your hands in your pockets
•	Jingling coins in your pockets
•	Repeated use of words like, "you know," "well," "so," etc.
What Can You Do About Them?
•	Rehearse and correct
•	Seek help from friends
•	Learn from feedback/response from earlier programs
What Effect Do These Have on Your Audience's Learning?
•	Audience loses interest and focus
•	Audience goes off track

(Includes Both Physical Layout and Content Design)
How Can These Help Manage Expectations?
•	Planning, room set-up reflect interactive style
•	Reach agreement on objectives of the class
•	Know your audience and design your course accordingly
•	Design materials appropriate for your audience
What Are Some Structure or Design Techniques to Keep the Class on Track?
•	Agenda, guidelines, timekeeper, flip charts, overheads, flow diagrams, hard copy of
overheads available, summarizing information discussed
What Happens If Structure/Design Don't Make Sense?
•	Use discussion and interaction to adjust
•	Allow flexibility to restructure as necessary and appropriate
•	Call "timeout," and use breaks to assess and evaluate changes required
How Do You Know If Structure/Design Makes Sense?
•	Time flies
•	Participants are engaged in the process

What Tools Can You Use to Find Out About the Audience Before the Class Begins?
During Class?
•	Use registration forms that describe participant's responsibilities, educational
•	Ask participants to complete questionnaires
•	Require participants to submit resumes or CVs
•	Gass introductions
•	Class presentations on various topics
•	Evaluation forms
What Have We Used in This Course To Find Out About You?
•	Registration forms that included a questionnaire
•	Class introductions
•	Class presentations on various topics
•	Icebreaker exercises
•	Evaluation forms
What If Prepared Material Is Inappropriate for the Audience?
•	Use whatever is relevant
•	Correct the mistake
•	Always have on-site assistant to locate and obtain correct materials
How (and Who) Determines Your Audience?
•	Depends on course objectives

Being Evaluated
•	Use the evaluation as an interesting feedback process
•	Design your own evaluation form
•	Use daily evaluation as a way to improve the course day-by-day
•	Expect opposite comments from participants: for each person who thinks some is
the best, another will think it is the worst
•	Use comments as a way to improve
•	Give some but not too many sophisticated examples to show how skilled you are
•	Don't underestimate the participants
•	Encourage participation by asking questions or stirring emotion in the audience
(but not in a hostile manner)
•	Use questionnaires, quizzes, continuous evaluation, and exams
•	Address simple questions to persons who are not participating
•	Split into groups to encourage students to share with a smaller number of people
•	Increase participation opportunities
•	Do exercises in pairs
•	As some of the people in the audience to describe graphically (i.e., through
drawing) what they have learned
Hostile/Disruptive Audience
•	If an individual is being disruptive, speak to that person privately during a break
•	Show the value of presentation to the audience
•	Find out what the disruptive person really thinks. Negotiate
•	As the group to help manage unruly participants (also, use groundrules)
•	Answer hostile questions after class
•	Let the person vent (briefly!)
•	Try to use humor to turn a hostile person around and to gain the sympathy of the
rest of the audience
•	Don't let the hostile person make you become angiy and hostile too!
Audience Not Interested
•	Keep the agenda flexible to incorporate input from the audience
•	Use multiple speakers to keep interest
•	Try to determine audience's interests by asking participants to introduce
themselves and state their interests
•	Ask participants what they would like to see covered (i.e., invite questions and
comments from the audience)
•	Be prepared beforehand
•	Make material easy to understand and use examples
•	Use more audio-visual presentations instead of just lecturing
•	Don't assume that there is a lack of interest - people may be tired or have jet lag

Can't Answer Questions/Audience Knows More
•	Ask the audience for suggestions or answers
•	Offer to research the question later and ask the questioner to give you contact
information at the end of the session
•	Don't provide wrong answers just to give an answer
•	Anticipate questions before the class
•	Try to obtain the answer from the group
•	Don't try to hide the fact that you don't know an answer
•	Tell the participant that you will look up the answer and get back to them
Shy Participants/Shy Instructor
•	Use icebreakers
•	Divide into small groups of 3-4 people
•	Acknowledge differences
•	Stress that everyone has many points in common (e.g., interests)
•	Use practical case studies dealing with the areas that concern the shy participants
•	Provide positive reinforcement
Not Comfortable with Material
•	Educate yourself or seek the assistance of an expert in teaching the course
•	Put in time at the library
•	Use a pencil to write notes on flip charts under the bold marker points (pencil
can't be seen)
•	Revise the material
•	Arrange/develop the material yourself
•	Don't give too many handouts
•	Have notes
•	Provide additional material during or just after the end of the course (commitment
is important)

Company Concerns Associated with Chemical Manufacturing
•	Liability
•	Compliance with regulations
•	Fear of penalties
•	Cost of disposal
•	Consumer health
•	Export restrictions
•	Public image
•	Future growth of the company
•	Environmental considerations
•	Worker health
•	Insurance costs (for worker health and environmental cleanup)
•	Reduced dividends
•	Remaining competitive
•	Environmental management
•	Product acceptability
•	Unions
•	Neighborhood concerns
•	Certification
•	Environmentalists
Neighbor Concerns Associated with Chemical Manufacturing
•	Worker health
•	Health of family
•	Economic impacts
•	Effect on ecosystem
•	Accidental releases
•	Lack of environmental management
•	Lack of common interest
•	Perception of unknown risks
•	Property value
•	Aesthetics
•	Hazardous wastes
•	Employment

•	The company was committed to pollution prevention.
•	Workers had been influenced by their children. Education is important. It makes
a difference.
•	Automation/modernizing makes pollution prevention easier.
•	Companies are responding, not taking initiative for pollution prevention.
Laws/rules are the drivers. Companies need incentives.
•	The company was using preventive maintenance to reduce pollution.
•	The company is only in the early stages of prevention. They are not really
investing in prevention yet, but rather are looking for quick payback opportunities.
Options Implemented
•	Recycled cooling water
•	Total quality management
•	Cans are thinner (therefore, less raw materials are used)
•	Recycled cans are major raw material
•	Recognition for good performance
•	Switched to water-based paints/coatings to reduce solvents
•	There was a system for pollution prevention. The facility complies, follows the
rules. They take pollution prevention seriously.
•	Awareness is important.
•	They followed the pollution prevention hierarchy and worked to minimize waste.
•	The process was similar to the process used in a plating facility in Tunisia. Waste
treatment also was similar.
•	The air quality in the facility was not good, even though the facility is complying
with applicable regulations. Air quality could be improved.
•	Workers and management are committed to pollution prevention. They recycle
water, segregate waste, send hazardous waste to a recovery facility.
•	Systems used in the plating plant may not be available yet in countries like Tunisia
(e.g., waste recovery).
•	Economics are important.
•	Rules/compliance/enforcement vary significantly across jurisdictions.

Potential Audiences
•	Industry (Managers, Technical Staff, Workers)
•	Students and Professors (University, Technical, K - 12)
•	Family
•	Media
•	Government and Regulators
•	Consultants
•	Public
Topics for a One-Day Pollution Prevention Orientation Course
•	Flow diagramming
•	Definition of pollution prevention
•	Program development
•	Impact of pollution: Problems and solutions
•	Techniques and technologies
•	Global village concept
•	Experience and results
•	Economic benefits/Social health
•	Regulatory framework
•	Barriers and incentives
•	Implementation

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2. o



Cultivate your faith in yourself as a learner. Research shows
that adults are better learners than children, if they have the
patience to be beginners.
-Marilyn Ferguson
Learning is not a task or a problem—it is a way to be in the
world. Men and women learn as they pursue goals and projects that
have meaning for them.
-Sidney Jourard
Learning is the very essence of humility, learning from everything
and everybody. There is no hierarchy in learning. Authority
denies learning and a follower will never learn.
There is no limit to the process of learning to learn, indeed,
once human beings have been bitten by the excitement of finding new
ways to structure knowledge, they will never again fear being
-Robert Theobald
The ancient Greeks knew that learning comes from playing. Their
concept for education (paideia) is almost identical to their
concept for play (paidia).
-Roger Von Oech
Today's successful managers can't spend valuable time in
unproductive seminars that are 60 percent old stuff or sit around
waiting for someone to offer just the right course. Only those who
can design their own learning can cope with constant change.
-Paul Gugliemino
Intellectual independence at the earliest possible age should be
the object of education... .The initiative should be transferred to
the student at the earliest practicable stage.... The
educational ladder should hoist the climber up from the child's
passive role to the adult's active one.
-Arnold Toynbee
Tell me, I'll forget. Show me, I may remember. But involve me
and I'll understand.
The adult learners of the future will be highly competent in
deciding what to learn and planning and arranging their own
learning. They will successfully diagnose and solve almost any
problem or difficulty that arises. They will obtain appropriate
help competently and quickly, but only when necessary.
-Allen Touch

Moving From a Teaching Culture to a Learning Culture
course outlines
competency specifications
group testing of content
individual testing of competence
testing of knowledge using paper/pencil
testing of competence through scenarios, simula-
tions and interactive techniques
training delivered to groups at central location
learning environments established at the worksite
training delivered at a fixed location
learning available where needed
group paced
self paced
. available on schedule
available on demand
group standardized approach
individually tailored approach
"automating the past" by continuing what we are
doing only doing it faster
reanalyzing the need and developing a new
solution now possible because of the new tools
or techniques
segregating training from job performance
incorporating performance support tools acting
as advisors/agents with learning environments
education and training delivered principally by
text and talk
multimediated, interactive learning environments
learning by reading and listening
learning by doing through simulation and other
instructor or teacher control
learner control
linear and sequential access to information
random, on demand access to information
teacher centered didactic approach
learner centered approach where the strategy is
matched to the learning style of the individual
a vision of human learning and performance
restricted by text and talk
a vision of human learning and performance
incorporating varying modes of perception and
a concept of the mind as a container to be filled
with knowledge and skills
the mind as human potential to be developed
through its own activity

Training Fact Sheet: 'Training Your
The teaching situations which most people are familiar with are hierarchical. A
teacher who has the answers and information is teaching students who are
presumed to have little or nothing to contribute. Their task is to learn what they
are being taught as exactly and rapidly as possible. Children at school are expected
to be, in effect, blank slates on which the teacher can write.
Training adults, especially your peers, is a very different context for many reasons:
¦	Adults have their own opinions about whatever subjects you are discussing.
Rather than swallowing what a trainer says to them whole, they are likely to
question your views. If you haven't thought about what you are saying from
multiple perspectives, you may feel somewhat overwhelmed and defensive. The
more opinionated members of the group may seem threatening to you.
¦	Adults have their own experience, which gives them a basis for evaluating what
the teacher is saying. As you talk, they will be testing your statements against
their own experiences. They may ask, "How would that apply in a situation
where xyz?" Or they may tell you that, in a similar situation, they tried the
technique you were recommending, and it didn't work. Unless you are prepared
to suggest alternatives, or to allow for the fact that your approach is imperfect,
you may set yourself up for attack.
¦	Adults form alliances with each other more readily than children. They are
skilled at discovering affinities and bonding on those bases, so if you find ways
to turn them to your favor, you will help the participants teach each other. On
the other hand, one disgruntled person may attract allies very
quickly—especially if you attack, rather than assert, as the leader.
¦	Adults don't want to sit and listen; they want to participate. They have a lot of
energy which can either be harnessed to propel the course forward, or can stew
and create a negative atmosphere. Keep them moving and involved as much as
you possibly can.
¦	Adults have particular needs when they arrive at the course, and they want to
see them addressed. If you don't, they may dismiss you as incompetent or
uninformed, while in fact, you may simply be on a different track. Check their

expectations from time to time; some you will never meet, but sometimes you can
make adjustments that will benefit the entire class.
¦ Adults need to be persuaded that the material you are presenting is relevant
and useful to them. If they cannot see bow it wUl apply specifically to their work
or personal lives, they will ignore you. It must be linked directly to their
experience in a way they can understand.
While there are many training approaches which can be taken successfully with
adult peers, the most important principle is to act like a peer, not an emperor.
Recognize that everyone has something valuable to contribute, and give them a
chance 10 do it-without going to the extreme of giving them control of the group.
You will know when someone is off the track, start by steering them gently, and
escalate. Don't be afraid to shut people up if you have to, but try to do it in a way
that doesn't set you up for a mutiny. The more you recognize and value the
contributions and experiences of others, the more likely they are to see you as an
ally and peer, rather than someone to be shot down as a know-it-all.
Training Fact Sheet: "Training Your Peers" was prepared by:
Mary Dingee Fillmore (617) 969-4974

(by permission of)
Garland D. Wiggs, Ed.D
Associate Professor of Adult Education
and Human Resource Development
The George Washington University
School of Education
Washington, D.C. 20052

One of the greatest influences in creating a productive adult learning climate is the
trainer. To help you be an effective trainer there are many practical ideas from adult education
research. Your understanding of these ideas can make your work easier and your student's
learning more effective.
When teaching adult learners, the trainer should try to use the adults' own resources they
bring into their learning situation. Recognize that:
1.	Your adult learners have living experience which can contribute much to the
learning situation. As adults, we define ourselves by our experiences. We have a
deep investment in their value. Therefore, if we find ourselves in a situation
where our experience is ignored or minimized, we feel rejected as a person, our
ego suffers.
The implications of this fact for you as trainer are obvious:
a.	As adults, we have much to contribute to the learning of others. This
contribution, if encouraged, can be exploited by the trainer if he/she uses
experiential, action-oriented, problem-solving methods and techniques in
b.	As adults, we have a good foundation of experiences from which we can
related new learning. Illustrate new concepts and generalizations with on
the job experiences drawn from the participants themselves.
c.	With broader depth of experiences as adults, we have also acquired a
number of fixed habits and thought patterns that may interfere with
learning. A warm, non-threatening learning climate can help participants
evaluate themselves more objectively and help overcome the resistance to
new ideas. The trainer establishes the necessary learning climate in his/her
class by being a warm, helpful and empathic person.
2.	Adults tend to be autonomous and self-directing. Consequently, as learners they
feel uncomfortable when placed in a dependent role. One way to encourage more
self-direction in learning is to give the responsibility for working out solutions to
the students themselves. The trainer serves as a resource to their problem-solving
The implications for the trainer include:
a. Treating adult participants with respect - avoid preaching, telling,
embarrassing, punishing, and directing. Be supportive rather than
judgmental.. . friendly and informal, not aloof or formal.

b.	Allowing the participants to shape part of their own learning by bringing
up problems related to the content that suits their needs.
c.	Acknowledging the adult's previous knowledge and experience with the
new content being learned. While most adults haven't been in the habit of
studying, we are all used to reading mail, outlining specifications and other
job related activities. The effective adult trainer recognizes that past
knowledge and experience is a foundation to the introduction of the new
knowledge; tying the known to the unknown, the familiar with the
unfamiliar, is a key to effective learning.
3.	As adults, we are most often interested in the immediate application of new
knowledge. What's in it for me ... now? Adults as learners are more likely to
learn things they perceive as helping the resolve current issues, concerns, and
problems facing them as individuals at work or at home.
The implications for you as trainer are as follows:
a.	The starting point for adult learning should be the problems and concerns
of the participants. What's "bugging" them about this topic, right now?
Taking time to "air" problems and making adjustments to account for them
in the material to be covered will add relevancy to the learning for the
adult participants.
b.	Class discussions should address approaches for solving problems raised by
the participants relating to the content
4.	Adults have a readiness to learn those things that are necessaiy to help us advance
our career and personal life goals. We tend to be most receptive to learning when
we are confronted with the fact that we don't know something we feel a need to
know. That is the adult's most "teachable moment."
Some implications for the trainer are:
a.	Recognize that many of your participants know that this training enhances
their professional development and will help them advance in their career.
They are eager to learn	motivation is evident.
b.	Use cases early in the session to indicate the knowledge needed to resolve
the problem situation presented; then present your lecturette offering the
new content. Don't always give the adult students the "facts" until you've
got their attention, proving they need these "facts" to solve the problem.
The Learning Process
Learning is a change of behavior occurring from the process of internalizing knowledge,
skills, or attitudes by the individual student A trainer cannot "learn" his/her students; only they as
individuals can learn. Just because an instructor has conveyed facts and ideas, there is no
guarantee that learning has taken place. Learning takes place only when the student gets

involved in the learning process. Learning is not a passive endeavor. Effective adult learning
involves a mutual partnership between the student and the instructor, each recognizing the other's
responsibility for helping the process of internalization to take place.
By asking questions skillfully, an instructor can confirm if the participants are achieving
the learning objectives. Because the thinking process takes time, the instructor must give the
participants sufficient time to prepare answers.
There are four effective techniques of questioning:
1.	Overhead Question - A question the instructor asks the whole group, used to open
a discussion, introduce a new phase, or give everyone a chance to comment.
2.	Direct Question - A question the instructor directs to a specific participant, used
to request specific information or involve someone who has not participated.
3.	Relay Question - A question from one participant which the instructor relays to
another person or to the whole group, used to help instructor avoid giving own
opinion, get others involved in a discussion, or call on someone who knows the
4.	Return Question - A question from a participant which the instructor refers back
to him, used to help instructor avoid giving own opinion, encourage questioner to
think for himself, or bring out opinions.
If you see some puzzled expressions after you've asked a question, ask your question again
but phrase it differently. Wait to ask your key questions until you've built up to it with secondary
questions. During this preliminary build-up, the participants are "wanning up" and should then be
ready to respond with more thoughtful answers than before. Remember, key questions help the
participants progress toward the main objectives and desired results. Phrase questions so that
they provoke discussion and do not merely require brief answers. Frame questions that require
thinking, organizing, and relating new information with existing experiences. Obviously, you
should carefully prepare your questions as part of your preparation for the sessions.
Basic to effective learning is effective communication. The trainer must always recognize
the pitfalls of ineffective communication in his/her classes.

The trainer must be heard and understood by the participants. Be sure the volume of
your voice is loud enough. Check this by asking participants at the rear of the room if you can be
Demonstrate enthusiasm to keep the topic interesting and participants alert. There are
several ways to accomplish this. First, there is movement. Move away from the podium, go the
chalkboard, or even make occasional trips down the aisle.
Another way of showing enthusiasm is voice inflection. Vary the pitch and pace of your
voice. Speech needs punctuation just as does writing. Pauses allow time for thought, loudness on
key words, repetition to call attention to key principles. These are all forms of emphasis. Try to
use them in your lectures.
A subtler form of enthusiasm is establishing rapport with the group. This evolves into the
creation of good personal relationships with your adult students, giving them the feeling that you
know their problems-being empathic with them.
Enthusiasm can be quietly demonstrated by efficiency created by your own self-confidence.
That is, you trust the group will learn what you have to offer.
Finally, establishing specific learning objectives plays an important role maintaining your
own healthy attitude toward the learning activity. Before each session, you should ask yourself,
"What skills should they possess when we have completed this lesson?" Such a personal challenge
should help you establish your own enthusiasm.
Aids to Help Participation in Learning
If the instructor is to be accountable for helping his/her adults learn, he/she must consider
both the content and the manner it is to be presented. Many studies have been made that show
how little we remember of what we hear. Accepting even a conservative figure, it is known that
after two days the student will forget at least 75% of what he hears.

Audio-visual aids are devices that supplement learning by appealing to the participants'
other senses besides hearing. They may be graphic materials, tape recorder, film, chart, or
blackboard. All of these devices reinforce what is heard.
An important principle to remember is to pace the viewing of visual materials to match
the instructor's narrative. Since the eyes can quickly absorb details, the participant may become
bored until the instructor catches up. A good idea is to show only the portion being discussed at
one time.
Check to see if visuals can be seen by all participants. Check if the participants can hear
the sound; both volume and tone are important to the adult learner. Regardless of the aid,
always introduce it to the participants and explain its purpose. For example, if using 01ms, an
introduction can point out the learning principles to observe. The discussion following the
showing can be summarized through a discussion of the key principles it highlighted.
Use of Aids
Preparation begins before you enter the classroom. You must:
1.	Become thoroughly familiar with the aid.
2.	Plan where, when, and how you will use it.
3.	Ensure that equipment you'll need will be available.
During the actual use of an aid, several factors must be considered:
1.	Always introduce the aid at the time it is to be used in the lesson. This
introduction should be stated before displaying the aid. It should be aimed
at preparing the participants for what they get from the aid, its learning
2.	More than one aid should not be displayed at the same time unless they
supplement one another.
3.	When an aid has served its function in a lesson, it should be removed or
Control Techniques
As a trainer, you will always want to maintain a healthy interaction among the participants.
Students come to class for many different reasons. Some are "told" to be there. Others come
because they really want to learn. Those who are taking the course as a means of getting ahead
may try to dominate the discussion for their own benefit, while those who are willing to learn as

part of their professional obligation may not attempt to get into the discussion at all. The three
most common student problems to be faced by an adult trainer are the "dominator," "withdrawer,"
and "group silence."
How to deal with the "dominator":
The dominator places the instructor in a most delicate position. Impressions given that
the leader is stifling discussion or feels displeasure about the "problem participant" may create a
"threat level" that will discourage others from participating or protect one of its members.
Remember, until proven otherwise, every participant must be treated as though he wants to learn.
1.	Call upon other participants to respond.
2.	Interrupt tactfully with a question or summarizing statement.
3.	When the talker pauses, rephrase one of his/her statements and pass on to
another question
4.	Allow the group to cut this participant off, which they probably will do if
the talking persists.
5.	Subtler method is to rephrase a talker's response and ask others.
6.	More directly, after other attempts have failed, speak to the participant in
private by simply stating the fact, "Your attitude doesn't seem conducive to
learning, and I don't want it to affect the rest of the group. Is there
something I can help you with?"
How to deal with the "withdrawer":
The quiet non-participator may be overlooked because he/she is not interfering in any
1.	Force the withdrawer to participate in a nonthreatening situation. Call
upon the withdrawer after a group exercise to report the results.
2.	Phrase questions in a way to stimulate participation of the withdrawer.
3.	Ask a direct question to the quiet participant
4.	Make direct eye contact when asking a question of this participant.
5.	At the first convenient break, simply ask, "Well, what do you think of the
course so far?" or "Do you think there's anything here that you can use
back on the job?"
How to deal with group "silence":
Silence from a group when there is a lack of response is very threatening to the
inexperienced instructor. The beginning instructor often feels the strain and often tries to fill the

gap with talk, talk, and more talk. Instead, he/she should encourage the members of the group to
express what's on their minds, a lack of interest in the topic, a lack of motivation, a
misunderstanding of the subject, insufficient information, or a feeling of antagonism? Just what?
As an instructor, you must evaluate the situation and then try to correct it. Also, recognize that
seconds seem like minutes to the inexperienced trainer... and "deadly."
1.	Rephrase questions.
2.	Ask for examples of summaries.
3.	Give information without appearing to lecture.
4.	Ease the situation by injecting some humor ... "defuse" the group in any
way possible to relieve the tension if obvious.
In summary:
Know that learning can be fun: helping adults learn can be one of the most satisfying,
fulfilling things you as an adult can ever experience. Welcome to the ranks of the adult educator
glad to have you with us.
by permission of	 Dr. Garland D. Wiggs
The George Washington University
Washington, D.C. 20052

Training Assumptions
2.	Learning may be defined as a change in behavior.
2 Participants bring with them a duster of skills, understandings, appreciations,
attitudes, and feelings that have personal meaning to them and that are, in effect, the
sum of their reactions to previous experiences.
3.	Participants have developed self-concepts that directly affect their behavior.
4.	Learning requires activity on the part of the participants; they cannot be passive.
5.	Ultimately, participants leam what they want to learn; they do not learn what they
do not accept (or come to accept) as meaningful and usefuL
& Learning is enhanced when participants accept responsibility for their own
7. Self-evaluation is important to the learner.
& Learning is enhanced when the learning situation provides an opportunity to apply
new information in as realistic a situation as possible.
9.	Participants are more highly motivated when they understand and accept the
purposes of the learning situation than when they do not
10.	Participants are motivated by experiences of success.
11.	Participants tend to be motivated if they feel accepted by the trainer.
1Z Participants are motivated when they can associate new knowledge with previous
13. Participants are motivated when they can see the usefulness of the learning in
their own personal terms.

14.	Learning is enhanced if the environment is physically comfortable and
psychologically safe.
15.	Mating mistakes is perceived as a requirement of learning.
Seven Characterisitics Of Learning
Twenty-one Principles Of Instructing
Learning Is Growth-like And Continuous
Begin where the learner is.
The new must be related to the old.
The pace must be adjusted to the learner's capacity.
Learning Is Purposeful
The learning must make sense to the learner.
Progress must be constantly appraised and redirected.
Purpose must be kept in sharp focus.
Learning Involves Appropriate Activities That Engage
A Maximum Number Of Senses
Learning results through self-activity.
Activities appropriate to the specific learning situation must be used.
Learning activities should engage a maximum number of senses.

Learning Must Be Challenging And Satisfying
Instructor motivation of the participant is essential in making learning more
Appropriate and timely recognition should be given to participant achievement.
Standards demanded of learners should be suitable to their abilities.
Learning Must Result In Functional Understanding
Memorization alone is temporary unless reviewed or put to use in a practical
Course content should be organized into meaningful units.
Activities that stimulate situations are most effective.
Learning Is Affected By Emotions
The instructor should strive to increase pleasant emotions and decrease
unpleasant ones.
The intensity of emotional feeling affects learning differently in different
The expression of emotions is highly trainable.
Learning Is Affected By The Physical And Social En-
The general physical environment should be suitable to the kind of learning
taking place and to the activities selected for use in the learning situation.

Specific physical factors of the training room should be suitable to the kind of
learning taking place and to the activities selected for use in the learning situation.
The instructor should recognize and use the effects of the social environment on

Trainer is enthusiastic and well informed
Information and opinions are welcome
Group is involved in the process
Atmosphere is comfortable and relaxed
Course is well structured and designed
Content tailored to group needs
Content and design flexible



Active student is persuaded, not told
Experience of student is valued and used
Student evaluates self and trainer
Material applies to student's life and
Content is discussed and
discovered — not "hammered-in"

Emphasizes the skills of analysis and

decision making thru cases
Establishes a learning rather than a

teaching approach
Practical and job-based

10% of What They Read
20% of What They Hear / SOUND
of What They See
50 %| of What They
Hear & See
90 %| of What The
Say as They
Do a Thing


Setting the tone
Facilitating participation
Varying approaches
Solving potential problems

Agenda On Flipchart Or Transparency
Regular Summary And Forecast
Frequent Reference To Agenda
Relate Comments To Overall Points
Know In Your Mind What's Next

Training Fact Sheet: "Preparing For
Preparing Your Materials
When you prepare handouts, either to include in advance materials, or to give
people after your course is finished, think first about your purpose.
¦	Do you want to remind people of what you said?
¦	Do you want to ranraliye them with what you are about to say?
¦	Do you want to give them clear instructions about an exercise or case study?
¦	Do you want them to read the material later as an amplification of what they
¦	Do you want them to find more detail about what they already know, or just
reinforce it?
¦	Will the materials be used for reference?
¦	Would you like participants to distribute the materials to others?
There will nearly always be some people in a course who want to pursue the
subject further, and you may want to provide them with a bibliography or list of
groups and people they might consult. In designing the materials, try to put
yourself in the position of the trainee. What would you want to know? How much
would you already be likely to know? How much background would you need? If
possible, talk to some people like those who will be participating, and get their
Once you have drafted the materials, get other people's comments about
them—particularly those who know little or nothing about the subject. They are
most likely to pick up on anything obscure or inconsistent, unless you are dealing
with a highly technical area. Expect that you will need to revise your draft at least

In considering audiovisual aids, be sure that they are merely aids, rather than ends
in themselves. An overhead projector, showing the outline of what you are doing,
can be useful in an extremely large group. But it means a darker room where
people are much more likely to nod off. If your purpose is to maintain a good
connection with the group, any visual aid is likely to dilute your contact with them.
On the other hand, a video or film can be most helpful in changing pace,
especially in a course that lasts several days. If you decide to use any audiovisual
aids, know the equipment backwards and forwards, or who the technician will be,
and have phone numbers you can call if something goes wrong—despite the fact
that you will have run the whole operation through at least once on the equipment
you will use.
Preparing Your Space
You will probably be more comfortable and effective if you can select the room
and arrange the seating to suit the group. Be sure that you see the space in
advance and have a clear picture in mind of how you will use it. Know who has the
key to the room, if it will not be open, and specify the equipment you will need:
¦	Flipchart
• Fresh markers
¦	Paper for flipchart
¦	Paper/pens for participants
¦	AV equipment
¦	Tables or not
¦	Podium or table for notes
¦	Water
¦	Name tags

¦	Access to Xerox machine
¦	Pointers
¦	Tape or substitute
You may have you own peculiarities, but this is a good beginning list Consider
•	Space
Do you have a comfortable fit between space and the number of participants?
Hie interaction will be very different if a few people are swallowed up in a
cavernous space, or if they are crammed together. If you feel that the space is too
big, use room dividers, if available, or keep the lights out in one end of the room.
See if there are visual tricks you can play to make it seem smaller. On the other
hand, if the room is tiny, dear everything out of it except the flipchan, a table for
notes, and the chairs. If possible, leave the door open. Flan in advance for
breakout space, if you need it
¦	Chairs
If you have a choice, be sure the chairs are the most comfortable available, no
matter how they look. The chairs will have more to do with how well people listen
than almost anything e'se you do. Arrange them in a way that suits your purpose
welL If you want the participants to talk with each other and connect well, give
them an arrangement like a circle that will help them see and talk with each other.
If you want all their attention on you and the fiipchart, try a more conventional
configuration. You may also want to vary the seating, especially if you are working
with them more than a day.
¦	Tables
If participants have to take extensive notes, tables can make them less physically
tired and enable them to spread out comfortably. The price is that tables divide
people from each other, and can get in the way if you want the group to break
down into smaller units other than pairs.
•	Clocks
Try to set up the room so you can see the clock, but the participants can't. If there
is no clock, bring some timepiece of your own with an analog dial. You can't
glance at a digital display as quickly as you can an analog display.

¦ Orientation
If the room has a gorgeous view out the window, set up the room so you look at it,
rather than the participants. They will have natural light coining in over their
shoulders, and will be focused on you and one another, rather than the beauties of
the great outdoors. If you have a choice between a blank wall and one that is
duttered up with doors or equipment, choose the less cluttered one. The less
people have to be distracted by accoutrements, the better.
¦	AV Equipment
If you are using AV equipment, be sure that it is installed and in working order.
Run through what you will have to do with it, if there is no technician, and double
check the phone numbers for people who can repair it, if something does go
¦	Flipchart
Be sure that there is enough paper to meet your requirements, and then double
that amount Markers are usually old, so be sure you get some fresh ones. Prepare
all the flipcharts you want to have ready in advance. If some of them will follow
group discussions, when you expect to use up blank pages, consider putting the
prepared flipcharts at the back of the pad, and tabbing them with paper and tape
so a number or word indicates where each one is, or using paper dips for the
same purpose. The flipchart should be used not only to keep the group dear
about what will come next, but also to clarify and order their discussion so they
can see how they are related to the course topics.
Be in the training room at least an hour before your session begins. Try to make
the final arrangements and head problems off at the pass. A few partidpants will
be there 15 minutes early, and you want to be ready when they come.

Preparing Yourself
1.	Recognize and build on your strengths as a trainer.
Ask others what you do well, and use your own good judgment. If you have a
strong voice, be aware of how you use it If you know the subject backwards and
forwards, use that as a confidence builder. Write down some of the things you
know and do well on index cards as reminders for the times when anxiety is
building. Figure out bow you can strengthen your strong suits still
further—through practice or amplification, using them in new settings, or
2.	Identify and erode your fears and anoedes*
Be very exact about what is bothering you. When you fantasize a disastrous
scene in the training room, what is it? Is it yourself drying up, or getting no
response from the group? Is it being attacked by a hostile participant? Be as
specific as possible, and work with others on what you would actively do to
change the situation if it arose. Role play if you need to, in order to give
yourself more confidence.
3.	Diagnose and practice improving creas in which you are weak.
Ask friends and observers whether you have verbal or non-verbal mannerisms
which could distract an audience. Most of us say Tim" or "Uh," put questions at
the end of our sentences when they are not appropriate, and have irritating
fidgety or other non-verbal tics. Watching yourself in a mirror, or listening to
yourself on a tape, you will soon find them just as irritating as others do, and
will be more conscious of them. Think about what you will do instead. In the
case of verbal mannerisms, reminding yourself before you begin to speak that
you do have something important to say, and can say it clearly, may help.
Non-verbal mannerisms usually have to be extirpated by replacing them with
something else. If you play with a pencil, be aware of arranging your hands
differently and perhaps keeping pencils away from the training room altogether.

4.	Rehearse in front of a mirror, with friends, and especially with peers who are trying
to leam the same skills.
Ask an ally to attend your training session, so you can get feedback from a
supportive peer. Tape what you say and listen to yourself. See if it makes sense,
and bow you sound. Get as many opinions of your performance as possible.
5.	Clear away false obstacles.
Don't wreck your composure by having any concerns that are unnecessary. Try
your clothes on a few days before the event and make sure you didn't spot that
blouse or those trousers. Think about transportation in advance. What time
will you have to leave home, and how, to get to where you're going in good
time? Preparing your material well in advance, and knowing it thoroughly, can
alleviate some (although probably not all!) of the anxiety every novice feels.
6.	Make sensible fined preparations.
Get enough sleep the night before the session. Prepare flipcharts and other
materials in advance, so you don't have to worry about them. Review your
notes only as much as necessary; don't obsess. By the time the day itself comes,
you know what you are going to know, and the rest has to wait Remind
yourself of your strengths and what you are trying to do. Remember why you
wanted to teach the course in the first place. Finally, put it in proportion: none
of the participants will die if the day doesn't go perfectly, and neither will you.
Training Fact Sheet: "Preparing For Training" was prepared by:
Mary Dingee Fillmore (617) 969*4974

Visual Aids
This is a visual world. There is much evidence that people of all ages not only
understand, but also retain what they $££ significantly longer than what they
merely hear.
Everyone is aware of the power of pictures, words, sounds, and action when they
are skillfully combined.
Visual aid materials have useful powers in communication: they compel
attention, help an audience to understand ideas and items which are too complex
for verbal explanation alone, and they can help overcome limitations of time, size,
and distance.
Some examples of visual aids that you can use to make your lectures more
effective are:
¦	Paper Flipcharts, Chalkboards and Magnetic Boards
Use to list major points; to list ideas generated from the class; and to summarize.
If diagrams or words are applied before starting your presentation, tape sheets of
blank paper over them and remove them at the appropriate times during your
• Graphic Techniques
Application of certain graphic techniques are important for preparing graphic
materials to dramatize, explain problems, or demonstrate.
¦	Projected Materials
Overhead transparencies are particularly useful for addressing large groups. The
screen becomes a large Qipchart. You operate an overhead projector in the front
of the room as you stand or sit beside it, facing the audience. You can point to
details, write or draw symbols on the transparencies while they are projected on
the screen.
35 mm slides can be handled and stored easily and are an adoptable medium for
nearly all types of presentations. Slides are arranged in trays and with a
remote-control attachment you can operate the projector from the front of the
room. To use slides effectively, room illumination must be markedly reduced.

¦ Recorded Materials
Audio recordings. Use a tape recorder to judge the "audio" pan of your speech.
Your inflection, the number of pauses, the "ahs," and other speech mannerisms
become immediately evident
Videotapes, carefully chosen for relevance to your subject matter, are often a
graphic and interesting way to stimulate thinking about a problem; to impart
knowledge, or to change attitudes. To be effective it must be followed by a group
discussion during which you analyze the particular situation.
Videotapes can also be very effectively used to see and hear yourself as you give a
speech, to be able to study your body movements, facial expressions, and the
manner in which you use your visual materials can be a constructive revelation.

"Let's Assume That You Are Faced With The Task Of Preparing A Slide/Tape
Program. Where Do You Start?"
By Stewart LBurge
It can provide elegance and aesthetic appeal... impact and sensory involvement
"It" is the use of slide/tape programming which, with a reasonable amount of
planning and creative forethought, can add all these things and more to virtually
any training program.
The slide/tape medium is common to most organizations. It is used for
new-employee orientations, sales meetings, management-development
presentations, and dozens of other applications where audience impact,
production economy and program flexibility are paramount
Like any other communication endeavor, the success of a slide/tape presentation
is directly related to the amount of planning that goes into it This is Cardinal
Rule Number One and holds true no matter how simple or complex the finished
product may be.
Let's assume you are faced with the task of preparing a slide/tape program. Where
do you start?
The real pros begin by putting down on paper three elements that are so obvious
they are often disregarded:
1. Objectives of the program
A written statement of what your program is intended to accomplish helps
crystalize your thinking and direction. Having those objectives in writing allows
you (or your boss) to refer to them at any time during the production phase of
the project to insure that each component being built into the presentation
contributes directly toward your overall purpose.

Z A description of the intended audience(s)
A written audience description is vital in gathering and presenting materials
that apply directly to the people you are trying to reach.
3. A content outline
After stating your objectives and defining your target audience, you are ready
to collect and organize in outline form the content materials which support the
program's objectives. All applicable materials and ideas—both visual and
verbal—should be written down and saved, even if some of them eventually
are discarded.
A popular and extremely helpful aid in the program development is the
stoiyboard which serves as a blueprint, and lets you visualize your progress and
make necessary modifications.
Plain white 3x5 inch or 4 x 6 inch index cards are usually used in the initial
planning stage. The idea is to indicate on the cards each point you want to include.
The first card should indicate what the first slide in your finished program will
look like; each successive card will show subsequent slide changes.
Exciting ideas frequently result if you call on some in-house creative help and
brainstorm the program. Often, excellent ideas develop from what may at first
seem to be impracticable suggestions. Encourage far-out thinking. You have
nothing to lose at this stage of the game.
When the first stoiyboard "draft" is finished, the editing process begins. Cards
with similar ideas are grouped; concepts that are impractical for filming, or that
don't correspond with your objectives, are set aside (not discarded); and new or
substitute cards are added.
When you are satisfied with the results, secure whatever approvals are needed.

Single Screen
For purposes of discussion, let's assume you will be using a single-screen format
for your program. This is the simplest and most economical way to go, but still
permits some degree of latitude in the hardware to be used. Several of the most
common equipment configurations for showing the program on one screen
¦	One 35 mm projector, one tape playback unit (either cassette or reel-to-reel)
and an operator with a dearly marked script in band who manually advances
the slides to correspond with the taped audio portion of the program.
¦	One projector and a synchronizing tape recorder which automatically controls
the projection equipment. The simplest and least expensive of these are
cassette-tape units which use an inaudible "beep" to signal the projector to
advance at predetermined points in the audio track. Using such a device
permits showing of the program time after time with the slide changes always in
perfect synchronization with the audio.
¦	Two 35 mm projectors, a "sync" recorder, and a dissolve unit which connects the
two projectors and provides smooth, professional-looking slide changes without
annoying blackouts between slides.
We list three combinations here, but the variety of programming and
dissolve-control equipment is vast. If you want to explore the hardware field or
need to add to your A-V arsenal, it's a good idea to talk to some of the
audio-visual equipment suppliers listed in the Yellow Pages. Management types
like the term "cost-effectiveness," and this is a good concept to keep in mind when
considering A-V hardware. Sophisticated equipment is expensive and the special
effects it makes possible should be viewed with a "Do I really need it?" attitude.
After the stoiyboard has been developed to your satisfaction, the next step is
usually a "running script" or "shooting script" We balk at the term "final script"
because one of the beauties of the slide/tape medium is that changes and
modifications are possible-and often desirable—at any point through the final
slide-editing process.
There are a number of formats for the running script A typical arrangement
consists of blank rectangles positioned down the left side of an 8 1/2 x 11" page (to
indicate the sequence of the narration, descriptions and cues for music and sound
effects and production notes indicating pacing, dissolves, etc.).

The keen writing and photographic abilities of the (one-person?) production crew
comes into play at this point
Because viewers must assimilate a considerable amount of information in a
limited amount of time, with no chance to stop the program and repeat a specific
point, it is vital that all elements of the presentation be presented clearly, simply
and logically.
All graphs, charts and titles must be reduced to their simplest form so they can be
easily read and understood. "Scenic" slides should be uncomplicated and of the
highest technical quality. The recorded narration should be well-organized and
use simplified terms and concepts written in a conversational style.
Remember that A-V involves a blend of audio and visual elements to create
feeling and involvement among the audience. Getting the right balance requires
pacing, timing, good aesthetic judgment and practice.
After the sound track is recorded and all the slides are takes and arranged
sequentially in trays, it's time for the first rehearsal. This involves setting up all
the equipment and running through the entire program. It's a good idea to take
notes on any changes that need to be made, any equipment that is missing or
needs repair and other pertinent information.
"Gee, boss, I'm sorry I forgot about that," does little to compensate for faux pas in
your presentation.
Cardinal Rule Number Two: Rehearse the program until you are tired of seeing
and hearing it.
As a parting shot, here is a brief check list that may help your presentation run
more smoothly.
¦	Make sure circuits (and extension cords) can handle the electrical load of your
¦	Use simple, reliable projectors. Kodak Carousel and Ektagraphic models are
probably the most often used.
¦	Automatic-focus projectors are definitely worth their slightly higher cost.

¦	If at ail possible, have on hand a fully focused projector in case of problems. It is
far easier to swap projectors than to attempt to change a red-hot lamp that has
burned out
¦	Clearly label all slide trays, tapes and boxes.
¦	Unless there is a very good reason, don't splash too many images onto the
screen in rapid-fire succession. By the same token, images left on the screen for
too long a time lose the audience's attention. The content of each slide and
common sense dictate the length any particular visual should remain on the
¦	All slides should be relevant, attractive and easily understood.
¦	A dynamic audio recording is an important element and care should be used to
insure a good balance of audio and visual elements to elicit audience response.
¦	If possible, keep all slides in a horizontal format when shooting and projecting.
¦	Use blank (opaque) slides at the beginning, end and anywhere in the body of
the program that calls for a black screen. It eliminates squint-producing glare
from a suddenly white screen.
• Many creative slides can be produced by copying graphics and still photos on a
Stewart Burge is editor of Management and Share Owner Information for the Mead
Corp. in Dayton, Ohio. He has a bachelor's degree in journalism and a master's in
communication, both from West Virginia University.

Training News
A Monthly Newspaper for the Trainine Professional
"Discovery Learning"
And Technical Material
Can The Two Be Matched?
Frederic H. Margoiis
This article is about a revolution, a revolution that is going on right now. It's
similar to the one that started about 30 years ago when management training
curricula switched from an information-based (pedagogical) approach to a
"discovery-learning" (or andragogical) approach. This time, the revolution is
taking place in the training programs for people engaged in high technology and
professional areas: computer science, accounting, insurance, real estate law,
medical science, and so forth.
Traditionally, the training programs in these areas have focused primarily on a
straightforward conveying of information. The approach seemed logical because
the people working in high technology and the professions have a very simple
need, the need to stay current with their fields. Their abilities depend on their
knowledge of their subjects. Accountants can't issue reports on financial
statements unless they know recently-issued principles of accounting. Accurate tax
services cannot be offered if new tax laws aren't understood. Hence, both learners
and instructors expect the training to consist of a simple process of acquiring
But simply teaching the prescribed knowledge is not sufficient If you are involved
in information-based training programs long enough, you begin to hear revealing
comments from managers and participants.
These people have learned the principles, but they don't know how to apply

* This training program doesn't reflect the real world."
¦	"Some of the information was useful, but most of the session was over my head."
• 1 knew most of that stuff before I came to the course."
¦	Too many lectures and slides. After a while, it all seemed the same."
Many trainers have realized that relying primarily on the process of conveying
information is not as effective as they want. Even slides, movies, and occasional
discussions are limited in what they can do.
An Andragogical Revolution
The revolution started when some organizations started using job-related
"discovery learning" approaches in their training programs. I was asked to be a
consultant to such a company which developed over 75 professional and high
technology courses. The subsequent six years of helping them develop their
courses taught me a lot about the andragogical approach. .
The first problem I encountered was explaining the differences between
information-based and "discovery learning" approaches. "Discovery learning" is
the essence of andragogy and, while most people by now understand what that
means, perhaps a review of the definition is in order. Andragogy has been called
"the an and science of helping adults to learn." It stresses mutuality and respect
between instructor and learner, as opposed to the authoritarian, formal climate
cultivated by pedagogy-the science of teaching children.
It is not easy to explain all the differences between andragogy and pedagogy and
there is much room for misinterpretation, so my initial job was to develop a
checklist for determining the degree to which a program is information-based or
andragogically based.
1.	Are participants given presentations, films, or readings followed by a series of
problems or cases to which they apply that information?
2.	Are participants given problems or situations to analyze or solve followed by
the information needed to analyze or solve the problems?

3.	Are problems or cases designed primarily to help participants understand the
4.	Are problems or cases designed primarily to help participants do their work
more effectively?
5.	Is 50 percent or more of the training time used by participants to read, listen to
presentations, watch films or slides?
6.	Is 70 percent or more of the training time used by participants to actively
engage in problem-solving, analysis, or decision-making usually with the help of
other students?
7.	Is the primary job of the instructor to present information, discuss questions, or
pose reinforcing questions to the class?
8.	Is the primary job of the instructor to help, consult, advise, and pose problems
to be analyzed (both individually and in small groups) and then manage an
interactive discussion?
There could be more questions, but by now you've gotten the point.
An andragogical approach:
¦	Emphasizes the skills of analysis and decision-making through a series of
¦	Establishes a learning approach rather than a teaching approach by a series of
planned structured activities enabling the learner to acquire the appropriate
¦	Is a practical job-based approach which keeps the learners constantly aware of
the value of the training program to them and their work.
Applying Andragogy
If you want to use the checklist on your own programs, the odd-numbered
questions tend to get "yes" answers when the program is information-based. The
even-numbered questions tend to get "yes" answers when the program is more

If your answers are mixed, review the questions again. Perhaps you missed a
subtle issue. If your answers are still mixed, then you may have a little of both in
your programs. You are on the road to revolution yourself!
Once you have understood differences between information-based programs and
"discovery learning," the next step is to work with technically knowledgeable
people to write the courses. When I first started working with technical people,
my responsibility was to help them (1) select the content, (2) sequence the
content, (3) select methods which emphasized discovery learning, and (4) write
the course so they or others could teach it.
Here are some other issues we confronted:
Motivation. We started with the idea that most professionals are motivated to
work and motivated to learn. The motivation to work is stimulated by having
interesting work to do, progressing in the profession, financial reward, and
appreciation and recognition from supervisors and clients.
The motivation to learn is closely tied to the motivation to do better work.
Training courses must tap into this aspiration. Courses that are seen by learners as
closely tied to work skills are considered relevant: those which do not appear to
be related to work content or processes may be seen by trainees as peripheral of
Inappropriate, boring, or seemingly peripheral training programs can actually
reduce or temporarily extinguish the motivation that participants bring with them
to the course. So competently designed training programs build on the existing
motivation through careful selection of content and methods.
Selecting the Content Different methods of carrying out a need diagnosis can be
used, depending on the type of course, experience of the learners, and how
frequently the course is to be offered.
Regardless of the diagnosis method, however, you must use the technical experts
in the process because they are the ones who know what the trainees have to
learn. On the other hand, the need diagnosis method should only identify what
the learners need to know for their present job or work they will be doing in the
near future. Anything else is going to undermine motivation.

You will find that most technical people have difficulty in limiting the content of a
course. They want to include "everything." The best way to deal with this impulse
is to use challenging questions.
¦	Why do the trainees have to know that?
¦	If they know this, how will it help them on their jobs?
¦	If they don't know this, how will it affect their work?
Selection of Methods. The general labels that trainers use for interactive methods
don't always work for technical experts. Merely using the words "case,"
"discussion," or "question and answer session" does not convey to the technical
people any picture of the learning that will take place. The challenge is to create
specific activities that will obviously help participants improve the skills of analysis
and decision-making they need.
I tried to meet the challenge by developing a series of specific activities or tasks
for each course using a standard format.
1.	A brief introduction and explanation;
2.	Detailed specific instructions for the participants to follow;
3.	The participants' active engagement in these activities—whether small group
discussion, question and answer sessions, or whatever, followed by
4.	A sharing or synthesis by the participants; and
5.	A summary of presentation by the instructor based (not on prepared texts but)
on some of the comments produced in the activity. This can also incorporate
examples, presentation of principles, or practical experiences.
Each activity selected should be checked against the following criteria. What is
the degree the structured activity:
¦	Achieves the intended learning goals
¦	Is job-related
* Requires investigation, analysis, creativity, or decision-making

¦	Is challenging
¦	Requires new thought or synthesis and not simple regurgitation
¦	Is seen by participants as useful and will help them develop technically and
Resources Needed
In the process of discovery learning, the central person is the course writer. This
person must have competence in the technical aspects of the course as well as
competence in andragogical methodology.
The writer's technical competence is supplemented by a consultant who is
technically expert in the content area. The technical expert assists in deciding on
the content and final approval of the technical aspects.
The writer's methodological competence is supplemented by a consultant who is
experienced in andragogical methodology. This person helps determine the
sequences of methods to accomplish the learning goals, and is responsible for
checking the methodological approach.
Usually, instructors for high content courses are technically competent people
who lack experience in teaching an andragogical course. The course, then, must
be written with great detail and attention given to managing the discovery
learning process as well as outlining the content that has to be learned. And no
matter how explicit the course design is, there must be an instructor-training
course emphasizing the skills of presenting and managing the five-step activity
format mentioned above, as well as the skills of facilitating group discussion.
Just because the content of a training program is very technical or dense does not
mean you have to rule out the excitement and effectiveness of discovery learning.
In our project, we developed 75 courses, of which a few were:
¦	Computer Modeling
¦	Making Computer Hardware/Software Choice
¦	Advanced Statistical Samplings

¦	Corporate Reorganizations and Business Acquisitions
¦	Auditing Hospitals and Medical Services
¦	The Principles of Escrow
When the training director of this program was asked why his company switched
from an information-based to an andragogical approach, he answered, "It works.
Knowledge increases and is better retained when information is applied to
job-related situations. We also found the skills of analysis, problem-solving, and
decision-making were improved when participants actively engaged in job-related
problems. Most important, confidence and ability increased when participants
successfully demonstrated professional competence in job-related situations in the
training course."
Discovery Learning in Action
This transcript is an excerpt of a consultation between a technical writer and a
training consultant They are designing a course for mortgage analysts employed
at a financial institution who make decisions on home mortgage applications.
Note how the consultant focuses on practical, job-skill exercises and tries to cast
the material in the five-step format outlined in the accompanying article.
Writer. This is a very important course. The way to get ahead here is to know how
to analyze mortgage requests.
Consultant. What does a good analysis entail?
Writer. It involves getting the appropriate information, checking it, applying a
debt/income formula, then deciding. We have to tell the participants to apply the
formula and how to decide what mortgages should be approved. In the past we
have had our mortgage manager lecture for two hours using some excellent slides.
He explained the whole procedure.
Consultant. Why aren't you continuing to use that program?
Writer. Well, the participants seemed to understand, but when they got back on
the job they had trouble making the right decisions.

Consultant Let's see if we can figure out some other ways to help them learn.
You said that there are four steps in the mortgage process:
1.	Getting the appropriate information
2.	Checking it
3.	Applying a debt/income formula, and
4.	Making decisions
Do they know what information to gather?
Writer. Yes. All they have to do is fill out the form. They don't have any problems
with this pan.
Consultant Good. Then, we don't have to work on that issue and we can
concentrate on the more important ones. Do they have any problem in checking
the accuracy of the information?
Writer. No. The procedure manual is clear, and there is no problem following it
Consultant What about applying the formula?
Writer. The actual applying is not a problem, but they need to be told how to do it.
Consultant. Tell me about the formula.
Writer. It's simple for new loans. All they need to do is determine all income and
all debts. Then, see that the annual debts are not more than 34 percent of the
annual income.
Consultant Do they have any problem applying the formula?
Writer. Not in applying it But they often do not always include all income or all
debts. We have to be sure they know what they must include.
Consultant One way to do that is to ask the participants to list all the different
kinds of income and debts that usually appear on a mongage application. That
might be better than lecturing them.

Writer. No, that's not quite right. It's not just knowing about income and debts:
it's analyzing the applications.
Consultant I see. So, we might give them some filled-out applications and ask
them to list all the income and all the debts indicated. The first being
straightforward and another having some hidden income or debts.
Writer. That's good. It's what they have to do as part of their job.
Consultant. Let's be more specific How does this activity sound?
1.	Brief introduction explaining the problems and importance of accurately
identifying income and debts.
2.	Hand out an application which is simple and straightforward.
3.	Ask participants to list all income and all debts on a form we will provide.
Groups of three might be best, giving them the opportunity to help each other.
4.	When they are through, one group can read their income list and other groups
can agree or add to the list. Then, another group reads its lists of debts, etc. When
the reporting is complete, the instructor can comment, add, or correct, if
5.	Then hand out a more complicated application involving child support,
alimony, income from a partnership, gifts from an estate, and a condominium fee.
6.	Ask the same groups to repeat the procedure of analysis, listing, and reporting.
In this situation, there will probably be some disagreement as to the amount of
income or debts. The groups should be allowed to fully examine the issues before
the instructor comments. What do you think?
Writer. I like it It offers the participants a chance to examine the issues and it
actually gives them practice in doing the analysis.
Consultant. Now let's look at the issue of decision-making. Is it largely
mechanical or is there room for judgment?
Writer. Ninety-five percent of the applications are clear-cut and mechanical. It's
the five percent that cause the problems. These are the cases that just barely meet

the requirements or in some cases don't meet them, but have mitigating circumstances,
such as other non-income producing equity.
Consultant. What are the usual problems?
Writer. Three things:
1.	The mortgage analysts apply the formula too rigidly,
2.	They don't take into consideration discretionary income, or
3.	They don't consider future problems. For example, if an applicant just barely
has enough income to make the monthly payments and is buying a very old house,
we have to consider the probable extra expense of repairs.
Consultant. Are the criteria clear?
Writer. There are some guidelines, but at our institution it's still a judgment call.
The manager used to include several examples in his lecture.
Consultant. Here is another idea. Perhaps you could identify two or three real
applications that fell into that five percent area. We could use them to help the
participants gain insight into the problems.
Writer. Good idea. Using real situations will increase their interest.
Consultant Perhaps this sequence might work:
1.	Introduction and explanation of the formula and how to apply it with an
explanation of the professional judgment that is required in special situations.
2.	Hand out two applications, both of which are difficult decisions.
3.	Groups of three or four analyze them and decide whether to accept them for a
home mongage or not, and then explain the reasons for their decisions.
4.	Each group repeats their decision—one case at a time-and the reasons for that
decision. When all groups have reported, then
5.	The instructor shares what the institution had decided and why.

6. Then the instructor summarizes the guidelines for accepting mongage
applications, relates some of his/her personal experience, and answers questions.
It's not really important if the groups agree with what your institution decided.
What's important is their learning the process of thoughtful analysis.
Writer. Great! The participants will like doing that, and it will help them in the
areas they need the most help. Now that we decided that, what's the next step?
Consultant Well, it has to be written in much more detail. The instructions to the
training must be explicit and clear...
Frederic H. Margolis is an independent consultant in training design, training
delivery, organization development, and conflict resolution. He has spoken at over
thirty national conventions, authored numerous articles, and is a director of
Andragogy Press, a company specializing in andragogically-based, packaged
management training programs.
Reprinted with permission from November, 1981 issue of Northeast Training News.
61981 Warren/Weingarten, Inc.
Northeast Training News
178 Federal Street
Boston, MA 02110 (617)542-0146

The National EPA Institute Instructor Symposium
18-19 November 1966 Washington, D.C.
How To Give A Technical Presentation
To A Nontechnical Audience
Beverly Carlson Qulnn
The Skill of Interpreting Is an essential communication
skill for adapting technical information to individuals with
limited knowledge in a technical field. It requires
technical speakers to change their way of thinking and
Interpreting Is explaining the meaning of something.
This seems straightforward and obvious but It is difficult
to convince technical speakers to use the skill. Technical
speakers/Instructors consistently present technical
Information Instead of presenting what the information
means. Thl9 leads to the frequently heard comment that
technical people know their subject but do not know how to
explain the information to others.
There is a reality that needs to be acknowledged regarding
technical Instruction to nontechnical trainees. Due to the
nature of the work place, trainees have a minimum amount of
time to acquire a working understanding of technical areas.
These trainees do not have the time nor do they often want
to become technical experts in every field. What they want
from the technical instructor is:
In other words, they are asking you to Interpret for them.
The Skill Of Interpreting Copyright 198? Beverly Carlson
Ouinn All rights reserved.

Interpetlng Is identifying the essence of the technical
information and presenting it in an understandable way.
Three criteria help determine when you are Interpreting.
They are:
1.	No Technical Language. Use Everyday English.
No technical Jargon. No technical terminology.
No acronyms.
Nontechnical listeners want to hear the
technical information in the language they
understand, which is Plain, Everyday English.
2.	Streamline the message.
Cut through the details, methodologies, and
complexities of a field and get to the main
elements the trainee needs to know and use.
3.	Answer the question: "What does it mean?"
Nontechnical audiences do not want technical
information. They want what that Information
means and how It relates to their immediate
If you have difficulty determining the meaning of the
technical Information, try the "One Word Technique". This
technique states the meaning of the presentation in one
word. The presentation is then developed around the word and
adapted to the audience. Reducing the message to one word
without technical terminology or Jargon cuts through the
complexities and details and focuses on the meaning of the
information to be communicated.
Having determined what the Information means and how it
relates to the student, the next step is to work the
interpretation Into the Instructional presentation. This is
done through the support material selected and the visual
aids used.
Support material adds substance to the main points In the
form of stories, comparisons, examples* statistics,
illustrations, descriptions, testimony, and quotations. This
support material gives specifics and helps the trainee
develop a better understanding of what the main points mean.
Support material also adds Interest to any presentation.
The Skill Of Interpreting Copyright 1987 Beverly Carlson
Qulnn All rights reserved.

Visual aids are another way of working interpretation into
an instructional presentation. Visual aids provide a fast
message for what would otherwise take many words to
describe. Visual aids help nontechnical audiences
Immediately see what is being explained.
Far too often technical speakers/instructors use visual aids
that become a reading exercise for the audience instead of
providing visual support for listening. When audiences
concentrate on reading visual aids with voluminous notes and
complicated charts, they stop listening to the speaker or at
best hear only intermittent phrases.
Visual aids should reflect good Interpreting. They should be
In Everyday English, streamlined with only key words,
phrases, or pictures that can be Immediately understood.
Vhat happens when Instructors know how to Interpret but are
not doing it? If this happens to you, Identify why it is
4 It could be you are not thinking and from habit
use technical JArgon. Alert yourself to the
different audience and adjust your words
+ It could be a fear of 'talking down" to an audience,
of appearing simple. Interpreting, by getting to the
essence of the information and stating It in the
listener's language, allows you to talk "with"
nontechnical trainees, not "down* at them.
+ It could be an "expertise power play" designed to
establish the Instructor's superiority over the
less knowledgeable trainee. This power play may
give a momentary sense of dominance but it has
longer term costs.
Ve live with a paradox today. As our information and
technologies became Increasingly sophisticated, complex, and
specialized, there is at the same time a need to explain
this Information and use of the technologies to individuals
who have little understanding of them. Interpreting Is the
key to bridging the gap and developing successful
The Skill Of Interpreting Copyright 1987 Beverly Carlson
Qulnn All rights reserved.

How To Give A Technical Presentation
To A Nontechnical Audience
Excerpts from: "Observations and Thoughts On Interpreting".
The Skill Of Interpreting.
Beverly Carlson Qulnn. CO Enterprises.
McLean, Virginia. 1986.
SIMPLICITY IN COMPLEXITY is what interpreting is about.
Complexity is.scaring people. With increasing complexity
today, people want simplicity as a way of managing what
otherwise overwhelms them. For me, simplicity is the essence
of complexity. It is cutting through the countless details
to identify the underlying patterns, e.g., the main focus,
what it means and how it can be used.
The ROLE OF THE INTERPRETER is to take the meaning of
information in one language and translate that meaning into
a second language. Many technical speakers persist in using
technical terms or phrases which they mix in with their
general interpetation. To the nontechnical audience, these
terms are like a foreign language and tend to be
Incomprehensible. Technical speakers need to realize that
when their interpreting is done correctly, their information
is conveyed completely in the language of the listener.
BILINGUAL EXPERTISE between a technical language and
everyday English is urgently needed today. A technical
language is necessary for the precision required in
research, development and operations within a field. At some
point, however, the information, procedures or technologies
within a field need to move Into an application or use. As
individuals from outside the field become Involved,
interpreting becomes necessary.

Excerpts from: "Observations and Thoughts On Interpreting".
The Skill Of Interpreting.
Beverly Carlson Quinn. CQ Enterprises.
McLean, Virginia. 1986.
Examples of this are:
*	Technical experts have an Idea or proposal that must
go before management or potential Investors to get
*	Technicians can design and build a sophisi cated
piece of technical equipment, software or system but
then must explain how to use it to someone without
the technical background. If the users cannot
understand how to work with the equipment, they will
drop your product and use someone else's that they
do understand, even If yours Is technically
superior. Organizations annually discard technical
equipment that is too difficult to learn how to use
and whose sophlsicated capabilities are not
*	Potential buyers outside your field need to
understand what your product or service will do for
them before making a commitment to spend money on
that product or service. Your technical knowledge is
not the basis for their decisions. Their
understanding of your product or service is the
basis of their decisions.
Interpreting between a technical language and everyday
English is more than a word-for-word translation. Each
language has its own patterns of thought and way It puts
information together. Each language also has its own manner
of expressing those patterns. There are nuances and
subtleties of expression that do not translate directly but
do influence meanings.
Interpreting starts with the meaning of the information
in the technical language and puts that meaning in the
everyday language of the listener. This Involves using
different phrases, different expressions, different
formating of information than would be used when talking to
a technical person in the same field. Technical specialists
in other fields will listen to your Interpretation and then
reformat the information into the thought patterns of their
field. Managers, customers and buyers will do the same.
There is a need to develop a fluency in interpeting for
quick, smooth, creative communication. Those individuals
that develop this bilingual skill will be in great demand
because the need to communicate between technical fields and
nontechnical audiences wi11 continue to increase.

Excerpts from: "Observations and Thoughts On Interpreting".
The Skill Of InterprPtino.
Beverly Carlson Quinn. CO Enterprises.
McLean, Virginia. 1986.
(cont inued)
will major and become the next experts in the field are
nontechnical when first introduced to aspects of their
chosen field. At that point, good interpreting of the
concept or term should be used to move the students Into the
meaning of the Information and provide a basis for learning
the technical aspects. Often the education process is done
the other way around...flrst teaching the technical terms
and then coming to some understanding of what the terms
A typical scenerlo introducing new concepts or material
is to present a lecture loaded with technical Information
and terminology for which the students do not have a basis
of understanding. This Is followed-up with the pep talk
about "going home and studying this until you understand
it." The problem is the students have no basis for relating
the technical Information. So students read and reread
trying to understand the technical information. And when
asked how the course is going, they say "it's hard" which
translated means, "I don't understand It."
Students respond when the teacher's primary objective is
to develop an understanding of the concepts as they are
introduced. The October 1986 Smithsonian Magazine carried an
article on Jearl Walker, a physics professor at Cleveland
State University. The article describes Walker's classroom
technique for relating the principles of physics to everyday
situations or objects that are familiar to students. The
results, from the students' point of view, were expressed In
comments like, "It's not difficult to understand physics the
way he teaches It. He makes it so you're not afraid of it."
"He's getting his point across and I'm learning." (10)
While your style may be different from Walker's style of
teaching, the need to interpret technical information into
the everyday language of the student as new concepts are
introduced Is crucial for an effective understanding of the
USE OF TECHNICAL EQUIPMENT. The first tendency for technical
people is to start teaching technical aspects of
the equipment rather than facilitating the nontechnical

Excerpts froms "Observations and Thoughts On Interpreting".
The SKill Of Interpret 1 no.
Beverly Carlson Qulnn. CQ Enterprises.
McLean, Virginia. 1986.
individual's understanding and immediate use of the
equipment. When explaining or demonstrating a piece of
equipment, use the three criteria for interpreting regarding
the use of the equipment and your explanation.
No technical language. Use plain Enoil ah If the
equipment has keys or knobs with technical terms on them,
temporarily cover them up with color patches, easily
identified symbols or common, everyday words. Get the
individual using the equipment without the stumbling blocks
of technical terms. Tremendous time Is wasted not to mention
anxiety Induced teaching nontechnical people to become
technical enough to use a piece of equipment that could have
been designed to allow Immediate access if plain English and
good interpreting had been used from the beginning. The
Important thing is to get the nontechnical individual
comfortably using the equipment.
streamline the message. When introducing an individual
to a piece of equipment, streamline the steps taken to get
an end result so that the individual can get a sense of what
the equipment can do for them. Requiring a nontechnical user
to go through every detailed step is to guarantee that they
will become overwhelmed and stop trying.
Answer the question! What doea It mean? Nontechnical
individuals want to know what it means to use the piece of
equipment and what the equipment will do for them. Dally,
people use numerous pieces of equipment and never know nor
care to know the technical details and inner workings of
that equipment. As our technologies create even greater
numbers of new equipment, people will not have the time to
become technically knowledgeable to operate all of them.
Training time could be minimized whether at home or in
the office if the designers and manufacturers would drop the
technical labeling of parts and use plain English,
streamline the steps needed for use and focus on what it
means to use that piece of equipment. Interpreting provides
the quickest familiarity and easiest use of technical
equipment by nontechnical users.
LETTING GO OF NUMBERS Is difficult for technical people.
Numbers seem so concrete, specific, precise and objective.
Numbers have a life of their own. If enough of them are
used, certainly the listener will understand the

Excerpts from: "Observations and Thoughts On Interpreting".
The Skill Of Interpreting".
Beverly Carlson Quinn. CQ Enterprises.
McLean, Virginia. 1966.
(cont inued)
message. But in fact, numbers are technical information and
your manager, customer, buyer or another technical
specialist does not automatical 1y understand the meaning of
the numbers. An interpretation is still needed as to what
those numbers mean and how that information can be used by
the listener.
It is important when addressing a nontechnical audience
to get to the essence of the information those numbers
represent. Then select out a few critical numbers as support
material to illustrate your main points. If there are
additional numbers that you think the listeners need to have
for decision making or for background Information, put those
additional numbers and other details in a written handout
that the listeners can read at their convenience. If they
want more information at that time, they will contact you.
Your oral presentation should focus on what the
statistical information means and why it is Important for
the listeners.
TECHNICAL PURITY is a factor in why technical speakers
do not use interpreting even when they know how to do it.
Technical purity can lead to technical arrogance.
Technical purity is the belief that only a technical
language can express the information, processes or
technologies of a field and that to use any other form of
expression is to dilute the information. With technical
purity, it becomes important to resist outside Influences
that would deal with the field in anything other than
precise terms or functions.
From my perspective, technical purity can be traced to
the educational process at universities. When students enter
a program of study for their chosen field, they begin a
process of Increasing specialization, of being immersed in a
discipline where everyone else speaks the same language. At
virtually no time during this training are there manadatory
courses requiring students to learn how to talk about their
technical field to people outside of it or to communicate
across disciplines. In academia each field or discipline
often jealously guards its turf from outside encroachments
of other departments.
Yet in the work place, talking across disciplines is
what many technical experts are expected to do. They need to

Excerpts from; "Observations and Thoughts On Interpreting".
The Skill Of Interpret t no.
Beverly Carlson Quinn. CQ Enterprises.
McLean, Virginia. 1986.
discuss aspects of their field with people in government, in
management, in accounting, in sales and In a variety of
situations where their information and/or technologies are
REDIRECT YOUR FOCUS. Technical speakers need to change
their focus. They spend too much time attempting to make
their nontechnical audiences technically knowledgeable. As a
specialist said, "I wanted them (the nontechnical audience)
to understand the technical details. And I thought I was
doing a great Job." The problem with this focus is that many
nontechnical audiences do not want to become technically
knowledgeable nor do they have the time that it would take.
The reality is that technical speakers need to present their
technical Information in understandable English for the
nontechnical listener. Making this shift In focus is a major
change in thinking for many technical speakers but it is a
necessary change If they are to be effective communicators.
LANGUAGE TO LANGUAGE Is the rule in Interpreting
technical information for nontechnical audiences.
following this rule, many technical speakers work with an
ADVANCED TO BASIC approach and often find themselves in
trouble. The Advanced to Basic approach Is viewed as going
from the DIFFICULT TO THE SIMPLE, as in going from a Ph.D.
thesis to "Dick and Jane" or from computers to crayons.
The Advanced to Basle approach carries with It the
danger of over-simplistic and patronizing presentations.
This problem develops because the speaker remains within the
technical context and tries to simplify within that context
instead of genuinely translating across languages. A way of
visualizing this is to say the speaker is moving vertically
instead of horizontally.

Excerpts from: "Observations and Thoughts On Interpreting".
The Skill Of Interpreting.
Beverly Carlson Quinn. CO Enterprises.
McLean, Virginia. 1986.
(cont inued)
Simplifying within the technical framework leads to
basic information as a means of training the listeners to
become technically fluent. When presenting these basics or
simplified technical versions, speakers often feel a need to
apologize for Information that Is not "technical" enough.
The selected basics including technical terms and jargon
with their "one shot" definitions are usually given in a
three to five minute time frame early in the presentation
and do not realistically provide the listeners with an
adequate basis for understanding the full technical
presentation that subsequently follows.
With interpreting, you do not use basics. Instead you
move horizontally with the level of content by determining
what your technical information means and then translating
that meaning into the language of the listener. Nontechnical
listeners want to immediately understand the substance of
your information in their own language without learning
INTERPRETING IS NOT A "SNAP", it is a challenge.
Interpreting is not simplistic. It Is a skill that requires
a commitment to develop. It requires thought and trial and
error to arrive at the meaning of your information and how
you want to express it for the listener. It is determining
the focus of your presentation. It is creative and involves
brainstorming, selecting an approach from alternatives and
developing the format you want to use. It is simultaneously
keeping your field in mind as well as the needs of the
YOU ARE NOT THE EXCEPTION to using good interpreting
with nontechnical audiences. Technical people have a way of
rationalizing that interpreting is not only good but needed
by every other field, except theirs. They tend to believe
that other fields need to develop the skill but that their
field is unique and interpreting would not work. What these
technical people are really saying is that they do not want
to change their focus and they do not want to make the

Excerpts from: "Observations and Thoughts On Interpreting".
The SKI II Of Interpreting.
Beverly Carlson Qulnn. CQ Enterprises.
McLean, Virginia. 1986.
(cont inued)
commitment necessary to learn how to interpret.
Every technical field at some point needs to present its
information to nontechnical listeners. At that time, every
technical field needs interpreting.
RESISTANCE TO CHANGE can prevent a technical person from
developing Into an effective interpretor. Change means
letting go of old patterns. There is grieving over the loss
of comfortable habits, secure behaviors and a familiar
language. Change involves risk. Developing new patterns
requires trial and error, making, mistakes and feeling
uncomfortable and uncertain during the first efforts.
Successes are slow at first and then increase as new
patterns are put in place. When the skill of Interpreting is
developed, the technical person has an extended range of
communication that holds limitless possibilities.

Every trainer eventually runs into an audience determined to resist Here's how to
recognize volatile situations, cope with their challenge and reassert control
Participant Hostility:
Why It Comes With The Territory
by CarlE. Pick hard!
A trainer is always a target Even when training within the organization to which
you belong, your leadership position temporarily separates you from the group
with which you are working. Every group makes a participant/leader distinction:
the participants are we and the trainer or trainers are they. As an outsider trainer
this distinction is even more strongly felt: "You are a stranger, you are not one of
Participants do, however, assign you two roles as a trainer. You are an authority
coming in to exen training control, and you are an expert coming in to enable the
development of skills and understanding participants do not already possess, or
possess in lesser degree than yourself, Having given you these two roles,
participants have now identified you as a target, and some will feel impelled to
move to destroy your effectiveness and legitimacy in each area.
Why? Because in all organizations there is always a certain amount of
free-floating dissatisfaction, anxiety, frustration and anger which accrues from the
daily pressures of organizational life - people feeling pushed, blocked and let
down in their work relationships. There is a desire to express these negative
feelings, but in a "safe" setting which will not jeopardize standing at work. The
training situation can provide this outlet The rules of social conduct which
ordinarily govern work relationships are temporarily relaxed. The trainer becomes
a safe authority target upon whom participants may displace frustrations with their
superiors; someone they can with relative impunity challenge, criticize and punish.
They may in addition compete with the trainer, elevating their own self-esteem by
putting the "expert" down. Some may feel built-in resentment toward the trainer
as well: It's easy for you to talk about our problems since you don't have to live
with them." That the trainer is free from the toils of the participants' problems can
serve as an irritant itself.

Trainers are in a real sense paid to be scapegoats—to provide opportunity and
target for this pressure release. We must accept this reality and learn (and this
does take experience) not to take participant hostility personally. Any time you
are going to work with a group which you know in advance is operating under
undue pressure, you can expect basic attacks on your two roles. They will attack
your expertise Ofou don't know so much," 1 knew all this before," *1 know more
than you"). And they will attack your authority ("You can't control me," Til do
what I please," "I have more power than you").
Hostility Expressed
They will come at you in a variety of ways-
There is hostile withdrawal—participants who refuse you both verbal and
nonverbal response. If you can't reach us you will fail to teach us," they seem to
There is hostile diversion—participants who initiate their own social interaction
independent of that which you are orchestrating for the larger group. If we can
secede from your control, we can encourage others to do likewise," they seem to
There is hostile attack—participants who directly challenge your authority,
oppose your directions or criticize your message. "If we refuse to go along with
you, that rejection will undermine your confidence and destroy your poise as a
leader," they seem to say.
Participants particularly resourceful with their hostility can use all of these in
combination. For example, they first set up a diversion to invite your response.
Then, as you move to recontrol that situation, they attack you from out of their
support group. And finally, when you try to deal directly with their objection, they
withdraw into stubborn silence and will not respond.

What Does It Mean?
When participant anger is expressed in any of these three ways, it is always a
statement of protest The participant, beneath the overlay of hostility, is indirectly
saying: 1 don't like being placed under your leadership. I don't like what you
represent I don't like what you are saying. I do not like what you are asking me
to do."
Further, participants do not commit themselves to public protest unless they are
trying to elicit a particular trainer response to their challenge. They may want to
punish you, and indirectly those responsible for the training, until you defend or
apologize for your presence. They may want to push you until you give up your
agenda and give way to theirs. They may want to provoke you into a fight to allow
them to vent frustrations hitherto suppressed and usually forbidden.
The choices of a trainer wishing to honor protest are to reflect back the concern
you think that protest may be masking ("Would you like to talk about your
dissatisfaction at being her today?"), to apologize, change the agenda or absorb
the ventilation of grievances. The major problem in honoring participant hostility
in these ways is that it does delay and divert you from fulfilling the training
assignment There is, however, one case where some diversion may have survival
value for you as a trainer.
When Hostility Triggers Fear
In all relationships anger is the great intixnidator. For this reason one cannot
adequately talk about the management of anger without including some
discussion about the management of fear. It is an unpleasant reality of the
trainer's life that on some occasions the expression of participant hostility will
trigger within you some fear. This is normal. And although beginning trainers are
most vulnerable to this response due to inexperience, even the most seasoned
trainers are not entirely immune to this anxiety.

When, in response to participant hostility, you experience sufficient fear to
distract you from your training focus, your first priority must be to accept that fear
and move to reduce it as quickly as possible. Why? Because fear undercuts the
three major self-supports upon which your leadership as a trainer depends: your
confidence, concentration and momentum. You suddenly question if you can do
the job, your mind wanders away from your training purpose into worry, and you
lose the assertive and responsive momentum upon which the illusion of your
training authority depends.
Like all teachers, trainers have three major needs when working with a group: to
be liked, to be in control, to be effective. When these needs are frustrated the
trainer can become afraid. The participant who attacks you can trigger your fear
of rejection. (They do not like me.") The participant who creates a diversion can
trigger your fear of authority loss. ("I cannot control them.") The participant who
withdraws beyond your reach can trigger your fear of failure. CI am not being an
effective trainer.") Training is risky. Potential anxieties are built in, and under
pressure from participant hostility they may become actualized.
Coping With Fear
The most efficient way to reduce trainer fear is to close the distance with the
hostile participant. Although our instinct at these times is usually to move away
(to flee) or to defensively attack (to fight), both of these responses only increase
our own anxiety and communicate it to our attacker. Behaviorally, closing the
distance means:
1)	physically moving closer to the hostile participant;
2)	making direct eye contact;
3)	courteously soliciting information about the nature of their protest;
4) Dialoguing in a positive and supportive way about their concerns.

Even if the participant will not respond to these last two overtures, going through
these active motions can still serve as an anxiety reducing function for you. The
purpose of these four moves is to reduce your fear of the hostile participant by
reasserting your initiative in the relationship, by gaining more information about
them, by establishing through dialogue a working connection with them that you
can manipulate. Having moved to regain self-control, you are then ready to
consider your options for gaining control of participant hostility in a group.
Responding To Participant Hostility
One way to conceptualizes participant hostility is as a resistance to the training
progression through which you are leading a group. In your choice of responses it
is always well to consider that the harder you press against that participant
resistance the more likelihood there is that the resistance will increase. This is an
isometric principle. (Isometrics is the conditioning procedure where, by pushing
hard against a fixed resistance, you increase the tension in the relationship.) This
applies to managing interpersonal resistance. The harder you push against the
resistant participants, the harder their resistance is.likely to become, the more
energy you are going to have to spend in maintaining that relationship, and the
more fatiguing it will become to you over time. Trainers need to conserve their
energies and should follow the path of least resistance whenever possible,
particularly in response to participant hostility. The following five categories of
trainer response begin with the lowest and move to the highest amount of trainer
resistance applied to manage the situation.
Option 1: Avoidance. There are three major strategies to be considered here. The
first is to literally ignore the hostile action or remark and proceed with your
program as though nothing untoward bad occurred. Sometimes simply denying
protesting participants the reinforcement of your response is sufficient to shut
them down. A second set of strategies has to do with avoiding direct contact with
the hostile participants while attending to their disruption. Here you solicit peer
influence to shut them down. For example, you deliberately lapse into silence
after the hostile outburst If the majority of the participants want you to continue,
they will move to quell their disruptive peer. A third set of strategies has to do
with providing an indirect response to the participant You appear to be avoiding
the protest, but actually you are interpreting its intent and then responding to
meet the underlying concern expressed. For example, a diversion builds in a group
to your left, but you avoid looking at them.

However, because you interpret their protest as a restless desire for an
intermission, you go on a few minutes and then, apparently independent of the
protest, announce a break. Notice that with none of these strategies do you
actively engage the resistance.
Option 2: Acceptance. This strategy is a very direct one. When hostile
participants push against you, move to find out the purpose of the protest and
then give them their way—accept their resistance. Some people feel that a trainer
sacrifices authority by "giving in" this way. However, allowing some latitude for
participants to alter the content or conduct of the session to suit their needs can
actually increase their sense of ownership involvement in the training. For
example, a participant who is dissatisfied with a training agenda which puts his
concern last may well be brought back into cooperation by altering the order of
items to be addressed. Of course, acceptance of resistance is counterproductive
when the participant's only intent is to disrupt the proceedings.
Option 3: Adapt The strategy here is a manipulative one. What you want to do is
to engage with the participants in such a way that you ultimately use the force of
their resistance against them or for yourself. Thus when they protest and strongly
disagree with what you are saying, you immediately switch sides and say, "You're
right, that's a good point." Hies you take their argument away from them; you
begin arguing for them against the position you had previously taken. Having thus
championed their argument you have defused their resistance. Sometimes this is
sufficient for your purpose. At other times you may, now that you control the
thrust of their argument, want to turn it back into the direction you were
originally heading.
Option 4: Stand fast This strategy is at once a very simple, but a very
energy-expensive response to make. What you are doing is standing fast in your
intent to do what the participant is protesting. You will not give way. You will not
discuss. You will not negotiate. Perhaps the training was designed to include an
evening session, and several participants are vociferously complaining. You
simply stand there and let their resistance wash over you and wear itself out Then
you proceed with the program as contracted. Withstanding this onslaught of
negative emotions can be abusive to the trainer, which is why providing a firm
resistance against which the hostile participants can level their protest is an
energy-costly option.

Option 5: Push back. This is the most energy-costly response to participant
protest They push against you. You push back. When two resistances push against
each other, of course, you have created the social formula for conflict. What you
hope to gain by resisting is to overcome the participants' resistance, persuading
them to back oft The problem with pushing back, however, is that if the
participant doesn't back off you have just created a fight. In almost all cases, that
is a no-win situation for the trainer. If you "win" the fight, participants tend to
array against you out of sympathy for their defeated peer, if you "lose," then
participants tend to have reduced respect for your training authority.
Pushing back is always a gamble. As a bluff it can pay off if the protest subsides
and there is no conflict. Sometimes the stakes are even great enough where
fighting back with a hostile participant can be worthwhile for the trainer. For
example, you may have a participant so forcefully hostile that others are both
intimidated from cooperating with you and afraid to stand up to and stop their
peer. At this point, if the program is to be salvaged, you are the only person there
to beat this opposition down, restore order and reestablish the training
framework. Obviously, pushing back is the option of last resort when dealing with
a hostile participant.
Surviving Hostility
When encountering participant protest, the most critical concern for a trainer is to
maintain your "cool"—the capacity to calculate and choose wisely under pressure.
Fear provoke impulsive responses, not reasoned choice. The five management
options just described are available to us only so long as we retain our power of
reason. Thus the key to trainer control of a hostile situation is keeping fear down
and all management alternatives open.
As trainers we need to accept the inevitability of participant hostility. We need to
learn to deal with our fear when upon occasion it becomes aroused in a hostile
situation. We need to keep our cool in order to preserve our power of
management choice. We need to know and use the full repertoire of these
choices. And we must not take participant hostility personally. It comes with the

How To Make Participants Angry
And how to cool them down and turn their energy to your own objectives
Participant hostility truly comes with the territory. There are ways, however, in
which a trainer can create hostility over and above that which is already built in.
You can discount what participants say, or laugh at or make light of a remark
made in seriousness. You can not listen to what participants say or ignore the
implications of what they have said after they have said it You can interrupt them
and press on with your remarks or directions. You can put them down, using
humor-particularly sarcasm—to make them look foolish in front of their peers.
You can even side with one participant against another, thus publicly endorsing a
"winner" and, more importantly, a "loser" in an argument.
Value Offending
Here you advance ideas which you know to be counter to the dominant values of
the group. You can directly argue with or criticize values which are widely shared.
You can offend participant taste by the way you dress, address people (title
avoidance, discourtesy), or by the language you use (slang, peijoratives,
expletives). Many times you can be set up in advance to offend, as when you are
training on a set of value sensitive issues such as affirmative action, sexism or
Violation Of Expectations
Participants expect to be meeting within a specified time frame; start late and
keep them overtime. They expect coffee and there is none. They expect a certain
topic or agenda and you present a significantly different program. (Sometimes you
can be set up for this by a contracting agent who asks you to deal with one set of
issues, but tells the participants something else "in order to get them there.") You
can begin a program by soliciting participant input and then proceed to ignore the
issues they expected you to address.

Sometimes you can be trapped by a "Don't you agree...?" question—asked by
the people you are ostensibly working for with the clear expectation that you will
endorse the statement enclosed in their question. If you disagree, you violate that
expectation, and they can become very angry indeed.
Reduction Of Freedom
By restricting freedoms for choice which they have already or are expecting to
exercise you also arouse participant anger. You can prohibit smoking. You can
force them to group separately from their friends after they have already seated
themselves by social preference. You can force them to talk when they want to be
silent, be silent when they want to talk, share when they want to be private, work
on task exercises they dislike. Often you can be set up for this anger by a manager
who schedules training sessions over lunch, after hours or on weekends.
Prevention Of Participant Hostility
In all of these ways, you can by your own choice—and sometimes by the choice'of
others—be a contributing factor to the very hostility you seek to avoid. If, through
no choice of your own, you have reason to anticipant a hostile group, there are
some preventative strategies through which you as a trainer can move to reduce
the level of that hostility.
1. Personalize the session. One way to reduce participant hostility is to give up
some ownership in the session itself. People tend to be supportive of what they
help create. Therefore, either prior to or at the outset of the session, give them an
opportunity for input into the agenda. Then be sure you act on their input You
can powerfully reduce hostility if you can actually involve some of the participants,
providing they are willing, in training leadership roles; serving as group leaders,
giving directions, making short presentations. Participants are normally reluctant
to attack peers volunteering for such leadership duty. You can also personalize
the meeting space. For example, have participants create some personal
statements on newsprint and then post their production on the surrounding walls.

2.	Personalize your presence. For participants, the safety of a trainer as a target
for hostility is largely based on a "stranger" identity. Since they do not know you
personally, since they have no caring connection with you, they have little
reservation in attacking this unknown expert and authority. Conversely, the more
participants come to positively know you as a person, the less comfortable they
tend to feel attacking you. Therefore, help the people you are working with get to
know you for your own protection.
It is always useful to self-share, to present to the group information about yourself
that characterizes your individuality. In addition, you can prospect relationships in
advance of the session. Prospecting is the act of informally meeting and
socializing with as many participants as possible before the session begins. This
not only gives you information about the needs and expectations they bring to the
session, it introduces you to them so that when you first stand up in front of the
group you are a known, not an unknown, person. Finally, you can use ally
relationships. Here you get to know three to five participants well enough through
prospecting so that throughout the course of your training interaction with the
group you make public references to your relationship with them—what they
earlier said, what you and they discussed. Hostile participants are usually
reluctant to attack a trainer who is socially allied to their peers in what apparently
is a positive and familiar way.
3.	Purge anger. There are three kinds of initiatives you can take to elicit the early
expression of hostility in order to get it out and over with. You can make a
sympathetic statement: 1 feel that many of you are upset at being here today, and
if I were you I would be too." You can make a humorous statement: "Anyone
want to testify about how happy they are to be here today?" You can make an
attack statement: "You're all here today because you've been doing things wrong
and I'm here to get you to do things correctly. Right?"
Lancing and bleeding off the anger early can make for easier progress later on if,
having invited the protest, you are willing to commit sufficient time and energy to
listen to, legitimize and accept it. The choice of invitation—sympathetic,
humorous, attack—is a matter of which approach best fits your style as a trainer.

4.	Bridge building. If you sense the hostility building after the session gets
underway, pinpoint the participants leading the protest At a break (which you
may want to take early) initiate some positive social interaction with these
individuals to gain information about their objections and, more importantly, give
them an opportunity to positively know and connect with you. Another device, if
you don't want to stop and deal with a hostile objection at that moment, but do
want to allay further protest, is to table the complaint for later consideration, even
emphasizing your commitment to do so by noting it down on your chalkboard or
easelpad. In that case, be sure you do address the issue later.
5.	Rewards. Two rewards, second in potency only to money (stipends paid to
participants for attending) are time (early release) and food (refreshments).
Greeting people upon arrival with donuts and coffee and then announcing your
intention to amend the schedule so they will get out half an hour early are
enormously effective devices in influencing a positive disposition to a training
session which participants do not want but are directed to attend. For many
participants, handouts of written materials and tokens of attendance (special
folders, pens, etc.) are also effective.-CP.
Carl Pickhardt is a consulting psychologist for the Region 13 Eduction Service Center
of the Texas Department of Education in Austin. He is also a private consultant in
the areas of organizational life management and the psychology of helping.

Training 101
Adults iearn more easily and
recaii more readily when
material is "framed" for them
in ways that help them link the
course material to knowledge they
already have.
In the first article beiow. Susan L.
Michel describes three tools that can
help do just that: structured over-
views. effective graphics, and con-
ceptual maps.
Darryl Ann Lavitt follows up with
a discussion of the use of case stud-
ies in corporate training. Case studies
help learners apply new knowledge.
to realistic workplace situations. She
describes what a case study is and
what it is not. She talks about how to
use case studies and gives tips for
leading a class in a case discussion.
Three Tools To Help
Learners Learn	
The following passage illustrates
the importance of having a
mental frame of reference. It
was used by Bransforu and Johnson
in the early I9~0s as they studied
human learning. Their subjects were
asked to read the passage once, to
rate it for comprehensibility. and to
be prepared to recall it. As you read,
it might be interesting to put yourself
in the place of the subjects and try to
imagine how satisfactorily you would
have completed the assignment.
The passage is as follows:
The procedure is actually quite
simple. First you arrange items into
different groups. Of course one pile
may Ix; sufficient, depending on how
much there is to do. If you have to go
somewhere else due to a lack of facili-
ties. then that is the next step: other-
wise. you are pretty well set. It is
important not to overdo things. That
is. it is better to do too few thinsjs at
once than too many. In the short nin
this may not seem important but
complications can easily arise. A mis-
take can be expensive as well.
"At first, the whole procedure will
seem complicated. Soon, however, it
will become just another facet of life.
It is difficult to foresee any end to
the necessity for this task in the
immediate future, but then, one
never can tell. After the procedure is
completed one arranges the materials
into different groups again. Then
they can be put into their appropri-
ate places. Eventually they will be
used once more: then the whole
cycle will have to be repeated. How-
ever. that is pan of life."
Most of Bransford and Johnson's
subjects who read the passage cold'
rated it as incomprehensible and
recalled very little. Not surprisingly,
subjects had much higher compre-
hension if they were told ahead of
time that the passage was about
washing clothes!
Obviously, frames of reference are
helpful. So. how can you be sure
These tools and techniques
for "framing" course
material can help learners
link new information
with knowledge they
already have.
Traiuiiif! c- Duivlopmcnt. hum 19OJ 17

Training 101
that you and your trainees are in the
same mental ballpark?
Three tools. Three useful tools are
structured overviews, effective graph-
ics. and conceptual maps.
A structured ov erv iew is simply an
outline of the material that will be
covered. Nearly every trainer uses a
similar "prompt" when delivering
instruction. What many presenters
fail to do is share their road maps
with trainees.
If you prov ide the outline to partici-
pants ahead of time, you allow them
to "frame" the topic in a particular
way. The overview tells trainees what
you will and wiii not cover. It allows
them to activate what they already
know about the items on your over-
view and to be ready to fill in the
gaps in their own understanding with
the new information you provide.
The boxed example shows a struc-
tured overview from a stress manage-
ment workshop. Notice that words
such as "introauction" and "conclu-
sion" do not appear: they are not
directly related to the content of the
Trainers can also use graphics to
help provide a framework for learn-
ing. Graphics work best when they
are simple and forceful.
For example, a trainer who is
teaching participants about the
Shewhart Cycle problem solving
process would find it invaluable to
have a large "plan-do-check-act" circle
(shown in Figure 1) in front of the
group. Such a graphic would help
trainees orient themselves.
When trainees work to understand
the process of cause analysis, the
trainer can remind them, by pointing
to the chart, that they are still operat-
ing in the -plan" quadrant. This rein-
forces the importance of that pan of
the overall cycle and helps trainees
keep their bearings.
This approach is most useful when
trainees are learning an entirely new
concept or a different way of doing
something. In such cases, they are
likely to have little previous knowl-
edge to help them assimilate the
training material.
A conceptual map combines the
features of an outline with the
appeal of a graphic display. It shows
meaningful relationships between
concepts and provides visual assis-
tance for both trainer and trainee. By
"chunking" the material vertically,
trainees can move from general to
specific and back again. By "chunk-
ing" horizontally, they can see
important relationships that might
not be apparent otherwise.
Like an outline or a graphic, a
map can provide a schematic sum-
mary of what has been learned. It
can be used to help trainees as they
review matenal. Trainers can prepare
maps ahead of time and present
them to participants, or trainees can
actually work to devise conceptual
maps during the training.
Studies investigating the use of
conceptual maps show that maps
drawn by trainees become more
sophisticated and more fully inte-
grated as the trainees develop a better
understanding of the subject. So maps
can provide important information
about a trainee's progress.
A training program on the dimen-
sions of leadership used a map simi-
lar to the one shown in Figure 2.
No simple formulas. Effective corpo-
rate training can never be reduced to a
simple formula. Variables will always
exist so providing effective instruction
to adults will always be a challenge.
Unlike younger learners, the
adults in today's corporate class-
rooms don't iearn by rote memory.
18 Trai IIInV <¦"- !Jfi clnnnii'iil Imw / OOP


Team building
participative -2
For them, learning has to make
sense. The challenge for trainers is to
provide these learners with the tools
they need in order to construct their
own knowledge.
In other words, we need to
develop training programs and mate-
rials that will ensure learning. And
that means we have to help trainees
either activate or create appropriate
conceptual frameworks. Structured
overviews, effective graphics, and
conceptual maps can be useful in
hciping adult learners do what they
do best—create meaning.
— Susan L. Michel
Management Performance International
~ West Serentb Street. Suite 1000
Cincinnati. OH -t iJOJ
A Case for Training
What is a case study? First,
take a moment to formu-
late your own definition.
Block it out in your mind or on
paper. After you've done that, com-
pare your definition with these:
A case typically is a record of .1
business issue that actually has been
faced bv business executives, together
with surrounding facts, opinions, and
prejudices upon which executive deci-
sions have to depend. These real and
particularized cases are presented to
students for considered analysis, open
discussion, and final decision as to the
type of action that should be taken. ''
"The distinguishing characteristic
of the case method in the classroom
is the extent to which the analytical
sifting of pros and cons and arriving
at a definite decision is undertaken
by the student."
"It is useful to think of a case as a
connecting link that draws together
the experience of the executive on
the job. the executives uind potential
executives) in management develop-
ment programs, and the researcher's
efforts to understand the process of
management. The written cases are
catalysts to speed the process of
learning from experience."
"A good case is the vehicle by
which a chunk of reality is brought
into the classroom to lie worked
over by the class and the instructor.
A good case keeps the class discus-
sion grounded upon some of the
stubborn facts that must be faced in
real-lite situations. It is the anchor tin
academic flights of speculation. It is
the record of complex situations that
must be literally pulled apart and put
together again before the situations
can be understood."
"Class materials are largely com-
posed. not of texts, but of problems
adapted from actual situations....
Instruction is chiefly carried on. not
by lectures, but by Socratic discus-
sion in which the professors criticize
and question, but leave the students
to find their own solutions."
The above definitions are from
"Casing Casemethod Methods." by
Dooley and Skinner in the April 19~
Academy of Management Renew.
Those five definitions reflect essen-
tial elements of case studies:
» they are based on reality
» they include opinions and preju-
dices as well as facts
» they are complex
» they are created for students to
analyze in a classroom discussion.
The classroom discussion is driven
by the Socratic method, in which the
facilitator guides the discussion by-
asking questions. The participants
respond to the facilitator's questions.
Those responses, in turn, stimulate
more questions, and the dialogue
Training & IX'tviopnienl. June 199J 19



8, 11, 15, 5, 14, 1, 7, 6, 10, 13, 3, 12, 2

Numbers are arranged in alphabetical order:
Four and nine should be inserted in alphabetical order as well.

Connect all nine dots with four straight lines, without

Connect all nine dots with four straight lines, without
lifting your pen or pencil from the page.

Survey participants
Plan for student needs
Consider what they alrady know
Assess their work situations
Ask for feedback
Find ways to work-in other's ideas
Incorporate ideas from group

Preventing Audience Boredom
Everyone has been In classes where they were bored — because of
the subject, because of the everlasting rhythm of the Instructor's
voice, because of lack of sleep the night before. While there is no way
to keep every single person fully engaged at every moment, one of
the facilitator's main jobs is to see to it that the participants are
engaged most of the time. How?
Tailored information that you know is relevant
By careful advance work, you can ensure that the material you are presenting
is relevant to the audience's situation. Use examples which are drawn on
their experiences, and which apply directly to the dilemmas they have
discussed with you. Throw out any material which would be off track before
you start, so they dont tune out
A reason to listen
If you've done your homework, your audience will see Immediately why they
should listen and tune In. They will know how the course is going to solve
problems they face, or at least tell them how to approach difficult situations.
People can be very patient with a training situation if they are convinced it
will be helpful to them, but until they reach that point their attitude is
"show me." You need to win them over as early as possible.
Examples and anecdotes
Nothing engages most people as much as a good story. It must be to the
point and say exactly what you want it to (which real life often does not).
Polish your examples and anecdotes so that your timing Is as good as a
comedian's. Don't be afraid to talk about times when things went wrong, or
when you tried to do things the way you are recommending, and it didn't
work out. People often remember anecdotes and tell them to others long
after they have forgotten whatever was on the overhead. Beware, however,
confidentiality issues; "Oh yes, that must have been when Joe was chief. He
did a terrible job," is not the reaction you want
Think about every major point you want to make, and come up with at least
one cogent example or anecdote for each one.
Participatory exercises
With a few brilliant exceptions among the world population, most people
cannot lecture well enough to prevent boring an audience at times — even if
the subject is fascinating. Adults don't respond well to being talked at. Any
participatory exercise will perk things up. In addition to designing
participation in from the first, be flexible enough to respond if you see
(c) Mary Dingee Fillmore, 1993. For permission to reproduce, please call
617 969 4974.

people nodding off. Break them Into pairs to discuss some aspect of what
you are saying, and get them to report back; or ask them to to come up with
as many reasons as they can why what you are saying is dead wrong.
Controversy always picks things up.
Varied activities through the training period
Look at your training design from the standpoint of varied activities, not just
substance and how to cover it. If you have a 15 minute presentation followed
by a small group exercise, then another presentation and another small
group exercise, people may tire of it. Try to introduce different methods, or
different angles on the same questions. If people have been interacting in
twos and threes, try putting them in groups of seven, or letting them work
individually in writing for a while.
Physical movement: yours and theirs
The first thing to do if you see people's eyes wandering away is to move
closer to them, and use more vigorous gestures. Most people become much
more alert if someone approaches them physically. Try moving around
more, not only in the front of the room, but into the center of the U if you
are using one. or around the edges of the room. A team can make good use
of the physical space with one person at the front while the other circulates.
Diverse voices and opinions
Simply hearing different vocal tones prevents boredom, which is one of the
great advantages of team facilitation. In addition, asking for input from the
participants has the benefit of varying what others are hearing and looking
at. Different opinions (voices in the metaphorical sense) also stimulate
people and make them want to listen more closely, especially if everyone
feels that the field is open and they will be allowed to contribute.
Humor can make an enormous difference in maintaining interest ~ as long
as it is tasteful (i.e. avoids slurs) and in some way relates to your subject.
When you've tried everything else and people are still yawning, take a break,
and see if you can get a clue by talking with someone about what's wrong.
Physical arrangement of the room
Classic classroom arrangement is a killer. Try anything else. Many
facilitators prefer the open U, which allows you a lot of contact with people,
so you can keep track of how they are feeling.
Maintain your own interest. If you are bored, they will be, too.
(c) Mary Dingee Fillmore, 1993. For permission to reproduce, please call
617 969 4974.

Improving Your Facilitation Skills
(No Matter How Good They Are)
by Maiy Fillmore, Director
Changing Work, Chestnut Hill, Mass.
Even the very best facilitator can Improve. It is important to keep trying
different styles and techniques not only to maintain one's effectiveness in
groups, but also to avoid becoming bored with the way "I've always done it."
Here are some ideas to keep you moving toward excellence:
Pay close attention to written evaluations.
If all you are getting back is euphoric praise, change your evaluation so that
you receive specific input about points you can improve. Look for patterns in
what people are saying, and pay close attention to the one or two people
who were dissatisfied in some way. They probably represent a broader range
of people than you would like to think.
Invite a peer to critique you.
Ask someone you respect as a facilitator tq drop in for an hour or to and
watch you. Clue the person in about areas where you feel you may be weak,
or parts of your curriculum which you think may be fuzzy or unsuccessful. If
you are facilitating with someone else, ask them for the same services.
Develop alternative examples and anecdotes.
For all of your major points, develop new stories to tell or examples you can
use for illustration. Polish them carefully, and try them with different
audiences. See which ones work best. An obseiver can help you to decide,
and/or you can ask the audience specifically whether the point was clear.
Watch yourself for signs of boredom.
If you are bored, the audience probably is, too. Try changing the order of
your material, the room arrangement, or the techniques you are using (try
role play instead of debate, for example). Ask the group for more input and
examples from their experience. Move around the room more.
Use an audiotape for an hour.
Virtually everyone has characterlsUc speech patterns which become
monotonous after a relatively short Ume. Listen to an hour of your own
talking and try to hear the patterns. You may. for example, usually raise your
voice toward the end of a sentence, or use a particular kind of opening
("Now, to take the next point. . Once you can hear the patterns, you can
break them, and you will be much easier to listen to. Likewise, find the
verbal tics (habitually used words or phrases) and purge them systematically.
Make it your goal to reach every single participant.
No matter how quiet or shy someone is, make it your goal to engage them
and make it possible for them to participate comfortably and actively. The
difference between outstanding and good facilitators is often their ability to

capture the attention and contributions of the people who too often stay
mum. Ask yourself what you did to draw out every person present, and what
other steps you could take to involve them.
Watch a videotape of yourself.
The first time you see it, turn the sound off, and watch your body language.
Do you look calm or frenetic? Composed, or ready to fly away? Do you seem
rooted to the ground, or tentative and unsteady? Make sure you are
conveying the impression you want to. If you are not, practice and re-tape.
When you listen to sound as well as watching yourself, pay attention to the
substance of what you said, the pattern of your voice, and verbal tics (see
Redo your visual aids.
Almost all visual aids can do with simplification. Reduce the number of
words on your slides, overheads or flipcharts, and add illustrations wherever
you can.
Interview participants who maybe honest with you.
While it is never easy to find someone who will give real feedback, call
several people who have been in groups you have facilitated, and ask if they
would spend half an hour with you discussing the session. Explain that your
purpose is to improve your performance, which you can only do if you know
how you are coming across as a facilitator. Ask specifically about the most
boring parts of the day, the tone, the time allotment to different topics,
what was missing, other ways you could have handled different people or
situations which arose, and so on.
Set your own criteria, and evaluate yourself!
You probably know better than anyone where your weak points lie. Set some
criteria for improvement, and look at yourself in that mirror at the end of
each session. You'd be surprised how much better you can do.
(c) Mary Dingee Fillmore, 1993. For permission to reproduce outside EPA
Risk Assessment Forum, please call 617 969 4974.

Methods And Media
The number and variety of teaching methods and media that are available today
can be overwhelming. You can significantly increase the motivation, learning and
mastery of skills by wisely choosing appropriate methods and media.
The key is to be able to choose those methods and media that will most effectively
help you to reach your goaL If you try to teach or improve skills by using the
"lecture" format, very little actual learning will occur.
Below is a simple guide that describes various methods and media that you should
take advantage of in your training. It will help you to choose those methods that
will be most effective for your purposes.
The "lecture" format (standing up in front of the class and talking or reading to it)
is the most frequently used method of training
When used alone, it is also one of the least effective ways to teach.
However, used in conjunction with visual aids, and some structured interaction
with the class, it is a practical way to present "concepts", "knowledge", or
It is generally not a good way to teach skills.
During the lecture, don't hesitate to call on people to add to the knowledge you
are giving out. Never sav something in a lecture that vou could draw from the
group itself. For example, don't idl the group that the two most common types of
accidents in the kitchen are burns and cuts, when you can ask your trainees to tell
the class what they are.
Encouraging as much participation as possible in defining the problem, and
finding the solutions, will start your trainees thinking, and improve their

Be sure to make your lectures simple, clear and concise as possible. Limit your
material to 5 (or 7 maximum) points. Draw on examples that are familiar and
relevant to your employees in order to illustrate your points.
A presentation that shows how to use a procedure or perform an act. It is often
followed by a practice session in which trainee does activity under supervision of
A demonstration is often the most practical and straightforward way to teach a
particular task, procedure or skill.
Trainees are highly active and have a high interest level Provides practice, gives
instant feedback. Uses actual item and shows steps in logical sequence.
To be effective, it is important to break each task, skill or procedure into clear,
concise, logical steps, TTiis requires some thought and organization ahead or time.
Good for manual skills training. Is expensive and time consuming.
Don't find yourself like the instructor who said, "Oh, I forgot to tell you yesterday
that you must turn the red lever to the right... no, I mean to the left, every time
you want to shut off the machine... well, not every time, but whenever the
machine is hot..."
Buzz Groups
Buzz groups are discussions in which the trainer does not participate. The larger
audience is divided into groups of 5 to 7 members for a limited time—5 to 10
minutes-each group is given a task, or series of tasks, and each member
contributes his/her ideas.

The advantages of buzz groups are:
¦	It promotes nearly total participation on everyone's part
¦	Good for developing questions for a speaker or panel to generate information
¦	It promotes team building
1. Prepare the task.
Choose a topic that is relevant and somewhat controversial It is important to
limit the subject matter and make it specific.
The task should relate to objectives of the class.
It could be a case study which describes a difficult situation. The case study
should be written down and passed out to the group.
1 State the rules.
Give careful instructions and be certain the group understands what is
expected of it, and what its objectives are,
3.	Appoint a secretary or spokesperson.
Instruct the groups to appoint someone who will record what the group
decides, and present it to the larger group.
4.	Set a time limit.
Limit the buzz groups to 5-10 minutes. The discipline of problem solving with
an allotted time forces the group to focus on the task.
5.	Discuss the results.
Discuss the results of all the groups; why one group came up with different
solutions; how they feel about each other's solutions.

Role Play
Several individuals or a small group act out a real-life situation in front of a larger
group. The individuals make up their parts as they act-there are no scripts. Role
play helps understand human behavior and to improve attitudes. It allows players
to explore solutions without dangers of on-the-job trial and error.
The "Problem Solver" role play is one of the most effective formats for training. In
this format, one or more people are told to act out a character which creates a
problem for the other person, who is playing the role of "Problem Solver".
In role play, your function is to set the stage.
1. Choose a typical problem which might occur in your department.
The problem should be fairly simple and give the student a good deal of
latitude in solving the problem.
2 Explain carefully to the person playing the problem what the role entails.
Do not tell them what to say, but rather, tell them the mood they are in, and
the problems they have been through. You may wish to send the problem
solver out of the room while you are explaining the problem to the problem
role player and the rest of the group.
3.	Do not give the problem solver extensive instructions.
In most instances, they are going to play themselves.
4.	Instruct the group to be quiet and observe the role play carefully.
5.	After the role play is completed, ask the problem solver how it went.
Then ask the group. Finally, give your own comments.
6.	Repeat the role play using different actors if time permits.
7.	Give the rules for behavior or suggestions as to how the situation could be handled1

You may even take the role of the problem solver as an example.
& Variation
The role play just described will tend to give people practice in the right way of
handling a situation. Some people also use role play to show how to handle
a situation. In this case, you would give extensive instructions to both
participants, telling the problem solver to make as many mistakes as possible.
Following this role play, you can ask the group to list all the mistakes that were
made by the problem solver.
Additional Methods And Techniques For Adult
Correspondence Course
A type of individual learning where the communication between the learner and
source of instruction takes place by mail The learner proceeds through a
sequence of assignments, each of which concludes with an examination. The
examination is returned to the school where it is evaluated and returned to the
student. The learner proceeds through the course at his/her own rate.
One individual who possesses a skill teaches it to another. On-the-job training, as
the name implies, takes place in the workplace. Simple operations are taught first.
As the learner acquires these skills, more advanced operations are taught Four
steps are followed:
¦	Prepare the learner for instruction.
¦	Present the operation to the learner.
¦	Have the learner perform each part of the operation as it is taught
¦	Follow up on the training, make corrections and reinforce.

Participants spontaneously present ideas on a given topic No idea is dismissed or
criticized—everything offered is written down. Quantity, not quality, is sought
After the listing, the group clarifies, categorizes, and/or discusses each item. Gives
everyone an opportunity to participate.
Case Study
A detailed account of a real or hypothetical occurrence that trainees might
encounter on the job. Following discussion of the case, trainees are often asked to
produce a plan of action to solve the problem.
Field Trips or Tour
A group visits a place of educational interest for direct observation and study.
Provides first-hand knowledge, stimulates interest, illustrates results, and relates
theoretical study to practical problems.
Panel Discussion
A small group of resource persons with special knowledge of a subject having an
orderly conversation on an assigned topic in front ot an audience. Establishes
informal contact with the audience and stimulates audience interest and
discussions through frequent changes of speaker and viewpoint A skilled
moderator is needed to keep discussions going.
Programmed Instruction
Involves a self-instructional format, using print and/or other media. Progresses
from simple to more complex levels of instruction. Requires action involvement
of learners. Provides immediate feedback. Learner works at own pace.
Simulation (Gaming)
A structured experience in the form of a game that has the characteristics of a
real-life situation. May make a task simpler to understand. Allows trainees to
make decisions or take action in a "safe" environment

Permits extensive study of a specific topic Participants must be willing to work
independently and in groups in which they may improve their proficiency, develop
new operating procedures, or solve problems.
A close-knit group who work together in a formal manner. They give serious
consideration to problems and their specific solutions.
A recognized expen leads a discussion among a group of trainees who are
engaged in a specialized course of study. A seminar may be for one day or longer.
A series of prepared lectures given by two to five resource people with each
speaker presenting one aspect of the topic in usually less than 25 minutes.
A small group of trainees selected to ruitiii a function or perform a task that
cannot be done by either the entire group or one individual. The committee may
plan an activity, advise the group, study a particular problem, promote an event,
or evaluate a particular activity.


Training Methods Usage

Manual Skills
Job Function
Behav. Chg.


Bus Groups

Role Play

Correspondence Course



Case Study

Field Trip or Tour

Panel Discussion


Programmed Instruction


Simulation (Gaming)








Case Study
The case studv is a detailed account of an event or a series of related events
that may be presented to an audience orally, in written form, on him. or in a <<>m-
binatton of these forms
The Case Study May Be Used:
1	To present in detail to a group a problem with which
the group is concerned
2	To present and studv the solution of .1 |ir<>hlrm
similar to one confronting the group
3	To teach the prohlem-solving pwt«
Some Advantage*:
Gives a detailed accounting of the case under studv
Helps the learner to see various alternative solutions
to the problem.
Helps people develop analvtical and problem-sole ing
Some Limitation*: I. Some individuals may not see the relevance of the
case being studied to their own situation or the
group's problem.
2. A considerable amount of ume and thought is often
required to develop the study
V Some group members are stimulated 10 overpartm-
pation while others may assume a non-part iripamrv
Physical Requirements: I Physical requirements vary »uh the tvpe of presenta-
tion. If the case is presented through dramatic acting,
a stage area is required. If visual aids are required
in a presentation, the room should be suitable for this
kind of presentation. If the case studs is a written
one. a large table and chairs mav be all that is
Procedure*. 1. Materials are put into the hands of the pannip.ino
in advance if the case study is in written form and
to he read before the meeting
2. Appropriate techniques to use during the pn-snit.i-
lion and discussion are selected, and pan- rrhc.irsrd.
if necessary.
.V The chairman or moderator introduce the topic
explains what the case studv is. .ind the rcspc>n>thil-
ity of each individual. He then guides the disc ussmn
and other activitv.
Similar Methods and Techniques: I Written materials, tilm. the dr;»matu skit and spen h
may be used to present the case to the group Group
discussion is used to tarry out the second part ol
the case study

Role Playing
In role playing some members act out a real-life situation in front of the group.
There is no script, no set dialogue, and they make up their parts as they go along.
The group then discusses the implications of the performance to the situation or
problem under consideration.
Role Playing May Be Used: 1 To examine a delicate problem in human relations.
2.	To explore possible solutions to an emotion-laden
3.	To provide insight into attitudes differing sharply
from those of the participants.
Some Advantages: 1. A dramatic way of presenting a problem and stimu-
lating discussion.
2.	It can provide clues to possible solutions and explore
them without the dangers inherent in a real-life trial
and error approach.
3.	It gives the players a chance to assume the person-
ality of another human being~to think and act like
Some Limitations: 1 ¦ Some people may be too self-conscious or too self-
centered to act successfully in role playing. Others
may be shy and fear being made "ridiculous" before
the group.
2. Role playing before large audiences is less effective
because of the psychological effect of the large group
upon the players.
Physical Requirements: 1. A room large enough to provide seating so that all
members of the group may see the action. No stage
or platform is necessary with groups of 30 or less.
Costumes or elaborate props are not necessary.
Procedures: 1. The problem or situation is clearly defined by the
group before role playing begins, and the scene is set
by the group leader with the assistance of the group.
2.	Players should be selected just before role playing
begins and not warned in advance, although a brief
warm-up period may be necessary to thro* off self-
consciousness and get in the spirit.
3.	The leader should allow the action to proceed onlv so
long as it is contributing to understanding (usualK
five to ten minutes).
4.	After discussion a second set of actors may be chosen
and the scene replayed.
Similar Methods and Techniques: I Role playing is staged in about the same manner as
the dramatic skit. The primary difference is that in
the skit parts are assigned in advance and it is
rehearsed before presentation before the group In
role playing there is no advance preparation and all
is spontaneous. Role plaving dealing with problems
of a social nature is sometimes called a sociodrama.

Brainstorming is a technique where creative thinking takes precedence over the
practical. The idea ii to get out before (he group all ideas possible, with no thought
to how practical the ideas might be. The participants are urged 10 be as "free-
wheeling" and uninhibited as possible.
Brainstorming May be Uied: ). To get as many new and novel ideas as possible
before the group for evaluative discussion.
2 To encourage practical-minded individuals 10 think
beyond their day>to-day problems and to think
quantitatively instead of qualitatively.
3.	To move out on a problem when the more conven-
tional techniques have failed to come up wuh a
4.	To develop creative thinking
Some Advantages: 1. Many people are thrilled at the freedom of expres-
sion inherent in brainstorming.
2.	Solution* to previously insoiuable problems can be
3.	All members of the group can be encouraged to
Some Limitations: t. Many individuals have difficulty getting away from
2.	Many of the suggestions made may not be worth any-
3.	In the evaluation session it is necessary to criticize
the ideas of fellow members.
Pbysial Requirements: 1. A meeting room with a chalkboard or other surface
on which the ideas produced can be written hurriedly
and preserved for the follow-up discussion period.
2. A conference table or semicircle arrangement to en*
pedite discussion following the brainstorming
Procedure: I. The chairman explains the procedure to be used, and
a recorder is selected to list the suggestions.
2.	As ideas are thrown out they are recorded in public
3.	The ideas are discussed to determine if any have
practical application to the problem at hand.
Similar Mrthodf wj T**h»i'p—	Brainstorming is different from any other group
technique, although principles of group discussion
and buzz sessions are much in evidence.

Leading Group Discussions
Some techniques for conducting successful discussions follow:
¦	Set ground rules
Try to adhere to the amount of time allotted for each discussion.
Encourage everyone to participate.
Discourage interruptions to the speaker.
Monitor the discussion and the speakers.
End the discussion when the allotted time has passed.
" Establish a nonthreatening environment
Encourage open, relaxed communication. Keep the discussion on
a positive, constructive note. There are no wrong responses. If a
response is not the answer you are seeking, ask the group for
additional answers. When the correct answer is offered, substan-
tiate and support that answer.
¦	Ask for volunteers to respond to questions
Don't demand—invite and encourage participation. If necessary,
call on individuals who will not be intimidated by being singled out
You may be able to encourage participation from shy or quiet
individuals by engaging them in conversation during a break.
a Encourage participants to be concise and specific
Ask them to provide support for their answers.
" Encourage responses from personal experiences
The participants' personal experiences are important elements of
the learning process. Actual experiences help to relate the
material to on-the-job applications.
¦	Keep the discussion on topic
If a participant's response is clearly off the subject under
discussion, redirect the discussion by asking a question that ties it
back to the subject Or acknowledge the point and recommend
that it be brought up again at another more pertinent time in the
¦	Summarize what has been said
When it is time to move on to another topic or question,
summarize what has been said. This provides a valuable reinforce-
ment of key points and smoothes the transition between topics.

II. Introduction to P2

Pollution Prevention
Terms and Definitions
Environmental Pollution
Prevention Project
Environmental Pollution Prevention Project
U.S. Environmental Protection Agency
U.S. Agency for International Development
May 1994

"the time has come to
look not just to the
discharge of pollution from
the end of the pipe but to
scrutinize the production
process itself.
Treating pollution as
inevitable is a backward
concept in a competitive
Michael Deland, Chairman CEQ, 1993

What is Pollution/Waste?
"Pollution is nothing but the resources we are not harvesting. We allow
them disperse because we are ignorant of their value/'
Buckminister Fuller
"Waste should really be a verb; what we do with something if we cannot
avoid making it initially or find some useful purpose for if'
William Beck, DuPont Chemical Co.
"Waste is the result of our unwillingness or inability to design goods for
easy use, and use them over long periods of time through self-
replenishing, sustainable loops and to develop the necessary methods to
maintain a stock of goods."
Walter Stahl, Product Life Cycle Institute
"Pollution is the undesirable change in the physical, chemical or biological
characteristics of air, water or land that may or will harmfully affect
human life or that of other desirable species, our industrial processes,
living conditions or cultural assets, or that may or will waste or
deteriorate raw material resources"
EPA Science Advisory Board 1992
Waste can include:
-defective product,
-air emissions,
-wastewater discharges,
- solid wastes,
-hazardous wastes,
-production loss,
-excess energy and water consumption
-inefficient use of labor and raw materials
-unusable as well as discarded chemical residues

What is Pollution Prevention?
Pollution Prevention is defined as,
"source reduction practices that reduce the amount of any hazardous
substance, pollutant or contaminant entering any waste stream or
released into the environment (including fugitive emissions) prior to
recycling, treatment or disposal."
"use of processes, practices, or products that reduce or eliminate the
generation of pollutants and waste at the source, including those that
protect natural resources through conservation or more efficient
Pollution Prevention activities include equipment or technology
modifications, process or procedure changes, reformulation and or
redesign of products, substitution of raw materials and improvements in
housekeeping, maintenance, training or inventory control.
1.	Pollution prevention is a dynamic process that responds well to the
idea of continuous improvement	a move towards a zero
discharge is ideal.
2.	Pollution prevention is multi-media in that it addresses all forms of
pollutants and wastes including air emissions, wastewater
discharges and hazardous and solid wastes.
3.	Pollution prevention activities can be implemented by all sectors of
society including industry, governments, agriculture, energy and
transportation sector and consumers.
Pollution Prevention Act 1990
EPA Working Definition 1994
Keep in mind:

^"use of processes, practices, or
products that reduce or eliminate the
generation of pollutants and waste at
the source, including those that protect
natural resources through
conservation or more efficient
Pollution Prevention activities include:
-equipment or technology
modifications, modernization,
-process or procedure changes,
-reformulation and or redesign of
-substitution of raw materials and
-improvements in housekeeping,
maintenance, training or inventory

The members in your group all live adjacent to a large
chemical company.
As a neighbor of that company, list the reasons why,
living next to the plant, you might be concerned for
yourself, your spouse,
and family.

Now, the members in your group are all officers or
workers in that chemical company.
List the reasons why you might be concerned about your
company's use of toxic/hazardous materials.



The Obstacles
to Waste Reduction
Both industry and public-interest groups remain attached to the
established methods of pollution control Until we come to understand
why; the long-term benefits of waste reduction will remain elusive.
Joel S. Hirschhorn ami Kirsten U. Oldenburg, Office of Technology Assessment, Washington, DC 20510
Hazardous waste reduction—reducing the generation
of all environmental pollutants by changing indus-
trial production processes, technologies, proce-
dures. raw materials, and sometimes products—is gaining
popularity. Congress has shown considerable interest in
oaste reduction, and the Environmental Protection Agency
JPA) has a new Office of Pollution Prevention. The ERA'S
Science Advisory Board stated that pollution prevention
should be a major strategic initiative for the agency and
companies are discussing waste reduction more often. But
this new interest by industry and government in what is an
old idea may not be as significant as it seems, and a na-
tional, long-term commitment to waste reduction as a seri-
ous complement to traditional environmental protection is
not assured.
While fewer companies and'environmental groups are ig-
noring waste reduction, many people and organisations give
it a low priority relative to other environmental issues, to
regulatory problems, and to traditional forms of waste man-
agement. Waste reduction seems different than other areas
of federal involvement Because its benefits appear so great
J5. Hlnehfconi b a senior aitoritrte at the Congressional Office of
Ttdmohgg Aiuumtnt (OTA) who hat directed ttafin on hazardous
wastes that helped shape the 1984 amendments to tht Resource Con-
servation and Recocerg Act, tht 1986 Superfund Amendment and
Smathmizatkm Act, md teoeral matte reduction UBt, The author of
more titan 100 paptn and several books, ht hotdt two VS. patents
end it a frequent speaker on hazardous watte at conferences and
woikihops. Prior to Joining OTA, he wot a proftum of tuyimeerlng
n ov vmw* of ifomnn « wwiwii
K.U. OMeaborg, a potteg anafgst with OTA (or the past dee wears,
currenttg conducts research on the Supeihmd program and mtmki•
pal toUd watte. The author or co-aatnor of numerous articles an
watte reduction and ttrategk materials, the was assistant project dt-
•tctor of the 1986 OTA report, -Serious Reduction of Hazardous
Waste," and a special reporU-"Fnm Foliation to Prevention: A Prox-
ies* Report on Ntafc Reduction" (1987). She earned her BS degree
to materials science and engineering from the 1Mb. of CaBfornia at
and widespread, it seems as though it should happen by it-
self. Because it is easy to miss the obstacles to waste reduc-
tion and to overlook the negative consequences of relying on
industry and the states to implement waste reduction, not
understanding the importance of federal waste reduction
policy is also easy.
The public has heard little about waste reduction, partly
because waste reduction as good news does not compete
well with all the bad environmental news. They have not
linked past successful energy conservation and preventive
health care experiences to the possibility of future environ-
mental waste reduction. There is little public debate on fed-
eral waste reduction policy, programs, or appropriations.
Moreover, widespread frustration with the ineffectiveness
and inefficiency of the current pollution control system has
not created a viable, parallel prevention strategy that is at-
tractive to government, business, and environmentalists.
After a hard analytical look at the facts, many people
agree that a major national shift away from traditional reg-
ulated end-of-pipe pollution control to voluntary pollution
prevention is technically and economically feasible, but it
has not yet occurred. Extensive data from industrial exam-
ples make the case that true waste reduction, as a preven-
tive tactic, provides the most certain environmental protec-
tion and is profitable to industry. Pollutants not produced
cannot harm humans and the environment Waste reduc-
tion can cut industry's escalating waste management, pollu-
tion control, regulatory compliance, and liability costs, and
it can do so with small investments that yield returns within
weeks, months, or rarely, a year or two—at least in the ini-
tial stages.
If we accept these findings, then we must understand why
more industry and public-interest groups do not aggres-
sively support government help to industry, help that is de-
signed to reap the environmental and economic benefits of
waste reduction. Some believe that a major federal effort is
June 1989

unnecessary because industry and individual states are
doing enough. There are more and more publications and
conferences about waste reduction, and some states have
passed laws and set up programs to help industry reduce
waste. But these efforts are very small compared to estab-
lished environmental programs, are often focused on mini-
mizing use of landfills disposal rather than on true waste
reduction, and frequently directed to small waste genera-
tors who account for only a fraction of the nation's environ-
mental waste generation.
We believe that many in the private sector have not yet
seen the critical need for a major federal waste reduction
program because they are worried about possible secondary
impacts. Industry fears burdensome waste reduction regula-
tions. Companies in the waste management and pollution
control business may lose markets, and environmental or-
ganizations worry about losing support for established reg-
ulatory programs. These concerns, if not confronted, will
handicap public debate and impede the development of fed-
eral waste reduction policy and well-funded programs.
The real problem
The new interest in waste reduction may hide a serious
national problem: nearly every part of American society is
mentally locked into the established, institutionalized pol-
lution control culture, a paradigm that defines environmen-
tal protection in terms of what is done to wastes and pollu-
tants once they are produced. Many people do not realize
that pollution control often transfers pollution from one
regulated environmental medium to another, and some-
times the other medium is a less- or nonregulated medium.
And pollution control is based on the concept of safe or al-
lowable levels of pollution, which, because they are so diffi-
cult to set, means that many hazardous substances remain
unregulated while debate continues for years. Pollution con-
trol also pits economic and health benefits against one an-
Another problem, particularly in the environmental and
public-interest community, is the difficulty in seeing waste
reduction as a fundamentally different strategy to achieve
commonly accepted environmental protection goals. The
switch from pollution control to pollution prevention is a
classic example of a paradigm change—a truly profound
change in the way people think about something. Changing
to a new paradigm takes time. In the interim, most people
fail to see the comparative advantages of the new paradigm
and the old one continues to prevail. And so it is for waste
reduction. Although many do not see waste reduction nega-
tively, they do not see it as better than pollution control.
These problems help to explain why stepping briskly from
belief in waste reduction to political action appears to be
impeded by diffuse and cautious support for (rather than
explicit objection to) waste reduction as well as (at times) by
subtle attempts to redirect waste reduction policies and pro-
grams, particularly in favor of recycling and waste treat-
A number of waste reduction bills have been introduced
in Congress to greatly expand the federal waste reduction
Loading and unloading facilities at Eastman Chemical Products. Al.
pipelines, tanks and pumps at site are restricted to one product ani
all lines have filter systems. Photo courtesy of Eastman Chemica,
effort at the Environmental Protection Agency, to provide a
consistent national framework (including how to define and
measure waste reduction), and to fund state prograr
While differing in a number of details, only one of tfu
bills calls for traditional prescriptive regulations for in-
dustry. Instead, the bills focus on government-provided
technical assistance to industry of a kind already proven in
several demonstration programs (e.g., Ventura County, Cal-
ifornia, and North Carolina). Last fall, the House and Sen-
ate passed waste reduction bills but did not have time tc
reconcile them in conference. Serious congressional consid
eration of waste reduction or pollution prevention in 198£
seems assured.
Although there are many dedicated people working to put
waste reduction on the national agenda, there has been lit
tie widespread public support of such bills by either indus
try or public-interest groups. At a congressional hearing ir
April 1988, only one of several industry representative:
supported legislation. The lack of visible, organized suppor
appears to be inconsistent with the generally acceptec
benefits of waste reduction. Meanwhile, using the appropri
ations route, Congress has supported waste reduction b;
providing greatly increased funding for waste reduction ir
recent EPA budgets, but these funds still are only a tin)
fraction of the EPA's total budget
The problem of implementation. The literature detail
ing the technical and economic feasibility, costs, and bene
fits of waste reduction is voluminous. Thus, there is no neec
to repeat yet again examples of successful waste reducti>"
There is only need to caution that just as zero risk and .
emissions make little sense, zero waste generation for ai
industry is also an abstraction that must yield to the laws a
Chemical Engineering Progra

•« —	
* v A major national shift away from traditional regulated\ end-
jf-pipe control to voluntary pollution prevention is technically and
economically feasible.
rhwics and chemistry. But the waste reduction literature
(tos dearly indicate that it is sometimes possible to totally
dmrinate a specific wastestream, even a very large one, from
> mature industrial process. Additionally, the level of yet
unrealized waste reduction is large: the Office of Technol-
ofr Assessment estimates that neither technology nor eco-
nomics prevents industry from reducing its environmental
wastes by up to 50% within the next few years. Several in-
dustrial firms and federal agencies have adopted this level
of waste reduction as a short-term goal. Research and de-
velopment efforts could, in time, lead to even greater reduc-
The larger problem with implementing waste reduction m
industry is that a host of nontechnical factors work against
its application. One, for example, is lack of information: it is
common for people in industry to conclude that they have
exhausted their waste reduction opportunities when, in fact
they have not Other factors are competing production
priorities, the belief that legally required pollution control is
pood enough, lack of management support to allocate pec-
's time and capital for waste reduction, lack of rewards
successful waste reduction, accounting systems that do
not allocate total environmental costs to production profit
centers, incomplet&data on the exact sources and amounts
of environmental wastes, and the difficulty of simultane-
ously spending resources on regulatory compliance and
waste reduction. As a number of pioneering companies have
shown, all of these, except the last, will yield to determined
management attack from the top.
Some companies and states have adopted a hierarchy of
waste management options with waste reduction at the top.
To agree in principle with the primacy of waste reduction,
however, is not the same as implementing it with a vigorous
long-term commitment. For example, in 1976 the EPA
adopted such a hierarchy for solid waste, but until waste re-
duction was publicly resurrected a decade later, it had de-
voted nearly no resources to its implementation.
Congress has made the critical leap in thinking. The Haz-
ardous and Solid Waste Amendments Act of 1984 (HSWA)
states: "The Congress hereby declares it to be the national
policy of the United States that wherever feasible, the gen-
eration of hazardous waste is to be reduced or eliminated as
expeditiously as possible. Waste nevertheless generated
should be treated, stored, or disposed of so as to minimize
the present and future threat to human health and the en-
rironment" While Congress has unambiguously stated the
"rimacy of waste reduction, it has not applied the principle
all wastes and pollutants because HSWA deals only with
legally defined hazardous wastes, a subset of all environ-
mental pollutants. (The law also included minor regulatory
requirements. Companies must certify that they are pursu-
ing waste minimization, a term broadly interpreted by in-
dustry (and, until recently, the EPA) to include waste reduc-
tion, waste recycling, and waste treatment]
Arc current efforts enough?
The most obvious explanation for the lack of interest in
establishing a major federal waste reduction effort is the be-
lief that for the most part industry has gotten the waste re-
duction message, taken its primacy seriously, understands
its benefits, ami made the necessary commitments to imple-
ment it over the long term.
This hypothesis is not easy to affirm or deny. Because we
have a dominant end-of-the-pipe pollution control system, we
have very little systematic, reliable data on waste reduction,
and we probably will not have data for some time. Based on
the monitoring of waste reduction data from industry and
government and participation at waste reduction confer-
ences nationwide, the authors believe that much of the talk
about waste reduction is misleading. We do not think that
the nation has turned the corner on waste reduction imple-
mentation. Waste reduction has not yet taken hold as a key
environmental protection strategy in government or indus-
Very few companies provide detailed information on their
waste reduction performance on a plant or company basis.
They speak in generalities or give specific examples that tell
very little about the company's generation of waste relative
to changes in its production output Much of the available
data is misleading. Improving industrial efficiency by cut-
ting waste production is variously called waste reduction,
source reduction, pollution prevention, or waste minimiza-
tion. There are no standard definitions. Companies often
claim that activities (such as incineration) that follow the
generation of a waste, rather than only those that avoid
waste creation, handling, movement and management are
waste reduction. Survey results and published papers show
that probably 75% of companies use a definition of waste
reduction that includes improved waste management and
pollution control.
Data from government sources are difficult to interpret
because wastes are accounted for by environmental media
(which differ). It is also not possible to separate out waste
reduction effects from effects caused by other factors, such
as changing regulatory definitions, plant closings, and vary-
ing levels of regulatory enforcement
Finally, companies may only pursue short-term waste re-
duction benefits. Waste reduction in any plant proceeds
through several stages. Companies without long-term com-
mitments to waste reduction often only tackle the first easy,
and low-cost waste reduction opportunities and then lose
interest They do not push waste reduction to its limits. As
June 1989

.lion paybacks decrease and projects become
ex and dependent on capital and R&D, public
tave to play a more critical role,
mpanies are providing good data showing that
nts of profitable waste reduction can be accom-
ckly. But these companies are the exception, not
heir successes do not mean that current public
ifficient; it only means that some companies have
xs to recognize the advantages and act accord-
s "Pollution Prevention Pays" and Dow Chemi-
ite Reduction Always Pays" are more than slo-
> are simple statements of economic fact These
% and others continue to work to overcome obsta-
ste reduction. Not every company will do so.
ing industrial priorities
ment intervention in the area of waste reduction
iate economic winners and losers, which may ex-
general reluctance of industry to support a gov-
eadily increasing national spending on the environ-
ow over $80 billion annually—helps companies un-
. the benefits of waste reduction, it also defines a
opportunity for many of America's largest manu-
i companies. Waste management and pollution cori-
ot a niche market More and more companies have
itering this business, often using the waste treat-
spertise they gained internally. This is particularly
ce Congress mandated the shift away from land dis-
f hazardous waste.
i a company has a successful waste reduction pro-
nd is in the waste management business, it is diffi-
it to see any advantage in supporting a government
m that would assist other companies in reducing their
generation, which would shrink the waste manage-
•ollution control market A government waste reduc-
rogram would create some new consulting business,
ire would be little demand for expensive hardware or
jering services.
sn a company with a successful waste reduction pro-
is not in the waste management/pollution control
iss, a government program could reduce its competi-
dvantage relative to firms without a successful waste
tion program. Moreover, a company that has done it on
m may feel that it is unfair for the government to assist
companies with less initiative,
d what about companies without successful waste ic-
on programs? A company that has not recognized the
omic benefits of waste reduction is unlikely to see much
ose in a government waste reduction program.
»r all companies, and particularly for those without a
essful waste reduction program and no waste manage-
it/pollution control business, there is the understand-
fear that any federal waste reduction initiative, even if
. nonregulatory today, wfll lead to a traditional regula-
' program tomorrow. Waste reduction, in other words,
> victim to industry's mistrust of any regulatory agency,
is is why some states have" kept their waste reduction
•grams out of their environmental regulatory agencies.)
Indeed, congressional waste reduction action in the context
of the Resource Conservation and Recovery Act regulatory
program for hazardous waste would support industry con-
cerns. Few companies yet understand how a nonregulatory
waste reduction program could make the regulatory pro-
grams easier to bear; most give greater weight to their fears
of waste reduction turning into a regulatory program.
Industry has two major concerns about waste reduction
regulation. One is that regulations requiring certain levels of
waste reduction might result in the elimination of certain
products and that the waste reduction concept might be ex-
tended to unregulated and postconsumer wastes. The latter
is particularly threatening because, from the industrial per-
spective, a company that is not generating a harmful waste,
or that is managing a waste in compliance with regulations,
could be forced to change or drop an established, profitable
product because of waste created late in the product's life
cycle. Indeed, a new interest in municipal solid waste reduc-
tion (ordinary garbage and trash) is upon us.
The other is that a company voluntarily reducing its waste
generation today—or yesterday—might be required to meet
some arbitrary additional level of waste reduction at great
cost and difficulty tomorrow. (This concern explains why
some major companies may not be revealing past waste re-
duction accomplishments; they ate "banking" them in case
they are needed to satisfy future regulatory requirements.)
Public-interest groups: Priorities and
People active in waste reduction during the past decade
are perplexed by the feet that so few environmentalists (and
even fewer environmental and public-interest organizations)
have made waste reduction a high priority. A few grass-roots
activist groups have, but they do not concentrate on federal
policy. The early writings of environmentalists, such as
Rachel Carson, contain the prevention theme, such as
avoiding the use of certain pesticides.
Early on, environmentalists accepted the pollution con-
trol strategy as expedient Limiting, not eliminating, pol-
lution was a practical first approach to solving the newly
perceived and overwhelming problem. Organized environ-
mental interests and public policy, however, have become
attached to the pollution control strategy. Environmental-
ists, like everyone else in the environmental regulatory
arena, have learned to play, maintain, and expand the
mostly legalistic game according to established rules.
Expertise, priorities, and commitments are established.
Partial wins seem preferable to gambling on a new strategy.
Support of a federal waste reduction initiative might detract
from political interest in and, possibly, funding for existing
regulatory programs. Waste reduction might even make the
limitations and faults of hard-won regulations more visible.
Moreover, there is a deep suspicion among environmental-
ists that a nonregulatory waste reduction program might
create oppoprtunities for industry to compromise regulatory
programs without really eliminating pollution. Some envi-
ronmentalists and people in government advocate the indi-
rect approach of expanding end-of-pipe regulatory programs
and improving enforcement, thus increasing costs to indus-
Chendcal Engineering Progress
ct on the waste
be countered by
'up market and
to waste level—
be allayed by a
"ogram, which,
uccessful waste
fer increasing
as industry be-
«d exiting, in
•bout waste re-
"ol would also
heir priorities,
will offset the
ing waste. For
cleanup sites
ible waste re-
lillion to the
f industry
s now at
*ste manage-
rs would be
federal tech-
re not likely
tax income
e reduction
benefits of
x 10 years
"al environ-
. even with
uction and


activities at EPA, such as regulatory development,
permitting, inspections, and enforcement, must reflect our
commitment to reduce pollution at the source, and
minimize the cross-media transfer of waste.
~	State and Local Partnerships: Increasingly, state and
local agencies are the "face of government" for the general
public. We will strengthen the national network of state
and local prevention programs, and seek to integrate
prevention into state and local regulatory, permitting, and
inspection programs supported with federal funds.
~	Private Partnerships: We will identify and pioneer
new cooperative efforts that emphasize multi-media
prevention strategies, reinforce the mutual goals of
economic and environmental well-being, and represent
new models for government/private sector interaction.
~	Federal Partnerships: We must work closely with our
counterparts in other agencies to ensure that pollution
prevention guides our management and procurement
decisions, and to pursue opportunities for reducing waste
at the source in die non-industrial sector.
~	Public Information/The Rieht-to-Know: We will
collect and share useful information that helps identify
pollution prevention opportunities, measure progress,
and recognize success.
~	Technological Innovation: We will try to meet high
priority needs for new pollution prevention technologies
that increase competitiveness and enhance environmental
stewardship, through partnerships with other federal
agencies, universities, states, and the private sector.
~	New Legislation: Where justified, we must not hesitate
to seek changes in federal environmental law that will
encourage investment in source reduction.
4. Definition
EPA has defined pollution prevention as "source
reduction" as that term is explained under the Pollution
Prevention Act, as well as protecting natural resources
through conservation or increased efficiency in the use of
energy, water, or other materials. EPA staff should
continue to use this definition, as elaborated in the
Agency guidance issued in May of 1992.
The guidance makes clear that pollution
prevention is not the only strategy for reducing risk but
is the preferred one. Environmentally sound recycling
shares many of the advantages of prevention — it can
reduce the need for treatment or disposal, and conserve
energy and natural resources. Where prevention or
recycling are not feasible, treatment followed by safe
disposal as a last resort will play an important role in
achieving environmental goals. In all cases, we must bt
guided by applicable statutory requirements.
5.	Regulations And Compliance
Our first obligation at EPA is to fulfill the
statutory responsibilities we have been given by
Congress. That generally means developing
environmental standards through regulation, and
ensuring compliance through a system of permits,
inspections, and enforcement actions. I firmly believe
that strong environmental requirements, if designed to
encourage cost-effective compliance strategies from
industry, can promote pollution prevention and improve
the competitiveness of American industry.
We can take a number of actions to realize this
potential. First, we must work within the law to design
and implement our regulations to provide incentives for
source reduction. That will mean better coordination of
different regulations that affect the same industry to
reduce transaction costs, minimize cross-media transfers
of waste, and provide a clearer sense of our long-term
goals for the regulated community.
— EPA's Source Reduction Review Project (SRRP),
which is exploring how best to encourage pollution
prevention in the design and implementation of rules
affecting 17 high priority industries, is a good star
toward this goal I also will expect programs to evaluat
opportunities for preventing pollution in each major
proposed regulation, as the Pollution Prevention Act
Second, we must encourage pollution prevention
as a means of compliance through our permitting,
inspection, and enforcement programs, relying on the
first-hand experience of regions and states in this area.
We can learn valuable lessons from experiments like the
Massachusetts Waste Prevention F.I.R.S.T. project,
through which the state promotes source reduction as the
principal means of correcting violations detected through
multi-media inspections.
Finally, we need to collect better data on those
cost savings that occur when regulations encourage
investments in cleaner, more efficient manufacturing
processes. As part of this effort, we must develop
credible measures of the economic value of natural
resources protected through prevention. We must also
explore non-traditional alternatives, such as life-cycle
analysis, that help shed light on the advantages
prevention can offer in meeting our objectives.
6.	State and Local Partnerships
The Clinton Administration has called for a full
partnership between federal, state and local governments
in defining and carrying out national policy objectives.
We delegate so many responsibilities to states and

localities under federal environmental law; we simply
cannot hope to offer effective incentives for pollution
prevention in permits or inspections without their close
cooperation. Furthermore/ some states have served as
national laboratories for the incubation of exciting new
multi-media experiments in reducing waste at the source,
and are often more in touch with industry and public
needs and how best to meet them. Several states also
have taken the lead in helping their citizens and
businesses use energy more efficiently.
We can explore different methods for offering
state and local governments more flexibility in the federal
grants used to support delegated activities like
permitting, inspections, and enforcement actions. EPA's
new guidance, beginning in the 1994 fiscal year,
encourages our regions to work with states to adjust
administrative procedures in grant workplans to make
room for pollution prevention investments. EPA regions
and states should make maximum use of this flexibility,
working within the statutory limits that govern grant
eligibility. The guidance requires programs to report on
legal barriers to funding worthwhile state pollution
prevention projects, so that we may consult with
Congress to seek appropriate remedies.
We also must trust our state partners with greater
responsibility for the Pollution Prevention Information
Clearinghouse, which will facilitate prevention technology
transfer and technical assistance. Our Regional Offices
also have lead responsibilities in the allocation of State
grant monies under the Pollution Prevention Act and in
3ie use of Regional extramural resources (ie. the 2%
funds) allocated to pollution prevention activities. We
must make effective use of these resources to support
strong state and local pollution prevention programs.
7. Private Partnerships
Collaborative efforts with industry or public
agencies in many cases can help us achieve results
through pollution prevention more quickly than could be
obtained through regulation alone. For example, EPA's
Green Programs to promote voluntary energy efficiency
will play a critical role in helping meet our obligations
under the U.S. Action Plan to stabilize greenhouse gas
emissions by the year 2000.
Furthermore, regulations often do not reach the
more complicated corporate decisions needed to evaluate
design, manufacturing, packaging, distribution and
marketing practices to reduce pollution and energy
consumption. We must encourage these efforts by
entering into partnerships with public and private
organizations where such cooperation can produce
tangible environmental results. EPA's collaborative
efforts - like the Green Programs, 33/50 and Design for
Environment - offer encouragement, assistance and
public recognition tojhose companies and groups willing
to commit the resources needed to get the job done.
Recently, these initiatives have expanded to
include WAVE, a program to encourage water
conservation with the hotel/motel industry. Earlier this
year, EPA proposed an "Environmental Leadership"
program to reward corporations willing to go beyond
compliance by making measurable commitments to
pollution prevention. EPA's FY 94 budget proposal
requests a substantial increase in funding for these
programs, reflecting our commitment to achieve
environmental gains by working cooperatively with
industry. These investments will supplement, but not
substitute for, regulatory approaches to pollution
8.	Federal Partnerships
President Clinton's Earth Day speech challenged
the federal government to, "lead by example - not by
bureaucratic fiat" Our government has a tremendous
impact on the environment as the nation's largest
landlord, and its biggest consumer of goods and services.
Later this summer, we expect to complete action on an
Executive Order that commits federal facilities to publicly
report wastes and emissions under TRI, establishes a
voluntary goal of cutting federal TRI releases 50% by
1999, and builds pollution prevention into the
specifications and standards that guide federal purchases.
EPA recognizes that other federal agencies can create
major opportunities for pollution prevention through
investments in new technologies, and through policies
that shape decisions in agriculture, energy, transportation,
and the management of natural resources. If we want
pollution prevention to expand in these sectors, we must
form partnerships that take advantage of the authority
and expertise at other federal agencies.
9.	Public Information/The Right-To-Know
Since pollution prevention is motivated in part by
public information, one of EPA's most important tasks is
to collect and disseminate "user-friendly" data that
measures progress in reducing waste at its source. The
Toxics Release Inventory (TRI) as amended by the
Pollution Prevention Act now requires 28,000 industrial
facilities to publicly report on the amounts of toxic
chemicals generated as waste or released to the
environment. These and other environmental data have
proved vital in helping industry to identify opportunities
to reduce waste and improve economic efficiency.
Through public disclosure, the TRI empowers local
communities, State agencies and other public interest
groups to become stronger advocates for pollution
I am committed to strengthening the Toxics
Release Inventory, both by improving the quality of the

information and by making more effective use of EPA's
existing authority to expand the scope of reporting to
additional chemicals and major sources of pollution. We
will also make the information more accessible and
understandable" to states and local communities that
depend on timely and accurate data.
EPA's public data bases are not limited to TRI.
Preventing chonical accidents also is important, and the
Agency collects information on chemicals that can present
a hazard if released during an accident Data collected
under laws such as the Clean Air, dean Water, and
Resource Conservation and Recovery Acts are important
indicators of environmental risk as well as prevention
opportunities, and EPA must take steps to integrate this
information and make it more readily accessible to the
We cannot stop at collecting and interpreting
data. We should encourage public education, from the
university to the grade school level, that illustrates the
importance of environmental protection and the benefits
of prevention.
10. Technological Innovation
Cooperative efforts with universities, industry,
and other Federal agencies help raise awareness of
prevention opportunities and attract leading scientists
and engineers to engage in demonstration, development,
and research focused on new prevention technologies.
Accordingly, we must expand work with groups like the
Department of Energy and its National Laboratories, the
National Science Foundation, the National Institute for
Standards and Technology (NIST), states, and the private
sector to advance both the development of new pollution
prevention technology and the effective delivery of
information about such technology to companies looking
for more efficient environmental solutions.
I want to make sure that some of the funding
available through the President's Environmental
Technology Initiative is targeted to help small businesses
meet compliance requirements through pollution
prevention while remaining competitive. As part of this
effort, I will expect our programs to work together to
identify small business needs so that we may target short
term technical assistance and long term cooperative
research in developing cleaner, more efficient
11.	New Legislation
I am convinced that we can achieve many
important pollution prevention goals working under
existing federal environmental laws. Where these statutes
present significant barriers to reducing waste at the
source, however, we should not hesitate to share this
information with Congress and, if needed, seek
appropriate statutory changes. I want to be sure that any
effort to seek new authority is informed by fact. That is
why it is particularly important to gather specific and
accurate information on legal barriers to source reduction
identified when developing regulations and negotiating
grants with states.
12.	Conclusion
I expect pollution prevention to continue to
evolve at EPA. As we learn more, no doubt we will ha'
to make adjustments to our programs that reflect ne
knowledge. In die final analysis, what is critical in our
efforts to advance pollution prevention is a willingness to
take chances, to question established practices and
experiment with new ideas, and above all to cooperate
with each other as we try to harmonize environmental
protection with economic growth. I hope you share my
excitement at the new possibilities for pollution
J>revention in the Clinton-Gore Administration, and I look
orward to working with all of you to achieve the
ambitious goals of this policy.
Carol M. Browner
EPA Administrator
June 15,1993

Pollution Prevention Strategy Summary
Strategy Objectives
EPA's pollution prevention strategy is designed to serve two purposes:
o To provide guidance and direction for efforts to incorporate pollution
prevention within EPA's existing regulatory and nonregulatory programs;
o To set forth a program that will achieve specific objectives in pollution
prevention within a reasonable time frame.
The first objective underlies EPA's belief that for pollution prevention to
succeed, it must be a central part of the Agency's primary mission of protecting
human health and the environment; the goal is to incorporate prevention into
every aspect of die Agency's operations in program and regional offices. EPA
encourages its programs and regions to continue to identify and exploit pollution
prevention opportunities. Many such initiatives are already underway or being
planned by program and regional offices.
To promote the second objective, achieving measurable results within a few
years, the strategy includes a project which involves targeting high risk chemicals
that present the potential for prevention, and sets a goal of reducing
environmental releases of these chemicals by 33 percent by the end of 1992, and
at least 50 percent by the end of 1995. This industrial toxics project is only the
first step ~ EPA has plans to work with other federal agencies to develop
strategies for the other sectors where significant opportunities for prevention
exist, such as agriculture, energy, transportation, and municipal water and
industrial wastewater.
General Principles
The following general principles will help to guide the Agency's specific
pollution prevention activities:
o The Agency's policy will be designed to maximize private sector
initiative by challenging industry to achieve ambitious prevention goals;
o EPA will continue to develop its strong regulatory and enforcement
program under existing statutory authorities to provide further incentives
to prevent pollution.

Institutionalizing Pollution Prevention
Based on these general principles, EPA will be working on die following
categories of activities which serve to incorporate prevention into existing
o Identifying and overcoming barriers to prevention ~ EPA is undertaking
several projects to identify specific regulatory barriers and determine how
they can be modified. Technical and financial assistance and information-
sharing are means to breaking down barriers among small and medium-
sized businesses;
o Expanding public participation and choice -- EPA is responding to die
public's need for more and better information about die environmental
impacts of both consumer products and industrial facilities by establishing
voluntary labeling standards and expanding public databases;
o Partnership with federal agencies - EPA will cultivate strong relationships
with the Departments of Agriculture, Energy, and Transportation and
other federal agencies to develop prevention strategies, to incorporate
prevention into management of federal facilities, and to increase the
consideration of environmental impacts in federal procurement decisions;
o Investing in the states - Through its Pollution Prevention Incentives for
States grant program, EPA is encouraging states to establish and expand
their multi-media prevention programs and is testing innovative
technologies and applications in the field;
o Outreach and training - EPA will continue to conduct educational and
outreach initiatives in an effort to foster a prevention ethic within
government, industry, academia, die general public, and internationally;
o Regulations and permits - The Agency will seek to strengthen the ability
of the existing regulatory framework to provide further incentives for
Hie Agency will categorize upcoming rules into regulatory
clusters which will improve cross-media evaluation of die
cumulative impact on standards and will encourage early investment
in prevention technologies and approaches;

As the Toxic Substances Control Act is a flexible statute well
suited to multi-media strategies, EPA will increasingly rely on
TSCA in developing cost-effective responses tailored to specific
environmental statutes;
EPA's regions will take die lead in investigating opportunities for
source reduction in permit writing. EPA is also assessing the
feasibility of a coordinated multi-media permitting system and of
requiring permits to include prevention plans.
o Enforcement - EPA will encourage the inclusion of pollution prevention
conditions in its enforcement settlements;
o Research -- Shoit-term research efforts will focus on targeted contaminants
and longer-term efforts will be directed at prevention opportunities in
other sectors and barriers to prevention;
o Emerging products and technologies - EPA will encourage development
of safer substitutes for hazardous raw materials and products, as well as
cleaner technologies.
EPA will also take steps to remove the institutional barriers that exist
within its own organization. Among the planned measures are: designating
special assistants for pollution prevention within each Assistant Administrator's
office; developing incentives and awards to encourage Agency staff to engage in
prevention initiatives; incorporating prevention into the comprehensive four-year
strategic plans that each program office develops; providing training to Agency
staff on pollution prevention; and including prevention-related activities in the
Agency's annual planning and regulatory review and development processes.
Industrial Toxics Project
EPA's industrial toxics project targets specific chemicals that are reported
and tracked in die Toxic Release Inventory and will develop focused prevention
strategies foe diem. EPA's goal will be to reduce aggregate environmental
releases of these targeted chemicals by 33 percent by the end of 1992 and by at
least 50 percent by 1995. Hie major elements of this project are:
o Targeting — EPA has developed a list of 17 TRI chemicals, drawn from
recommendations by program offices, based upon criteria including high
levels of emissions, technical or economic opportunities for pollution
prevention, potential for health and ecological risk, potential for multiple
exposures or cross-media contamination, and limitations of treatment

o Outreach - The Agency is seeking voluntary, measurable commitments
from Qiajor industrial sources of these contaminants to reduce
environmental releases through prevention. Beginning in early 1991, EPA
intends to produce a detailed plan for contacting these facilities or their
parent companies to ask diem for voluntary, measurable commitments to
reduce releases of targeted contaminants and to develop prevention plans to
cany out these commitments;
o Organizing for action - EPA will form cross-media workgroups to
provide analytical and technical support for the outreach program, to
evaluate industry voluntary plans, and to define regulatory clusters;
o Measuring progress - EPA will rely on data from the Toxic Release
Inventory to track reductions in releases of targeted contaminants from
industrial facilities. The Agency will develop more appropriate indicators
from sources not covered by TRL
Next Steps
While implementation of this strategy proceeds, EPA will be undertaking a
number of efforts to expand the scope of this strategy:
o EPA will work with the Departments of Agriculture, Energy, and
Transportation to develop specific pollution prevention strategies for these
o EPA will continue to work with other federal agencies to define an
appropriate federal role in pollution prevention and pollution prevention
strategies for federal facilities;
o Through a series of public hearings, EPA will begin work on a National
Pollution Prevention Agenda for the 1990s, with broad input from the
public, the private sector, the environmental community, local, state, and
federal government agencies, and the international community.

Communication SkiUs Instructional Strategies
The Art of Asking
By Dorothy Leeds
Every time you open your
mouth to speak, you have only
two options: making a state-
ment or asking a question. Perhaps
the most important lesson trainers
can learn is how to know which
option to choose.
When you are training, questions
can be your most vital tool. Robert
Focazio. a regional sales vice-presi-
dent at AT&T. says. "If you improve
your questions by 10 percent, you
improve your productivity by 20 per-
cent—and that's being conservative!"
These are the keys to improving
the questions you ask and the way
you ask them:
» realizing the incredible power of
> learning how questions can get
you past the barriers that block the
information you need
t applying specific questioning
techniques to the three phases of
training—needs analysis, program
content, and evaluation.
I first realized the power of ques-
tions as 1 was looking for ways to
improve my own training abilities. 1
was not achieving my training goals
and was looking for ways to get my
participants more actively involved. I
researched the art of questioning; in
the process I wrote a book on the
power of asking smart questions.
Through my research. I discovered
that asking questions is the most
effective way to get people moti-
vated and to optimize the learning
The first thing you do when
you're planning and conducting a
training session is to ask questions. I
believe asking questions is the only
way to plan and implement an effec-
tive training program.
You probably have a list of ques-
tions that you ask when doing a
needs analysis, conducting training
sessions, and evaluating a program.
But are you getting the information
you really need to meet your own.
your clients', and your trainees
needs and expectations?
Do you get the best information
in your day-to-day work? Do you
know if what you are trying to say
is understood? You have to do
more than just ask questions. You
must refine—perhaps redefine—the
kinds of questions you re asking.
The secret to getting the informa-
tion you want and need is asking
smart questions.
Training c- Development. January 1993 87

The five &eat powers of
From Socrates in ancient Greece to
millions of game-show viewers
today, people have always been fas-
cinated by—and learned from—the
fine art of asking questions. Ques-
tions affect your communication abil-
ities in five powerful ways.
Questions da maud answer*. A ques-
tion is like an electric shock to the
mind. As soon as you hear a ques-
tion, you feel compelled to answer.
The impulse to answer a question—
any question—is as automatic as the
"fight or flight" response. A question
is the most effective way to get com-
munications starred—and to get the
response you need.
Questions put you in central. As most
teachers and trainers already know,
the person asking the questions sets
the direction and topic in a discus-
sion. and maintains a sense of control
in a difficult situation. Most psycholo-
gists agree that anxiety arises from
loss of control. Because the other
person is compelled to answer, the
power goes to the person asking the
question. Just watch the power shift
when someone asks. "Where are you
going?" and you answer. "Why do
you ask'"
Questions provide Information. The
most obvious way to use questions is
to gather information. How effective
you are as a trainer depends on your
ability to get the right information at
the right time. You use questions to
find out exactly what problems your
training is expected to solve, to find
out how much trainees already know
about the subject at hand, and to
leam about their strengths and weak-
nesses. Eventually you discover just
how effective your training has been
in actual practice.
No one can hope to know every-
thing. But successful communicators
know how to tap into the most
accessible sources of information. As
humorist James Thurber said, "It is
better to know some of the ques-
tions than to know all of the
Questions get people to take on and
eolve their own problems. If you're
doing all the talking in a training ses-
sion, you're usually trying to con-
vince participants that you know
what's best for them. But somehow,
people never quite follow your sug-
gestions in the way you expect them
to. Thoughtful questions can lead
trainees to create their own solutions
to problems And people naturally
follow their own ideas better than
they follow other people's ideas.
Questions allow you to find out how
people think. There is alw-avs more
than one way to arrive at the same
conclusion. Personality, background,
previous training, and on-the-job
experience all influence the wax-
people think and respond to train-
ing. In school, we all took tests so
that teachers would know how much
we had learned. Teachers gave us
essay tests so that they could tell not
only how much we knew, but how
we derived our answers. Such tests
also gave teachers clues to our per-
sonalities and ways of thinking.
Asking trainees questions is like
creating your own oral essay ques-
tions. You can discover how individ-
ual participants process information,
how the group processes informa-
tion. and how trainees are likely to
use the information you've given
them once they return to their jobs.
Qetting past the Information
Why is getting the right information
from trainees so difficult' One prob-
lem is that people's responses to
your quesuons don't necessarily give
you the whole story. To obtain use-
ful information, you must thoroughly
understand four reasons why ordi-
nary questioning skills aren't enough
and why the ability to probe and
clarify is the greatest determiner of
success. The four barriers:
I People don t volunteer information.
I People talk in generalities.
• People make wrong assumptions.
» People perceive things differently.
To overcome these four commu-
nication barriers, a trainer needs to
develop the skills of a detective who
is tackling a baffling case. Good
trainers get answers to their ques-
tions. Great ones probe and clarify
each answer until they've solved the
Lawrence Sanders is the author of
many best-selling detective novels.
In his book. The Second Deadly Sin.
an ex-police chief says. "No one ever
volunteers any information.... If you
don't ask the right questions, you
find yourself stumbling around in left
Many trainers are stumbling
around in left field. To find your
footing and become successful in
asking questions, you need to learn
how to break through the four com-
munication barriers.
Barrier number one. The first bar-
rier—the fact that people don't vol-
unteer information—is a constant
problem in training programs.
Suppose you've been asked to do
a communications training program,
and you ask a senior manager.
"What is the major problem here?"
The manager might reply. 'My peo-
ple are not writing reports the way
they should." never volunteering that
¦my people" includes five different
levels of employees, none of whom
knows the manager is dissatisfied
with their reports. Those are crucial
details, but a manager probably isn't
going to volunteer them. It's up to
you to probe and clarify to get a full
understanding of a situation.
Barrier number two. Coaxing words
out of your program participants is
just the stan of the struggle for clear
communication. The second barrier
to getting the information you need
is the common tendency of people
to speak in generalities, although
they learn from specifics.
Even when people think in
specifics they are often too lazy,
afraid, or impatient to state their real
feelings. For example, trainees may
disagree with you on some point, for
precise reasons, but may be reluctant
to state them. Other times, trainees'
reasons for disagreeing with you
may be vague, such as feelings of
distrust caused by your tone of voice
or your level of eye contact.
Getting specifics is particularly
important when determining your
participants' expectations. If you are
teaching a skills program, you may
think those expectations are easy to
determine. For example, computer
trainees may say that they expect to
be able to learn a certain software
program well enough to use it on the
job. But do you really know what that
means? Do you know if they expect
to leam rudimentary procedures, or if
they need to produce complicated
charts and spread sheets?
SB Training 6- Development, January 1993

Instead of asking trainees what
they expect to pet out of the pro-
gram. ask them what specific skills
they expect to learn in order to fulfill
their job oblicauoas.
When you're training in such
broad areas as motivation or commu-
nication. you need to be even more
For example, say that managers
are dissatisfied with their employees'
reports and want you to set up a
communications training program.
For your program to be effective,
you need to find out the managers'
and trainees' specific expectations. If
you ask trainees about their expecta-
tions and receive such answers as.
"to improve my communications
skills." you need to probe and clar-
ify. A simple follow-up question,
such as. "What do you mean by
that'" will often do the trick.
Proper handling of this barrier can
also pay off when you're trying to
sell a training program to upper
management. In your role as a sales-
person. think about what to do with
general answers like. "I'll think about
it." What will the manager be think-
ing about? You don't know what
aspect of your proposed program he
or she will dwell on. Find out, and if
you need to. refocus the manager's
attention on the areas where you
want it. "That's great." you might
respond. "I'm glad you're going to
be thinking about this. What exactly
will you be thinking about?"
A standard objection such as,
"We're not ready to start a training
program yet." could mean. "We don't
like you." "We're considering two
other trainers." "We don't have the
money." or a dozen other concerns.
Unless you probe and clarify, you
have no idea what aspects to focus
on to convince an internal or exter-
nal client that those concerns won't
affect his or her satisfaction with
your program.
It's natural to enjoy hearing a
prospective client say. "I liked your
proposal." But this is one gift horse
you have to look in the mouth. Ask.
"What exactly did you like about it?"
You can then build on your own
strengths, as perceived by your
client, to sell your program.
Barrier number three. People make
wrong assumptions. For example.
early in my training career. I made
an overly pessimistic assumption that
cost me dearly.
I never contacted large associa-
tions and corporations because I
assumed that thev must already
have consultants—until a colleague
pointed out that my supposition was
I readjusted my thinking and in
no time doubled my list of clients. I
discovered that even the largest
organizations, including Mobil and
Merrill Lynch, were interested in my
You can't assume anything. When
a manager says. "I'll take it in to my
boss." most of us assume that is a
positive sign that the sale is progress-
ing. But a manager could be plan-
ning to tell his or her boss to hold
off on the training. Unless you probe
and clarify such statements, you'll
never know where you really stand.
Next time you hear, "I have to talk it
over with my boss." probe by asking.
"Do I understand you correctly? Do
you mean that if your boss likes the
proposal, then you'll be ready to
Barrier number fear. The final com-
munication obstacle is that people
perceive things differently. That's
because everyone's perceptions are
based on past experience and pres-
ent desires. So if I say. "Let's go out
to dinner." you probably envision a
scene that is different from the one I
Such differing perceptions can
play havoc with training. For
instance, a physician and director of
a surgical center in Kansas City spent
two hours training four administra-
tive assistants in how to field phone
inquiries. His instructions included
details about insurance forms and
scheduling for surgery, as well as
medical information about his spe-
cialty. At the end of the session, he
asked. "Got that'" The four assistants
A few weeks later, he decided to
test the efficiency of his staff by ask-
ing some friends to call his office
and pretend to be prospective
patients. The friends tape-recorded
the disastrous results.
One of the assistants had per-
ceived that the doctor thought they
were spending too much time on the
I Questions demand answers.
I Questions put you in controL
» Questions provide information.
I Questions get people to take
on and solve their own problems.
I Questions allow you to find
out how people think.
phone. In her hum* to get off the
phone, she neglected to ask for nec-
essary information. Another per-
ceived that the doctor was con-
cerned about medical information, so
she spent extra time on the phone,
putting people on hold to try to find
answers to their questions.
The doctor fired his four assis-
tants. and instructed his office man-
ager to "hire people with brains this
The doctor could have avoided
this waste of time, money, and
human potential by taking the time
to ask a series of smart questions
after his initial lecture. He could
have asked the assistants the follow-
ing questions:
I How would you describe in two
or three brief sentences what ser-
vices we offer?
• How would you advise a caller
who has no medical insurance1
I What information must you
always elicit from a caller?
I What will you say if a caller asks
you a question you can't answer?
Putting questions into practice
Now that you know why it is so dif-
ficult to get the information you
need, it's time to put the five powers
of questions to use in your training
practice—before, during, and after
your program.
The first thing a trainer does
before beginning any program is a
needs analysis. That means finding
out what the real problems are—not
just the ones you are being told
about. Consider the example of the
manager in a previous example who
said. "My people are not writing
reports the way they should." You
would need to know several things
before you could design an effective
training program for that manager.
What does the manager mean by
60 Tratmng & Development. January 1993

"not writing reports the way they
should"? Does the manager mean
there is a company standard that is
not being met? Does the manager
mean that he or she has a particular
preference—which may not be prac-
tical for on-the-job use. or with
which her employees disagree? Or
does she mean that her employees
do not have the skills and training
necessary to write the kinds of
reports her company needs?
You probably won't be able to
learn the answers to these questions
from this manager alone. You may-
need to talk to senior managers to
find out more about the company s
requirements. And you'll need to
speak with the people who are actu-
ally writing the reports to find out if
a lack of skill is causing the problem,
or if managers have unrealistic
expectations. Put on your detective
hat. Probe and clarify until you dis-
cover exactly where the problem is.
Asking smart questions before
beginning a program is valuable for
getting management commitment.
Do you know how your training will
affect the company's bottom line?
Can you estimate savings in terms of
money, time, or productivity? Do you
know the cost of not solving the
problem? The more specifically you
can answer these questions, the
greater your chances are of obtaining
full commitment to your program
from the upper echelons.
Plan your questions
Before you even begin to plan your
program, ask yourself what you want
to accomplish with it. To answer that
question, you must develop behav-
ioral objectives. In other words,
decide where you want to go before
you decide how you re going to get
In Preparing Instructional Objec-
tives. Roben F. Mager says that the
key question you must ask yourself
when writing behavioral objectives is.
"What must people do to demonstrate
mastery of the objective?"
The answer always begins with an
active verb, such as "identify."
"solve." "build." "draw." "list." -sort."
and "construct."
For instance, when I conduct a
program on speaking, my behavioral
objective is for participants to be
able to identify and correct the six
maior speaking faults. I don't want
trainees objectives to include words
such as know, understand, or appre-
ciate. How can you tell if trainees
"appreciate" anything? You must be
specific in your objectives, so that
you have a measurable standard for
evaluation. If my participants can
identify and correct their speaking
faults. I know—and my participants
and their supervisors know—that my
program has been successful.
One major mistake trainers make
is failing to plan the questions they
will ask in their programs. Know the
purpose behind every question you
ask. What exactly are you looking
for when you ask a particular ques-
tion? Do you want to know if your
information is being understood? Do
you want to know how participants
are going to use the information in
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Training & Development. January 1993 SI

their everyday work lives? Or do you
want to leam participants' emotional
responses to new matenaP
Choose your words carefully, and
listen to your pamcipant s responses
just as carefully. When I'm teaching
public speaking. I often ask partici-
pants to give sample presentations to
the class. Then I may ask other par-
ticipants. "How did you feel about
that presentation?"
Often a listener will answer. "Well.
I think he could have done it differ-
ently...." At that point. I usually inter-
rupt and say. "I didn t ask what you
thought about the presentation: I
want to know how it made you feel."
You present strong stimulation
every time you ask a question, so
you cannot afford to be haphazard in
your questioning process. The lan-
guage you use can make a great dif-
ference in the responses you get. For
instance, think about the differences
in the following three questions:
» What could you do to improve
your report-writing abilities?
I What would you do to improve
your report-writing abilities?
I What should you do to improve
your repon-writing abilities?
The first question will probably
get trainees to respond according to
the way things currently exist in their
day-to-day routine. The second
might show their willingness to look
for new solutions. The third question
might prompt trainees to try to sec-
ond-guess their managers' preferred
Are you planning to use visual
aids and other learning materials? If
so. you need to be sure that they are
appropriate and serve a particular
purpose. You might ask yourself
l Will this material tie in to my
overall training purpose?
I Does it enhance my behavioral
I Is it challenging, or is it boring?
I Does it provide new information?
I How can I get participants to inte-
grate this new information into the
rest of the program?
Trainers often relv on general
guides to help them ask questions,
after using learning materials such as
films and videos ."But such guides are
meant to apply to as many situations
as possible: you need to focus your
questions so that the material applies
to your trainees' needs.
Suppose you were using the same
video for a program on body lan-
guage. a program on public speak-
ing. and a program on sales. You
would have to tailor your questions
to the needs of the group—not sim-
ply follow the general questions in a
guide. It is a waste of time to look
for materials that do nothing more
than liven up your program. Select
activities for a specific purpose.
A question of style
Another important aspect of your
preparation is analyzing your own
questioning style. Do you know
when to use open-ended, general
questions? Do you know when
closed-ended questions would be
more appropriate?
The value of open-ended ques-
tions is drummed into every prospec-
tive trainer. Open-ended questions
are the best way to get participants to
open up. divulge information, and
reveal hidden resistance.
And so they are. But many train-
ers overlook the value of closed-
ended questions. Such questions get
you agreement and commitment, as
well as short, factual answers.
You can use both open- and
closed-ended questions to get infor-
mation and to help you move a
training process along.
Whatever style of question you
use. your main purpose is to meet
your trainees needs. You can't stop
every five minutes to ask. "Do you
understand what I've just said?" So
you must come up with other ways
of getting that information. The best
way to do that is to start from the
general and proceed to the specific.
For instance, in my communica-
tions programs I usually lead with a
listening exercise. I follow up with
the general question. "What did you
learn from that?" Then I ask a more
specific question: "Why is listening
so difficult?" Then I ask more specific
questions: "What are the responsibili-
ties of the speaker to the listener,
and of the listener to the speaker?"
and "Based on what we just shared,
how will you use this information
back on the job?" Finally I ask.
'What is the first improvement you
will make to increase your listening
Did the trainiitf wortc?
Evaluating whether the training
worked gets to the whole point of a
training program. You have not been
successful if trainees can't take the
information they learned in your pro-
gram and put it to effective use on
the job. And there is no way to find
out how successful you've been
unless you or the company conducts
a post-training evaluation.
Many trainers receive post-training
evaluations on their own perfor-
mance. These evaluations ask partici-
pants if they thought the trainer was
effective, if they found the material
useful, and if they have any com-
ments. Their answers usually provide
useful feedback for trainers regarding
their ability to conduct training ses-
sions. but they don t reflect long-
term results.
Here are the questions you really
need to have answered:
» How has the training benefited
the organization?
I What specific changes did people
make as a result of the training7
I Did you accomplish your objec-
tives and those of participants and
It is not always necessary to con-
duct your own evaluation. In fact,
that may be impossible for you to do
impartially. But you do want to
encourage managers to look at
behavior changes on the job.
When you end your training ses-
sion. set a specific time frame—such
as a week, a month, or six months—
for an evaluation. If you've been
hired from the outside, have man-
agers send you the results. Without
this knowledge, you have no way of
evaluating your own performance
and making improvements.
Your ability to ask the right ques-
tions in the right way can mean the
difference between a mediocre train-
ing program and a truly exciting,
effective learning expenence. It's one
of the best tools you'll ever use as a
trainer. The an of asking smart ques-
tions takes concentration and prac-
tice but reaps big rewards.
What more could you ask? ¦
Dorothy Loodo is the founder and
president of Organizational Tech-
nologies, 800 West End Avenue. Suiti
10A, Neu: York. AT 10025.
62 Trninir« A notvlnnmertt fnntmrv 70Q3

III. P2 Planning and Facility

'1/ '•£(*3 ' i >
» Track
• Measure


a clear concept of the process,
all the relevant pieces of the process,
all the input points and output points of the process, and
a common means of discussing the process with others.

A process How diagram is a graphic line sketch that includes symbols and
arrows that represent all of the steps of the process necessary for convert-
ing the incoming raw materials, energy, and labor into the finished prod-
ucts and residual by-products.
The simplest process flow diagram can be represented as:

A simple schematic of a TUR process flow diagram may look more
like the following:

Product Line*
1	Misc. supplies (paper^otvents)
2	Raw Materials/Product tram previous step
3	Liquid waste
4	Solid waste
5	Air emissions
6	Junk product
7	Good product

Valenti's Office Supply
The painting production unit for Valenti's Office Furniture Company uses
a spray painting operation to paint metal desks and other office furniture.
The metal furniture surface coating process is a multi-step operation
consisting of surface cleaning, coatings application, and curing. The
production outlined below uses solvent based paints applied by spray
guns. The spray coating production unit consists of the following
1)	Sodium hydroxide wash • to remove grease, oil, and dirt
2)	Phosphate treatment - to improve surface adhesion
3)	Hot water rinse
4)	Dryoff oven
5)	Spray paint application
6)	Flashoff
7)	Drying Oven
The spray painting application uses two different types of paint depending
on the product. Desks are painted with "SS-4004", Bookshelves are
painted with "Crystal Clear Spray Coating". The chemical constituents of
concern for these paints can be found on the attached MSDSs for these
paints. Assume the percentages of chemicals on the MSDSs are percent
by weight. The specific Gravity listings on the MSDSs are given in
For the purpose of this case study, the percentage of the total VOC
emissions given off at each emissions point are assumed to be as follows:
Spray coating application (40%), Flashoff (30%), and the Drying oven

(518) 385-2577

Dace January 1977
Reviewed: December 1979
Aerosol spray cans with aerylace resin solution under pressure.
Krylon Dept.
Div. of Borden Chemical, Borden Inc.
Ford and Washington Streets
Norristown, PA 19404	 Telephone: (215) 278-7400
Toluene (MSDS #317)
Methylene chloride (MSDS 0310)
Acrylic ester resin
Proprietary propellent 	
*ACGIH (1979) TLV (Methylene chloride is an
Intended Changes List)
~~Manufacturer's estiaated TLV
8-hr TUA 100 ppm(Skif)*
8-hr TUA 100 ppa*
Ho TLV Established
8-hr TWA 1000 ppa4
Aerosol container is under internal pressure of about 60 psi 6 70°F
Percent volatile (by volume Z) —		ca 93
Solubility in water (of contents) ---¦¦¦ ¦	¦ ¦¦	Slight
Specific gravity (of contents) (I^O"!)	¦ 1 ¦ ¦— <1
¦\ Point and Method
Mauulanmer	.
approximated >100°F
AutoIgnition Temp.
Flaaaabilitv Limits In Air
t by voliane (Toluene)
Release spray button if spray is burning. If discharged content is burning, treat
as Class B fire.
Extinguishing media - carbon dioxide, foam or dry chemical. (Dry chemical extin-
guishing media preferred by manufacturerJ The hazard of aerosol can explosion is
present in any fire involving this product. If this material is sprayed near an
open flame, spray may ignite and burn like a blow torch.
Firefighters should us* self-contained breathing apparatus when this material is prefr
This material, because it is normally enclosed in an. aerosol can, would not normally
come into contact with reactant chemicals. However, since it is a flammable
liquid, avoid contact with heat, sparks or open flames. Avoid contact. In the
liquid form, with strong oxidizing agents.
© MMCa

No. 105?
tlv (See Section II)
Vapor inhalation of low concentrations may cause lightheaded feeling, dizziness, head-
ache or drowsiness. Inhalation of high concentrations will cause a feeling of fatigue,
incoordination and irritation of the respiratory tract. Skin contact will cause de-
fatting and subsequent dermatitis. Some skin absorption of solvent may occur. Eye
contact with the spray may be irritating. Direct application of the spray into the
eye is extremely hazardous and must be avoided. Ingestion is unlikely.
Inhalation: Remove victim to fresh air; get medical assistance if victim is drowsy
or overcome or if irritation persists. (Methylene chloride metabolism
in the body will increase carboxyhemoglobin content of the blood.)
Ingestion: Unlikely occurrence. If it happens, get medical assistance promptly.
Eve Contact: Irrigate with water for 15 minutes; get medical attention.
Skin Contact; Wash area with soap and water; replace skin oils with approved creams.
Spills from aerosol cans are unlikely and also generally of small volume. Spill pre-
vention is thus not considered a major problem. In case of spill, remove sources
of ignition. Soak up with absorbent material. Ventilate area. The material is
combustible but not otherwise hazardous when the solvents have evaporated and can be
disposed of by incineration.
Do not incinerate aerosol cans!
Area for use of aerosol spray should be fireproof and well-ventilated. Exhaust ventila-
tion should be appropriate to use of spray, keeping solvent vapors below OSHA
specified threshold limit values.
Eye protection should be used if it is possible to spray into eyes.
Protective gloves should be worn if repeated or prolonged contact with liquid KRYLON
spray is probable.
Eye wash station should be available if eye involvement is probable.
Do not score aerosol cans above 120°F, as concents are under pressure. Do not allow to
stand in strong sunlight or near other heat sources. Do not incinerate as the
container will burse violently. Do not puncture aerosol containers (jet effect can
make a rocket out of the can and excessive inhalation of vapors is probable). With
proper techniques and precaution, empty aerosol cans may be punctured by an experienced
person for disposal as inert waste.
DATA SOURCE(S) CODE: 1 (MSDS #310, 0317)
Chemical Safety Coordinator
GE Electronics Laboratory
Syracuse, NY 12301

Kin 1008
DATE August 1983
MATERIAL NAME: SS-4004 (Tradename)
DESCRIPTION: Primer solution for improving bonding of RTV Silicone Rubber to
various surfaces. (See CE Material A15F11A1)
MANUFACTURER: Ceneral Electric Company
Silicone Products Division
Waterford, NY 12188
Telephone (518) 237-3330
Acetone (MSDS #300)
Isopropyl alcohol (MSDS #324)
Toluene (MSDS #317)
n-Bucanol (MSDS #337)
Ethyl silicate (MSDS #646)
*ACGIH (1983) TLV.
(skin) notation indicates material can penetrate the
slMn and ronriMhitr® rn Mirnl avnnitira
8-hr TWA*
750 ppm
400 ppm
100 ppm (skin)
50 ppm (C) (skin
10 ppm
Boiling poinc (initial), — 130 F (approx) Specific gravity (23/4 C) ¦	0.83
Vapor pressure, 20C, on Hg — 100	Volatiles, Z 	 60 (approx)
Vapor density (Air ¦ 1) 	 2-3	Evaporation rate (acetone » 1) 	 1.0
Water solubility — partially soluble
(over half of solvent
is vater soluble)
Appearance & odor: A bright pink liquid with a pungent odor resulting froa its mixed
solvent concent.
Floth Pomt and Mtihod
AmUiqwiioh Ttwp.
Elammobilrty Iwmi n Atf

10 F (-12 C) PMCC
(750 F)* (Est.
) Volume Z* (Est.)
maybe ineffective in extinguishing fire. Use blanketing effect to soother fire.
Explosive hazard from sparks or flame: can react vigorously with oxidizing materials.
Vapors are heavier than air and may flow along surfaces to an ignition source and
flash back.
Firefighters should use self-contained breathing apparatus whan large amounts of this
primer are involved in a fire situation.
*Estimated values based on solvent content. Properties can vary as evaporation occurs.
Material is stable when stored under cool conditions in a sealed container. The ethyl
silicate content will react slowly with atmospheric moisture when exposed to the air.
Hazardous polymerization will not occur.
Since it contains volatile, flammable material, keep strong oxidizing agents sway and
keep away from sources of heat, sparks and flames.
Thermal-oxidatlve degradation products can include carbon monoxide (CO), carbon dioxide
(CO.), and silicon dioxide (SiO.) smoke.
The solvents of this material can cause crazing of certain plasties (polystyrene,
polycarbonate, for example).

TLV See Section II
Excessive inhalation of vapors or misc from this solucion can cause irritation to
respiratory passages, headache, dizziness, and nausea. Short contact with liquid
may cause a defatcing, drying and irritating effect on the skin; while prolonged or
repeated skin contact may result in dermatitis. Solvent absorption through the skin
can also occur. Can cause eye irritation.
Eye Contact: Flush thoroughly with running water for 15 min. including under eyelids.
Skin Contact: Remove contaminated clothing. Wash area with soap and water.
Inhalation: Remove to fresh air. Restore and/or support breathing as required.
Ingestion: Contact physician. Do not induce vomiting, unless large quantity has
been ingested and medical help is not available. Cive 2-3 glasses of milk or water to
Seek medical help for treatment, observation and support after first aid.
When spills occur, eliminate all sources of sparks and flames; provide adequate venti-
lation (explosion-proof) to remove solvent vapors.
Absorb spills using inert absorbant solid. Place waste in metal disposal container in
a manner that avoids hazards from the volatile solvent content. Use non-sparking
DISPOSAL: No special procedures or disposal methods are recommended by Che manufac-
Controlled incineration should be considered.
Follow federal, state and local regulations.
EPA (RCRA) HW No. is D001 (ienitable waste): &OCFR 261.
Treat as a highly flammable
Provide adequate exhaust ventilation (explosion-proof equipment) to meet TLV require-
ments. No respiratory protection is required unless ventilation is not adequate.
Use an organic chemical cartridge respirator or supplied air mask in emergency
situation. (Other approved respirators can be used.)
Use impervious gloves to avoid repeated or prolonged skin contact with liquid. Use
chemical safety goggles where splashing is possible. Clothing soiled with liquid
should be removed and laundered before reuse.
An eyewash station and washing facilities should be available to area of use and
handling, and a safety shower should be considered when large amounts are used.
Store sealed containers in a cool (<80 F), dry, well-ventilated, flasmable solvents
storage area (OSHA Class IB flammable liquid). Keep containers tightly closed
when not in use. Ground and bond metal containers and equipment for transfers to
avoid static sparks. Use nonsparking tools. Electrical services must meet code.
Avoid breathing vapors. Prevent eye or skin contact with liquid. No smoking in areas
of use or storage.
DOT Classification: FLAMMABLE LIQUID n.o.s.	No- UN1993 Label: FLAMMABLE LIQUID

Draw a process flow diagram for the process described in the above
Given the process flow diagram for Valenti's office supply company,
show a materials flow diagram for all the chemicals used. Show inputs
and outputs.
List the occupational exposure limits for toluene and methylene chloride.
List the vapor pressure for SS-4004. What does the vapor pressure tell
you about a material?

Materials In = Materials Out + Materials Accumulated
A = B + C + D + E

Figure 7di Summary of Resources for Materials Accounting
Materials Procurement
•	raw material purchase records
•	transfer record
•	vendor invoices
•	receiving dock records
Materials as Inventory
•	end-of-year inventory records
•	storage records
Materials Use
•	operations logs
•	samples, analysis, and flow measurements
•	batch make-up records
•	product specifications
•	production line job sheets
Materials as Product
•	product shipment records
•	loading dock records
•	product specifications
•	invoices to customers
Materials as by-products
•	waste transport manifests
•	waste transport invoices
•	invoices to scrap buyers and recyders
•	sewer CPOTW) discharge records
•	Toxics Release Inventory Form R
•	DEP air source registration records
Materials Reuse
•	recycling records
•	reclaim records


Exercises used during the course
can be found in Section V.C. of this notebook.


If someone offers to give you $1,000 today or $1,100
one year from now, which would you take?
How much is $1100 worth today? Depends on the
discount rate.
PV = 1100 = 982
TVRl 1994 Module 10
100 in 1 year @ 12%

•	ANNUITY: A stream of equal payments
- $100 a year for ten years
•	PRESENT VALUE = the sum of the PV of each
$100 payment
•	CALCULATION: Multiply the annual payment by the
appropriate factor from the Present
Value of an Annuity Discount Table
TVRf ">94 Module 10

-	It NPV > 0: the project should toe accepted
-	If NPV < 0: the project should be rejected
-	If NPV = 0: the project generates exactly the return that is required
•	If NPV = 0: The savings generated by the project
is sufficient to:
(1)	pay off the Initial outlay of funds
(2)	pay off interest payments to creditors who fent money
(3)	provide the required return to shareholders
•	if NPV > 0: The savings generated by the project
is sufficient to accomplish 1, 2 & 3 plus:
-	increase economic value of the business
TVRI 1994 Module 10

•	What Is the IRR of a project that generates annual
net savings of $1000 for ten years on a $6000
•	STEP 1: Calculate NPV at an estimated discount rate
•	STEP 2: Using that NPV as base select a second
discount rate to narrow in on range of possible rates.
TUR^994 Module 10

-	If IRR > Hurdle Rate accept the project
-	If IRR < Hurdle Rate reject the project
•	Would you accept the project in the prior example
if your firm's hurdle rate were 12%?
*	IRR and NPV will give the same answer except for
projects with negative cash flow in some years.
TUR1 1994 Module 10

Toxics Use Reduction Planner Course
. procedures for operations
. maintenance records
. product specifications
. formulation
. design criteria
. water/ energy bills
. process flow diagram
. machine scheduling
. chemical use log
. yields
. vendor support
. waste haulers
. waste facilities
. manifests or bi-annual reports
. air permits
. form S and Form R
. water permits
. waste storage records
. sampling data
. waste profile sheets
. spill reports

. purchasing records
. cost of disposal
. insurance
. process for capital budgeting
. cost standardized against inputs
. invoices (raw material and wastes)
. sales records
. shipping logs
. inventory
. worker comp. records
. Business plan
. how the firm competes
. market
. capital plan
. history of company
NOTE: The above list should NOT be considered as all inclusive!!!

The Northeast Waste Management Officials' Association
The Massachusetts Office of Technical Assistance

•	310 CMR 50.45: COST OF TOXICS
'For each production unit, toxics users shall determine the total costs per
year of the covered toxic and the cost of the covered toxic per unit of
-	INFORMATION: Show how much the use of toxics actually costs a
-	PROJECT ASSESSMENT: Establish a framework for collecting cost
information to perform the financial analysis component of capital
budgeting to determine the potential economic value of toxic use
reduction options.
TVRI1994 - Module 9	No. 1
•	CAPITAL BUDGETING: Process of evaluating
investment options for long-term projects
-	Plant expansion
-	Equipment
-	Equity
» Stock
» Retained Earnings (internally generated funds)
-	Debt
» Bonds
» Bank borrowing
•	OPERATING BUDGET: Budget for short term
(quarter or year) operating expenditures
TURl 1994 - Module 9	No. 2
Page 1

Send RFF'ito Vcadon
Anal^i RFP'i
for Technical Fosibittly
CbooM Eqripafat battd
ob i mwrmn wm
| Lbt Qaltefte law
D«i»lu|i Co«np«nttJ*»
Awa impact*
Prepare J ustiQca boa Package
(with npporting documentation!
TURt 1994. Module 9
No. 3
PURPOSE: To determine whether an investment
adds economic value to a company
METHOD: Calculate cash flows over the life of a
project and apply measure(s) of profitability
p"Coll act Cost Information
» Current proems
[ » Proposed pre
• Determine relevant incremental cash flows
-	Apply measures of profitability
> Payback, Accounting Rate of Return, Net Present Value,
Internal Rate of Return
-	Interpret Results
TURJ1994-Module 9
No. 4
Page 2

•	STEP 1: Draft a Process Row Diagram
•	STEP 2: Identify costs
-	Labor
-	Materials
-	Equipment
-	Other
TUR11994-Module9	No. S
Material handling
Raw materials
Process water
Cleaning water
Office supplies
Training materials
Safety materials
Material handling
Waste treatment
Water treatment
Air Polutn Control
Waste disposal
Regulatory fees
Lab fees
TURI1994-Module 9
No. 6
Page 3

at Btow-o? or rooocimn ntocn*
I _____ I
TtlRI 1994. Module 9
NO. 7
TURl 1994- Module 9
No. 8
Page 4

Hudson Ice Cream Business Process Flow
Revenues ^
- Cost of Goods Sold
= Gross Profit
a Operating Profit
o Net Profit
TURJ1994-Module 9
"Flaw Materials
Production Labor
Monitoring 4 Reporting
Waste Disposal
UtfiUes & Depredation
Labeling & Manifesting
RigM-To-Know Training
Penrttsi Fees
Fines A Penalties
-Equipment Cleaning
PURPOSE: To provide information to management,
investors, regulators, and other external entities on
the financial performance and health of a business.
External Use.
-	Income Statement: Record of financial performance (income) over
a period of time (e.g., quarter or year)
-	Balance Sheet Snapshot of financial status (assets and liabilities)
at one point in time (e.g., December 31,1993)
-	Statement of Cash Flows: Record of actual cash flaws awar a
period of time.
TVRI1994 - Modult 9
No. 10
Page 5

PURPOSE: To provide management with information
to make decisions. Internal use.
Information can be:
-	Financial: costs - COST ACCOUNTING
-	Non-financial: cycle time, rework, customer returns, quality
performance etc. TQM metrics
TURI1994-Module 9	No. 11
PROBLEM: How do companies organize and
manage cost information?
OBJECTIVE: Balancing the need to have information
in a useful form with the cost of collecting and
managing that information.
-	Con vent anal
-	Activity-Based
-Full Cost
TURI1994 • Module 9	No.12
Page 6

TURJ1994 - Module 9
No. 13
Cost Pools
Raw Materials
Production I
Waste Disposal*
Monitoring & Reporting]
Labeling A Manifesting L
Right-To-Know Tralnlng^V^
Permits A Foes I	"V
Fines & Penaltisu
Equipment Cleaning
Utillttos & Depraciatfotj
Allocation based on
.different cost drivers
•each cost pool
TURI1994-Module 9
No. 14
Page 7

All Coats an attributed
to processes on the teste
of direct cost driven
Raw Materials
Production Labotv^
Waste Disposal
Monitoring & Repo
Labeling & Manifesting
Right-To-Know Train|
Permits & F<
Fines & Penalties
Equipment Cleaning
Utilities & Depreciation
TVRI1994-Module 9
Ma 15
TURI1994-Module 9
1	00
No. 16
Page 8

•	EXPENSE: Cost that is charged against revenue to
calculate income.
•	EXPENDITURE: Outflow of cash
•	CAPITAL ASSET: An asset with a useful life of
greater than one year.
- CAPITALIZE: Accounting treatment of a capital asset
•	DEPRECIATION: Non-cash expense that records the
using up of a capital asset over its economic lifetime.
•	OPERATING COSTS: Expenses for items that are
consumed in less than one year.
TURJ1994 . Module 9	No. 17
•	DEFINITION: Non-cash expense that records the
using-up of a capital asset over its useful life.
•	Various methods:
-	Straight-line: equal amounts each year
-	Accelerated: more in the earty years
-	Usage-based: according to actual usage of equipment
•	Straight-line Formula:
Initial Coet of Equipment. Salvage Valua
Expected Useful Lifetime
• Example:
* P s $3000 per year
TVR1 1994 - Module 9	No. 18
Page 9

DEPRECIATION - Non-Cash Expense I
•	EXPENDITURE: Outflow of cash
•	EXPENSE: Cost recorded on an income statement

Raw materials

Material handling





Process water

Material handling

Cleaning water


Office supplies

Waste treatment

Training materials

Water treatment

Safety materials

Air Polutn Control



Waste disposal
Regulatory fees
Lab fees
TURI1994 . Moduli 9
No. 20
Page 10

ACCOUNTING SYSTEM probably won't provide
much information directly. Many 'indirect costs' will
be hidden in 'OVERHEAD' and not readily available.
• RAW DATA: It will be necessary to search out the
'hidden' cost information. Sources of cost
information include:
-	Interviews with plant operational and environmental personnel
-	Purchasing Department records
-	Payroll Department records
-	Accounting records: receipts, invoices etc.
-	Vendors
TUR11994. Module 9	No. 21

SpUI/loofc teddoat
Number of laodeett
ril|i—f tnttrvww
Uniliwr i«m rnw
Nember of Shipmee
Ubor Horn • S/«Nk
Binli—i Imwim
MwiMnln* Inrti
Ughftt-KaowTrains! NnhtfoflaiMi UtarHosn Ifngliwi Ibwumk
(in hou—» S/waok 			

Hambtref Dremi
Ubor Hoon or/ tAwk
Si|tanr Ibcbvmw
AaoatiCI or
Ubor Noon mt S/woofc
EtXS/rhwnkal or/pi)
Bogio—f Imuiim/
iMllilW II Rnwnwt
Mnaamw h l«^ir
(Old Gqtapno
Nambor of Macbno
Ubor Hoars or/ S/woak
•pert pem/oqmpmoni
Ubor lie oft or/ l/ml
ipnt pom/oquiimwt
MlcfetM MlllftWWf
Vndor / Bii|Hni
Sotvoat DtspoMl
l/tfmor /lb
Aementies l«ee»d»
r«jui«Miim bcorti
Nambor of loporabl*
t TtHminl fnffj
TUIA Mporaas Fern
rmi—mn lacorti
Tmimag Sepptw
Nember ef Employee
Tnmd or/ Nvsbarof
EagiaMiiai heorts
Aonsttt IauiiIi
Pi wau»i Equipunut
Nsmbif cf Employio
So ft uioiactad
BflllMrtfll Mcsflti
TURI1994 ¦ Module 9	No. 22
Page 11

• QUESTION: How much does it cost to manifest a
pound of TCE per week?
ANSWER; "According to our records, we spent about
250 engineering hours last year manifesting seven
solvent wastes".
TURl 1994 - Module 9	No. 23
RIGHT PEOPLE: Who has the information? Who
performed the work?
RIGHT QUESTIONS: Fit questions to information
needs and to what information sources have access.
COMMUNICATION: Establish communication
channels for information development process.
SYNTHESIS: Combine data from different sources to
produce information.
TVRl 1994 . Module 9	No. 24
Page 12

310 CMR 50.45.(3F) & (4): Impact of Intangible Items
Estimated Qualitatively Not Quantitatively.
•	Potential Liability
-	Disposal
-	Transporation
-	Real Property Damage
-	Employee Health and Safety
•	Community Good Will
•	Market Share - Lost Sales
•	Corporate Image
•	Employee Relations
TURI1994-Module 9	No. 25
1.	Identify potential sources of liability on PFD.
2.	Arrange into risk groups.
3.	List various exposure events for each group.
4.	Assign probabilities for each event.
5.	Estimate severity of event.
6.	Rate degree of risk to overall liability
TURI 1994'Module9	No. 26
Page 13

lToccss UManscup
Hazardous Matfrtah
Heavy Mctab
Process Water
Hazardous Waste
Municipal Waste
On Site Stance
Process Use
Internal Recyi
External Recycling
TVRJ1994 - Moduli 9
Land Disposal
Fad Burn
Ma 27
Page 14

PURPOSE: Evaluate the economic impacts of a
Toxics Use Reduction Option
Part of the Capital Budgeting Process
TURI 1994 Module 10
No. 1
I Draft Project Pr—itin I
t 1
| SmdRFP't to Vendor* I
Anotyn Pmpwli
for Tfduial Ftslbttlly
CbooM Equipment bacd
oa TcdmicaJ Merits
TURI 1994 Module 10
Apply Mteiumof
I Interpret (otto
Evaluate Performance
| LUOaliUbtlma
Prepare Aeeenment Map |
(wttfa supporting documentation!
if approved * if approved
No. 2
Page 1

PURPOSE: To determine whether an investment
adds economic value to a company
METHOD: Calculate cash flows over the life of a
project and apply measure(s) of profitability
p"Collect Cost Information
» Current process
| » Proposed process
-	Determine relevant incremental cash flows
-	Apply measures of profitability
» Payback, Accounting Rate of Return, Net Present Value,
Internal Rate of Return
- Interpret Results
TUR11994 Module 10	No. 3
STEP 1- Cost Collection
Collect cost Information
•	Current process
-	Operating Costs
•	Proposed project option
-	Capital costs:
» Purchase
» Installation
- Start-up
-	Projected Operating Costs (Savings)
TURJ 1994 Module 10	No. 4
Page 2

STEP 2 - Incremental Cash Flows
Determine Relevant Incremental Cash Rows
•	Relevant: Substantial enough to have an impact
•	Incremental: Difference between current costs and
projected costs.
•	Cash flows: Stream of cash costs and savings over
the economic life of the project.
TURI 1994 Module 10	No. 5
• Initial investment
• Avoided treatment and
• O&Mfornew
disposal of wastes
• Maintenance savings
• Raw materials for new
on old equipment
• Avoided cost and
• New fees and
handling of toxics
• Reduced insurance &


• Depreciation tax shield

on new equipment
TURI 1994 Module 10	No. 6
Page 3

*	*	11
Cash Outflows $9000
Equipment S 8000
Installation $ 1000
Net Cash Inflows $ 4000
Year 1 	
Year 2 	
Year 3 	
TVRI 1994 Module 10
No. 7
STEP 3 - Measures of Profitability
•	Payback
•	Accounting Rate of Return (ROR)
•	Net Present Value (NPV)
•	Internal Rate of Return (IRR)
TURI 1994 Module 10
No. 8
Page 4

Purchase of hard-piped solvent recovery system for
a metal finsihing plant
- Equipment cost: $8000
•	SAVINGS: The equipment will enable $6000 in
savings in each of the next three years
- Before Tax Discount Rate = 14%
TVRJ 1994 Module 10	No. 9
-	Installation
-	Annual Costs
Annual Savings
Annual Costs
$ 6000
Annual Incremental Cash Row $ 4000
TURI 1994 Moduli 10
No. 10
Page 5

•	Measure: Time Required for Cash Flows to
Equal Initial Investment
•	Formula: Initial Investment ($)
Payback (years)
Annual Savings ($/Year)
•	Example: Initial Investment = $9,000
$8000 (Purchase Price) + $1000 (Installation)
Annual Savings = $4,000
•	Payback: = $9,000
——: = 2-25 years
TURl 1994 Module 10	No. 11
•	Simple & Easy.
•	Does not consider the time value of money
•	Does not measure the scale of gain of project
•	Acceptable only for first-cut analysis or for very
small projects
TURI 1994 Modal* 10	No. 12
Page 6

Measure: Annual Percent Return on Investment
Formula: Annual Savings ($/Year) w	#
Measures the value of money at different points in time
as determined by an opportunity discount rate
The opportunity discount rate is the rate of interest or
return that a business or person can earn on the best
alternative use of the money at the same level of risk.
The opportunity discount rate is also known as:
•	HURDLE RATE: Minimum rate of return that a project
must earn in order to be undertaken by a business
TURI 1994 Module 19	No. 15
The DISCOUNT RATE for a given firm is usually a
function of what that business must pay to acquire
capital (money) and what rate of return it must earn on
the investment to satisfy management and
DISCOUNT RATES are assumed to be after-tax
discount rates unless otherwise stated.
TURI 1994 Module 10	So. 16
Page 8

•	If someone offers to give you $1,000 today or $1,100
one year from now, which would you take?
•	If you invest $1,000 at 10% interest today, how much
will you have in one year?
- $1,000 + (1,000 X.10) =$1,100
Therefore, take the $1,100 in one year unless you can
earn better than 10%
TURJ 1994 Module 10	No. 17
$1,000 given to you today is not the same as
$1,000 given to you in 10 years
If I have $1,000 today, I can invest it in high yield,
no load mutual funds at 12%
Therefore my discount rate is 12%
TURI1994 Moduli 10	No. 18
Page 9

ff someone offers to give you $ 1,000 today or $ 3,000
ten years from now, which would you take?
Future value X PVP = Present Value
$3,000	X .3855 s $1,156
Therefore take the $ 3,000 in ten years unless you can
earn better than 10%.
*PVF = Present Value Factor from Table
TURI1994 Module 10	No. 19
Which would you take, if your discount rate was 5%?
•	$1000 today
•	$120 a year for 10 years
•	$1600 in 10 years
TURI 1994 Module 10	So. 20
Page 10

•	$120 a year for 10 ten years
-	120 x 7.7217 s $926
•	$1600 in 10 years
-	1600 X .6139 = $982
ANSWER: You would take the $1000 today
rum 1994 Module 10	No. 21
MEASURE: Value that an investment adds to a
business at a given discount rate.
Net Present Value (NPV) Spreadsheet:
Year Cash Flow Discount Factor Present Value
0	($ 9000)	1.000	($9000)
1	$ 4000	0.877	$ 3508
2	$ 4000	0.769	$ 3076
3	$ 4000	0.67S	$2700
Net Present Value of Cash Flows =	$ 284
TURI 1994 Module 10	So. 22
Page 11

•	Measure: Value that an equal annual return on
investment adds to a business at a given discount rate
•	Formula:
(Annua! Savings x PVFA) - Initial Investment = NPV
» PVFA s Present value factor of annuity
•	Example: Initial Investment = $9,000
Annual Savings = $4,000
PFVA of 14% for 3 years = 2.322
•	NPV: = ($4,000 x 2.322) - $9,000 =+288
TVRI 1994 Module 19	No. 23
•	Accurate; Considers time value of money
•	Measures risk-adjusted value added to business
•	More resource and information intensive
•	Requires estimation of cash flows over life of
project and calculation of discount rate.
•	Major project options assessment and final
analysis of all projects
TVRI 1994 Module 10	No. 24
Page 12

Discount Rate at which the Net Present
Value is equal to Zero
Try different discount rates until you
narrow the NPV as close to zero as
possible or/ Use a computer or business
PiMunt Rate	PVFA	IffiV
13%	1361	$ 444
18%	2.174	($ 304)
16%	1246	($ 16)
15%	1283	$ 132
No. 25
•	Accurate; Considers time value of money
•	Provides comparison to firm's hurdle rate.
•	More calculation intensive
•	Requires estimation of cash flows over life of
•	To prioritize or screen options and as further
check on other methods
TURI 1994 Module 10	No. 26
•	Measure:
•	Method:
•	Example:
TURJ 1994 Module 10
Page 13

•	Practiced by engineers and plant personnel
•	Simpler calculation
•	Fewer steps
•	Preached by academia and practiced by financial staff
•	Most accurate method
-	Reflects 'real world' conditions
-	Takes advantage of tax shields
-	Eliminates bias in favor of large capital projects with incremental
TUR1 1994 Module 10	No. 27
*	DISCOUNT RATES can be adjusted for use on
before-tax cash flows to improve the accuracy of
that method of analysis.
•	Adjustment:
Before Tax Discount Rate e AT PfeCTHilt RfltC	s 14%
(1 • Tax Rate) 1 . A
After Tax Discount Rate = BT Discount Rate (1-Tax Rate)
14 x A e 8.4
TURI 1994 Module 10	No. 28
Page 14

-	$9000 Capital costs - $4000 annual savings - 3 year life
-	14% Before Tax Discount Rate=8.4% Discount Rate
Incremental Cash Row	$4000
-	Depredation Expense 3000
= Taxable Income 1000
IncomeTax ® 40%	 400
Incremental Cash Flow	$4000
-IncomeTax	40Q
= After tax cash flow	3600
Present Value of Annuity (x2.55 [8.4%]) 9180
-	Capital Costs	9000
= After Tax NPV 180
TURJ 1994 Module id	No. 29
•	OPERATING COSTS (SAVINGS): Taxes offset the
effects of incremental operating costs and savings.
-	Calculation: Cash flow x (1-tax rate) = aftertax cash flow
•	DEPRECIATION TAX SHELD: Because depreciation
is a non-cash expense that reduces taxable income,
the tax that isn't paid is a savings.
-	Calculation: Depredation amount X tax rate = cash flow savings
•	NEW EQUIPMENT: The cost of new equipment that
is 'capitalized' is not recorded as an expense and thus
has the same pre-tax and after-tax value.
TURl 1994 Module 10	No. 30
Page 15

Because depreciation is a non-cash expense that
reduces taxable income, the tax that isn't paid. NOT
to the business.
Depreciation amount x tax rate = cash flow savings
$3000 x 40% s $1200 cash flow savings
TURJ 1994 Module 10	No. 31
•	Incremental cash flow savings
-	ICF5 x (1 - lax rata) x discount factor
-	4000 x .6 x 2.55 b
•	Depreciation tax shield
-	Depreciation x tax rata x discount factor
-	3000 X .4 X £55 » 2BSB
•	Capital Expenditures
-	Capital x discount factor
-	9000 X 1 a 8000
6120 + 3060 - 9000 = 180
TURI1994 Module 10
No. 32
Page 16

Other issues can add additional complexity but
increased accuracy to the analysis.
•	FINANCING TAX SHIELD: Depending upon how a
project is financed, it may be possible to count further
savings from the reduced taxes resulting from interest
different economic lifetimes cannot be considered on
an equal basis. Seek assistance from financial staff if
this situation arises.
TURJ 1994 Module 10	No. 33
TURJ 1994 Module 10	So. 34
Page 17


Identify Options
Assess Effectiveness and Impact
of Options
Compare Options to Each Other
and Existing Conditions

Screening: Narrow down set of options
Check feasibility based on
social, technical and economic impacts
Reevaluate TUR effectiveness of each
Compare and prioritize options

Use common sense for the obvious
Construct facility specific criteria:
Main benefits
TUR potential
Condition of existing equipment
Fit with company goals
Chance of success

Environmental effects
Public health
Worker health and safety
Management acceptance
Employee acceptance
Public image
Community good will

Effect on product quality

Direct costs or savings
Hidden costs or savings
New revenue sources

Informal approach
Formal comparison: Matrix Method
Establish set of criteria
Weight criterion
Score criterion
Multiply weight x score
Add total weighted scores for each
option and compare

EXERCISE: Hudson Ice Cream Company (A)
Frank Buchanan, manufacturing vice-president for the Hudson Ice Cream Company,
was pleased when he reviewed the final earnings statement for 1992. Despite the economic
slowdown in the Northeast, Hudson had managed to increase sales revenues and maintain
profitability. Although prices had remained stagnant over the past several yean, product
volume had increased an average fifteen percent annually, forcing Hudson to add a second
shift three days a week.
Founded in 1973, Hudson Ice Cream manufactured a full line of dairy products,
including yogurt, frozen yogurt and cottage cheese. Buchanancredhed the strong growth in
revenues to the new line of custom gourmet ice creams products, which were beginning to
gain wide-spread recognition among the ice cream elite in Massachusetts. Additionally, he
believed that the finely-tuned manufacturing process greatly contributed to the success of the
business. All of Hudson's ice cream manufacturing operations are centered in its Compton
facility. Here, the ice cream ingredients - cream, milk, sugar, milk powder, whey powder,
nuts, fruit, and flavorings - are purchased in bulk to reduce costs, stored, and processed
according to an old-fashioned recipe. Dry ingredients are stored in a single warehouse along
with the ice cream containers. Hudson's refrigerated warehouse stores both the dairy-based
ingredients and the completed products awaiting transportation.
The actual ice cream manufacturing process involves a number of steps. Since orders
are made up on a job lot basis, the required volumes of ingredients are assembled and sent to
the quality control department. There, roughly ten percent of the ingredients are rejected due
to a lack of freshness. From QC, the ingredients are measured out by an automatic dispenser
and transported by hand to the production area, where they are blended, mixed and processed
into ice cream. Due to good employee training, losses through spillage and contamination are
held to about three percent.
Given the large number of moving parts and frequent formulation changes due to
individual customer orders, the three dispensing machines must be cleaned frequently. The
dispensing machines become contaminated with oils from the ingredients, and cleaning is
performed with a solvent since many of the oils are non-soluble in water. Breakdown and
cleaning contaminates the solvent with both food oils and tramp lubricating oils.
The processing equipment also requires frequent cleaning. As the product is created,
a buildup of scum and sludge dries onto the surfaces of the vats and equipment. Removal of
this organic buildup can only be accomplished through the use of a hot sodium
hydroxide/water solution. The initial cleaning is followed by three to five separate water
rinses. The cleaning operation, following each batch, is performed several times per day.
Although the resulting waste is not hazardous and has been permitted for discharge to a
Publicly Owned Treatment Works (POTW), the large volume of organic particles sometimes
causes therbiological oxygen demand (BOD) to exceed permit Emits, resulting in occasional

fines. Because of the fines, the POTW recently increased its monitoring and reporting
requirements of BOD and other constituents. Because Hudson has no in-house lab
capability, the company hires an outside laboratory to handle these tasks.
Following processing, the ice cream is packaged and stored in the refrigerated
warehouse. Over runs are generally kept for several days and if possible, shipped to an
appropriate buyer. Past date overruns are returned to the plant where they are discarded
with the processing equipment cleaning solution.
Hudson ships ice cream to retail and grocery stores throughout New England. Due to
the custom product and service Hudson offers, it maintains a salesfbrce of ten
representatives. Once a store agrees to carry Hudson ice cream, a schedule is drawn up that
indicates the particular formulations desired and the delivery schedule. Hudson maintains a
fleet of 12 refrigerated vehicles for this delivery function.
Hudson's marketing department maintains an active marketing strategy that includes
print and radio advertising and such sales promotions as coupon deals with the retailers.

A -1
lie C. Sum of an Annuity of $1 for n Periods: ^ 2. (1 + r)'

* fWLg
6 1520
7 7156
8 1152
8 7537
14 796
11 413
14 615
21 12i
13 726
15 327
16 499
29 73"
9 7546
11 491
12 487
14 775
16 785
17 516
24 712
29 369
34 695
13 180
31 643
47 061

17 257
21 824
30 324
35 949
55 717
60 925
87 442
181 86
262 35
377 6S
18 430
20 012
21 761
23 697
25 840
36 973
40 544
59 117
71 673
105 93
157 25
347 30
514 K
21 412
25 645
2B 132
37 450
55 749
68 394
64 140
103 74
128 11
195 99
459 44
700 9:
20 610
27 67'
41 446
46 018
51 159
78 969
154 74
244 03
607 47
954 2*
29 778
36 785
45 782
51 160
102 44
146 62
494 21
602 86

2404 C
244 48
3771 ;

44 311
51 113
245 71
2185 7
47 064
54 669
74 483
102 72
1383 1
2798 7
5624 7
11197 5
49 967
134 20
7425 6
52 966
73 639
87 346
124 13
214 SB
377 16
669 44
964 06
2128 9
4587 6
20714 •

34 784
66 438
94 460
164 49
434 74
1181 8
3034 .B
•PV1FA . 99.99'
Table 0. Present Value of an Annuity of S1 for n Periods:
^ o»
r ^ —-—i
l t-1 0 + *)' J
mantm 1%
2 2832
i fwn

3 4976

4 1604
3 6U5
7 0197
5 1461
4 9676
4 7988
4 6389
4 0776
6 8017
4 7716
4 1633
4 0310

7 7217
7 3601
4 4941
4 1925
3 6615


14 7179
8 5436
6 7291
5 4746
4 7746
7 7016
5 7487
4 0795
11 1581
7 3656
5 6775
4 8435

11 4699
5 6278
5 1009
4 11C3






Exhibit H (1 of 2)
Table A. Compound Sum of $1: (1 + r)n

1 1941
1 4185
1 7716
t 0721
1 14(7
1 4071
1 7138
1 6280
1 9487
1 1717
1 4775
2 476C
11 7C
1 19S'
2 1719

1 1046

1 1726
1 6047
14 129
18 488
1 1643
1 4002
3 1588
4 3276
38 740
1 1961
1 7024
4 7171
1 7535
14 231
1 4859
13 743




11 918
19 040
114 47
13 110
34 389
784 83
1 7410
5 1117
11 167
50 085
164 84
1 7756
4 1161
7 1143
57 575
1 3478

•WIF . 99.9f
rabte B. Present Value ot $1; ^ J ^






« »•;
.01 IE

TVRI1994 - Module 9
No. 7

EXERCISE: Hudson Ice Cream Company (B)
[This exercise is intended to be used in conjunction with Hudson Ice Cream (A)]
Dispenser Cleaning
The frequency of cleaning the dispensing machines varies with the batch sizes and
scheduling of the custom orders. Frank Walsh, one of the operators, is responsible for
maintaining the cleaning records for both shifts. A representative sample of two weeks of
records is reproduced below. The contaminated solvent, about 95% of the original volume, is
shipped and disposed of as hazardous waste at a cost of $.28 a pound. Art Beckwith, a
process engineer who is responsible for handling environmental compliance, spends about 2
hours a month labeling and manifesting the hazardous waste drums. Because of the increased
volume and added shifts, Beckwith performs this and other paperwork after hours, at time
and a half. The use of the solvent exceeds the TURA threshold of 10,000 lbs. and triggers an
annual TURA fee of $1100.
The cost of the raw solvent is S .25 per pound. Handling the solvent (receiving,
inventory management, process use, and disposal containerization) requires about 10 hours a

Solvent used
uer shift Tlbsl
Processing Equipment
Hot sodium hydroxide/water solution is used to clean the scum and sludge build-up on
the vats and other equipment after each batch. A portion of the cleaning record is shown
below. The cleaning and each separate rinse for all the equipment uses 50 gallons of water, at
a cost of $40 per 1000 gallons. Each cleaning also uses five pounds of sodium hydroxide,
which the purchasing department reports it buys for $500 a ton. The hot water portion of
the $12000 annual gas bill is estimated to be roughly 15% of which all but 10% is used for the
equipment cleaning. Fines for exceeding the BOD limit have also been rising due to increased
production volume and tighter effluent limits. The fines were only $5300 three years ago and
$6000 last year. The municipal POTW has been discussing further tightening of limits
because of the worsening quality of its influent due to the growing number of food processing
companies in the area. The lab fees for performing the wastewater monitoring and reporting
are currently at a weekly cost of $100. Beckwith spends an hour a week coordinating with
the lab, reviewing and signing-off on the reports and estimated he spent about 100 hours in
the previous year meeting and talking to the POTW officials about the fines.

No. of cleanings oer dav
Cleaning Time per dav (minutes)

EXERCISE: Hudson Ice Cream Company
Each team should develop a discounted cash flow analysis of its project using the
information in the (A) and (B) cases and in the Project descriptions. Hudson's aftertax cost
ofcapital is 12 percent and its tax rate is 40 percent. The wage rate is $30 per hour. All the
options have 10 year economic lifetimes. Using both the information provided and your own
resources, examine qualitative aspects of the projects that might either augment or counter the
quantitative analysis.
Team "A" has been assigned to evaluate a project dealing with the BOD problems
generated by the frequent cleanings of the vats and other process equipment. The project
team is considering the purchase of a small package treatment plant, capable of treating 1000 -
3000 gallons of wastewater per day to a quality sufficient for raise in the cleaning process.
Only the final rinse of the equipment would require fresh raw water. The basic equipment
would cost about $50,000, with another $25,000 for engineering, plant modifications,
installation and attendant start-up costs. The operation of the plant could be handled either
by an outside operator, at a cost ofaboutSlSOa week, or by someone in-house. It would
take about 100 hours of training for an engineer to attain a license to operate the treatment
equipment, which would require about an hour a day lo run and maintain. Other operating
costs include chemicals and electricity, projected at £30 and $25 a week respectively.
Beckwith estimates that the plant would enable water purchases to be cut by 80-90%.
The small volume of wastewater that continued to be discharged to the POTW would be well
below current or projected BOD levels, reducing monitoring and enabling the lab testing fees
and related paperwork to be cut to 25% of the current level by the second year. The plant
would generate a small quantity of non-hazardous sludge which would cost $500 annually to
dispose of
The "B" team is also charged with addressing the excess BOD problem, but in a very
different fashion. Jim Wales, a process engineer, has recently attended a trade show on
process equipment. He returned all charged up about an innovative coaling under
development whose inventors claim that it can be applied to new vats to virtually eliminate
the build-up of scum and sludge. Though still in the pilot testing stage, the new vats • called
"Vat-free" - are due to hit the market in six months to a year. Production volume is expected
to be quite low for the first two years, and, based on the excitement that the product
generated at the show, Wales is certain that pre-production orders would be strong.

The patented "Vat-free" coating utilizes a ionized transfulvic polymer to inhibit
residue build-up. The small amount that would accumulate would be removed every few
hours by a low-voltage electric charge that makes the residue flake off into the bottom of the
vats where it can be brushed out and the cleaning completed with a single quick cold rinse.
Replacement of the vats and other equipment on the custom ice cream line would cost about
$175,000 at pre-production prices. The company developing the new equipment is selling
the first models at break-even cost to encourage their acceptance and to raise money to
completethe financing of the production equipment. After the promotion expires in few
months, prices are expected to rise by 35-40%. Thus far the coating has performed
exceptionally well in testing, though there had been no extended production runs and no
consumer testing of the ice cream produced in the "Vat-free" equipment.
Use of the new vats would reduce the time spent on the cleanings by 90% and would
reduce water consumption by 95%. The wastewater discharged to the POTW would be well
within BOD limits, though the POTW would probably still require quarterly monitoring.
The "C" project team's mission is to focus on the volume of solvent used and
disposed of as hazardous waste. It is considering the use of a solvent recovery still that a
sister division has in storage and would be willing to 'give away* for nothing. The still had
been used for several years but then discontinued due to the substitution of a non-hazardous,
aqueous-based solvent. Because it had been sitting unattended for several years without
proper cleaning and preparation for storage, the equipment would require an overhaul costing
in the range of $1500 - $3000 depending on what parts would be required. Art Beckwith,
the plant environmental engineer, estimated that the still would enable an 80% reduction in
the volume of solvent used and that the time required to operate and maintain the still would
be about four hours more than the time saved from decreased handling and use of solvent. He
estimated the electric charge at $600 a year. Because the still bottoms would be more
concentrated than the spent solvent, they would cost $1.50 a pound to dispose of but could
be stored and manifested for disposal once a quarter, instead of the monthly manifesting
under the current process. The volume of the still bottoms would be about 50% of the
volume of raw solvent purchased for the process.
The "D" team is also looking at solvent use and is investigating the purchase of a new
still for $18,000, inclusive of delivery and installation. A top-of-the-line model, the new still
would consume about 30% of the electricity needed by the old model and would need little
additional maintenance - about 1 hour a week. Art Beckwith estimated that the new still
would be about 12% more efficient than the older model. Other potential savings available in
the "C" scenario would also be available to the "D" team.

EXERCISE: Hudson Ice Cream Company (B)
[This exercise is intended to be used in conjunction-with Hudson Ice Cream (A)]
Dispenser Cleaning
The frequency of cleaning the dispensing machines varies with the batch sizes and
scheduling of the custom orders. Frank Walsh, one of the operators, is responsible for
maintaining the cleaning records for both shifts. A representative sample of two weeks of
records is reproduced below. The contaminated solvent, about 95% of the original volume, is
shipped and disposed of as hazardous waste at a cost of S.28 a pound. Art Beckwith, a
process engineer who is responsible for handling environmental compliance, spends about 2
hours a month labeling and manifesting the hazardous waste drums. Because of the increased
volume and added shifts, Beckwith performs this and other paperwork after hours, at time
and a half. The use of the solvent exceeds the TURA threshold of 10,000 lbs. and triggers an
annual TURA fee of $1100.
The cost of the raw solvent is $ .25 per pound. Handling the solvent (receiving,
inventory management, process use, and disposal containerization) requires about 10 hours a

Solvent used
per shift flbsl
Processing Equipment
Hot sodium hydroxide/water solution is used to clean the scum and sludge build-up on
the vats and other equipment after each batch. A portion of the cleaning record is shown
below. The cleaning and each separate rinse for all the equipment uses SO gallons of water, at
a cost of $40 per 1000 gallons. Each cleaning also uses five pounds of sodium hydroxide,
which the purchasing department reports it buys for $500 a ton. The hot water portion of
the $12000 annual gas bill is estimated to be roughly 15% of which all but 10% is used for the
equipment cleaning. Fines for exceeding the BOD limit have also been rising due to increased
production volume and tighter effluent limits. The fines were only $5300 three years ago and
$6000 last year. The municipal POTW has been discussing further tightening of limits
because of the worsening quality of its influent due to the growing number of food processing
companies in the area. The lab fees for performing the wastewater monitoring and reporting
are currently at a weekly cost of $100. Beckwith spends an hour a week coordinating with
the lab, reviewing and signing-off on the reports and estimated he spent about 100 hours in
the previous year meeting and talking to the POTW officials about the fines.

No. of cleanings per day
Pinning Time per dav (minutes)

EXERCISE: Hudson Ice Cream Company
Each team should develop a discounted cash flow analysis of its project using the
information in the (A) and (B) cases and in the Project descriptions. Hudson's after-tiu cost
of capital is 12 percent and its tax rate is 40 percent. The wage rate is S30 per hour. All the
options have 10 year economic lifetimes. Using both the information provided and your own
resources, examine qualitative aspects of the projects that might either augment or counter the
quantitative analysis.
Team "A" has been assigned to evaluate a project dealing with the BOD problems
generated by the frequent cleanings of the vats and other process equipment. The project
team, is considering tia purchase of a smali package treatment plant, capable of treating 1000 -
3000 gallons of wastewater per day to a quality sufficient for reuse in the cleaning process.
Only the final rinse of the equipment would require fresh raw water. The basic equipment
would cost about 550,000, with another $25,000 for engineering, plant modifications,
installation and attendant start-up costs. The operation of the plant could be handled either
by an outside operator, it a cost of about S150 a week, or by someone in-bouse. It would
take about 100 hours of training for an engineer to attain a license to operate the treatment
equipment, which would require about an hour a day to nm and maintain. Other operating
costs include chemicals and electricity, projected at J30 and $25 a week respectively.
Beckwith estimates that the plant would enable water purchases to be cut by 80-90%.
The small volume of wastewater that continued to be discharged to the POTW would be well
below current or projected BOD levels, reducing monitoring and enabling the lab testing fees
and related paperwork to be cut to 25% of the current level by the second year. The plant
would generate a small quantity of non-hazardous sludge which would cost $500 annually to
dispose ol
The "B" team is also dunged with addressing the excess BOD problem, but in a voy
different fashion. An Wales, a process engineer, has recently attended a trade show on
process equipment. He returned aO charged up about an innovative coating under
development whose inventors claim that it can be applied to new vats to virtually eliminate
the build-up of scum and sludge. Though still in the pilot testing stage, the sew vats - called
"Vat-free* - are due to hit the market in six months to a year. Production volume is expected
to be quite low for the first two years, and, based on the excitement that the product
generated at the show, Wales is certain that pre-production orders wouLd be strong.

The patented "Vat-free" coating utilizes a ionized transfulvic polymer to inhibit
residue build-up. The small amount that would accumulate would be removed every few
hours by a low-voltage electric charge that makes the residue flake off into the bottom of the
vats where it can be brushed out and the cleaning completed with a single quick cold rinse.
Replacement of the vats and other equipment on the custom ice cream line would cost about
$175,000 at pre-production prices. The company developing the new equipment is selling
the first models at break-even cost to encourage their acceptance and to raise money to
complete the financing of the production equipment. After the promotion expires in few
months, prices are expected to rise by 35-40%. Thus far the coating has performed
exceptionally well in testing, though there had been no extended production runs and no
consumer testing of the ice cream produced in the "Vat-free" equipment.
Use of the new vats would reduce the time spent on the cleanings by 90% and would
reduce water consumption by 95%. The wastewater discharged to the POTW would be well
within BOD limits, though the POTW would probably still require quarterly monitoring.
The "C" project team's mission is to focus on the volume of solvent used and
disposed of as hazardous waste. It is considering the use of a solvent recovery still that a
sister division has in storage and would be willing to 'give away* for nothing. The still had
been used for several years but then discontinued due to the substitution of a non-hazardous,
aqueous-based solvent. Because it had been sitting unattended for several years without
proper cleaning and preparation for storage, the equipment would require an overhaul costing
in the range of $1500 - $3000 depending on what parts would be required. Art Beckwith,
the plant environmental engineer, estimated that the still would enable an 80% reduction in
the volume of solvent used and that the time required to operate and maintain the still would
be about four hours more than the time saved from decreased handling and use of solvent. He
estimated the electric charge at $600 a year. Because the still bottoms would be more
concentrated than the spent solvent, they would cost $1.50 a pound to dispose of but could
be stored and manifested for disposal once a quarter, instead of the monthly manifesting
under the current process. The volume of the still bottoms would be about 50% of the
volume of raw solvent purchased for the process.
The "D" team is also looking at solvent use and is investigating the purchase of a new
still for $18,000, inclusive of delivery and installation. A top-of-the-line model, the new still
would consume about 30% of the electricity needed by the old model and would need little
additional maintenance - about 1 hour a week. Art Beckwith estimated that the new still
would be about 12% more efficient than the older model. Other potential savings available in
the "C" scenario would also be available to the "D" team.

EXERCISE: Hudson Ice Cream Company (B)
[This exercise is intended to be used in conjunction with Hudson Ice Cream (A)J
Dispenser Cleaning Costs
The solvent used to clean the dispensing machines is stored in a special containment
area, in which solvents for other processes are also kept. The containment area was
constructed three years ago specifically for this purpose. The frequency of cleaning the
dispensing machines varies with the batch sizes and scheduling of the custom orders. Each
cleaning requires 10 pounds of solvent. F. Walsh, one of the operators, is responsible for
maintaining the cleaning records for the day shift. Though some of the contaminated solvent
is lost to fugitive emissions, most is disposed of as hazardous waste. A. Beckwith is
responsible for handling environmental compliance, including labeling and manifesting the
hazardous waste drums and performing the regulatory paperwork. Because of the increased
volume and added shifts, Beckwith performs these duties after hours, at time and a half. The
use of the solvent exceeds the TURA threshold of 10,000 lbs. and triggers an annual TURA
fee. Handling the solvent (receiving, inventory management, process use, and disposal
containerization) requires about 10 hours a week.
Processing Equipment Cleaning Costs
Hot sodium hydroxide/water solution is used to clean the scum and sludge build-up on
the vats and other equipment after each batch. The sodium hydroxide is kept in a designated
portion of the regular storage area. F. Walsh has started to keep detailed records of the in
order to better understand the cost of the cleaning process. The cleaning and each separate
rinse (check 'A' case) for the equipment uses SO gallons of water. The plant has a total
annual gas bill of $12,000, a portion of which is used to heat the hot water. Fines for
exceeding the BOD limit have also been rising due to increased production volume and tighter
effluent limits. The fines were only SS300 three years ago and $6000 last year. The
municipal POTW has been discussing further tightening of limits because of the worsening
quality of its influent due to the growing number of food processing companies in the area.
Art Beckwith, in charge of environmental compliance, coordinates the testing with the lab,
reviews and signs off on the reports. Last year he spent a considerable amount of time
dealing with the POTW officials about the violations and level of fines.

COST OF TOXICS - Processing Equipment Cleaning



Total Capital Costs


Raw materials

Production & maintenance labor


> Water

> Electricity

> Gas/CHI

Waste Management

> Labor

> Chemicals

> Testing/Monitoring

> Disposal

> Labeling/Manifesting

> Recording/Filing paperwork

Regulatory fines

Regulatory fees (TURA)

Dealing with regulatory staff



COST OF TOXICS - Processing Equipment Cleaning



Total Capital Costs


Raw materials

Production & maintenance labor


> Water

> Electricity

> Gas/Oil

Waste Management

> Labor

> Chemicals

> Testing/Monitoring

> Disposal

> Labeling/Manifesting

> Recording/Filing paperwork

Regulatory fines

Regulatory fees (TURA)

Dealing with regulatory staff




COST OF TOXICS - Dispenser Cleaning



Total Capital Costs

Current Costs
Raw materials

Production & maintenance labor


> Water

> Electricity

> Gas/Oil

Waste Management

> Labor

> Chemicals

> Testing/Monitoring

> Disposal

> Labeling/Manifesting

> Recording/Filing paperwork

Regulatory fines

Regulatory fees (TURA)

Dealing with regulatory staff


COST OF TOXICS - Processing Equipment Cleaning



Total Capita] Costs


Raw materials
Production & maintenance labor

> Water
> Electricity

> Gas/Oil
Waste Management

> Labor

> Chemicals

> Testing/Monitoring
> Disposal

> Labeling/Manifesting

> Recording/Filing paperwork
Regulatory fines
Regulatory fees (TURA)

Dealing with regulatory staff


COST OF TOXICS - Dispenser Cleaning



Total Capital Costs

Current Costs
Raw materials
Production & maintenance labor

> Water

> Electricity

> Gas/Oil

Waste Management

> Labor

> Chemicals

> Testing/Monitoring

> Disposal
> Labeling/Manifesting
> Recording/Filing paperwork

Regulatory fines

Regulatory fees (TURA)
Dealing with regulatory staff





Equipment purchase

Installation & start-up
Total Capital Costs

Current Costs
Option A Costs
(Costs) & Savings
Raw materials

Production & maintenance labor


> Water
$16,640 | $2,496
> Electricity

Waste Management

> Labor

> Chemicals

> Testing/monitoring
> Disposal

Regulatory fees (TURA)

Regulatory fines
Recording/filing paperwork
Dealing with regulatory staff
Total Annual Operating Cash Flows
SI 5346

Incremental cash flows

+ Depreciation tax shield (dep x tax rate)

= Adjusted BT Cash Flow

x PV Annuity Factor (10 yrs @ 20%)

= Before Tax PV

- Total capital costs
= Before Tax Net Present Value


Incremental cash flows

- Depreciation

= Taxable Income

Income Tax @ 40%


Incremental cash flows

- Income Tax

= After tax cash flow

x PV Annuity Factor (10 yrs @ 12%)

= After tax Present Value

- Total capital costs
= After Tax Net Present Value



1	t			

Equipment purchase

Installation & start-up
• : ill ^111
Total Capital Costs
in Sfg


Current Costs | Option B Costs
(Costs) & Savings
Raw materials

Production & maintenance labor

> Water
> Electricity

> Gas/Oil
Waste Management

> Labor

> Chemicals

> Testing/monitoring
Regulatory fees (TURA)

Regulatory fines
Recording/filing paperwork
Dealing with regulatory staff
Total Annual Operating Cash Flows

Incremental cash flows

+ Depreciation tax shield (dep x tax rate)

= Adjusted BT Cash Flow

x PV Annuity Factor

= Before Tax PV

- Total capital costs
= Before Tax Net Present Value


Incremental cash flows

- Depreciation

= Taxable Income

Income Tax @ 40%


Incremental cash flows

- Income Tax

= After tax cash flow

x PV Annuity Factor

= After tax present value

- Total capital costs . |
= After Tax Net Present Value





Equipment purchase

Installation & start-up
Total Capital Costs

Current Costs Option C Costs
(Costs) & Savings
Raw materials
$4,160 | $832
Production & maintenance labor

> Water

> Electricity

Waste Management

> Labor

> Chemicals

> Testing/monitoring

> Disposal Spent Solvent
> Disposal Still Bottoms

Regulatory fees (TURA)
Recording/filing paperwork
Dealing with regulatory staff
Total Annual Operating Cash Flows

Incremental cash flows

+ Depreciation tax shield (dep x tax rate)

= Adjusted BT Cash Flow

x PV Annuity Factor (10 yrs @ 20%)

= Before Tax PV

-	Total capital costs
-	Before Tax Net Present Value


Incremental cash flows

- Depreciation

= Taxable Income

Income Tax ^ 40%


Incremental cash flows

- Income Tax

= After tax cash flow

x PV Annuity Factor (10 yrs @ 12%)

= After tax present value

- Total capital costs
= After Tax Net Present Value




	t	•	

Equipment purchase

Installation & start-up

Total Capital Costs

%/ - ssw ^ III


Current Costs
Option D Costs
(Costs) & Savings
Raw materials
Production & maintenance labor

> Water

> Electricity

> Gas/Oil

Waste Management

> Labor

> Chemicals

> Testing/monitoring

> Disposal Spent Solvent
> Disposal Still Bottoms

Regulatory fees (TURA)

Recording/filing paperwork
Total Annual Operating Cash Flows

Incremental cash flows

+ Depreciation tax shield (dep x tax rate)

= Adjusted BT Cash Flow

x PV Annuity Factor (10 yrs @ 20%)

= Before Tax PV

- Total capital costs

= Before Tax Net Present Value


Incremental cash flows

- Depreciation

= Taxable Income

Income Tax @ 40%


Incremental cash flows

- Income Tax

= After tax cash flow

x PV Annuity Factor (lOyrs @ 12%)

= After tax present value

- Total capital costs

- After Tax Net Present Value


Hudson Ice Cream Answer Sheet




Equipment purchase
Installation & start-up
Total Capital Costs

Current Costs
Option Costs
(Costs) & Savings
Raw materials

Production & maintenance labor


> Water

> Electricity

> Gas/Oil

Waste Management

> Labor

> Chemicals

> Testing/Monitoring

> Disposal

> Labeling/Manifesting

> Recording/Filing

Regulatory fees (TURA)

Regulatory fines

Dealing with regulatory staff
Total Annual Operating Cash Flows


Incremental cash flows

x PV Annuity Factor (10 yrs @ 20%)

= Before Tax PV

- Total capital costs
= Before Tax Net Present Value


Incremental cash flows

- Depreciation

= Taxable Income

Income Tax @ 40%

Incremental cash flows

- Income Tax

= After tax cash flow

x PV Annuity Factor (10 yrs @ 12%)

= After tax Present Value

- Total capital costs
= After Tax Net Present Value


Developing Interactive, Participatory Activities
1.	Determine the objective of the activity. What do you
want participants to learn?
2.	Characterize your audience (needs analysis)
3.	Design the activity so that it can be related to
participants' real life experiences
4.	Define boundaries. Have clear, written directions for
students (i.e., both what andj how they are to perform
the activity)

Conducting Interactive, Participatory Activities
As the instructor/facilitator:
1.	Describe the purpose/goal of the activity
2.	Describe the activity (the scenario), and give directions
(written directions are better)
3.	Turn over control of the learning to the students; allow
learning to take place
4.	Take back control from the students for debriefing from
the activity and to focus the learning

Tasks for Presentations
1.	Select a topic from the agenda
2.	Identify audience (for example, managers, workers, or community)
3.	Develop an exercise that involves the audience in learning about the
topic. This exercise could be a case study, a brainstorming
exercise, a role play, or a facilitated discussion. Feel free to draw
on the activities we have used this week as well as the materials
in your notebooks (Section V.C. of the notebook contains several
pollution prevention training exercises)
4.	Plan on having the activity last no more than 20 minutes
5.	We expect each member of the group to deliver a part of the
6.	Other class members will play the role of the audience that was
identified (e.g., managers, workers, community)

Who is your audience? How will you And out their needs?
What will you teach? What topics are most important for your audience?
What do you need to do to deliver this training? What are the steps involved?
What resources will you need and how can you get them?
How can EP3 help you implement your training action plan?

Points for the observer of the strategic meeting
1.	Make sure all participants in the sector group understands the purpose
of the strategic meeting and tasks each group must accomplish during the
time period allowed.
2.	Keep the group moving along, make sure they accomplish all the
tasks within the time allotted.
3.	When the meeting ends, assign specific roles for the hearing.
4.	Review the purpose of the public hearing.

Suggested roles for the public hearing
Private Sector
The President of Terry Incorporated
The President of Marco Incorporated
The Director of the Chamber of Commerce
Public Sector
Within ITESU - The government controlled company
Director of Projects
Director of Marketing
Director of Health and Environment
Ministry for the Environment
The Minister
The Advisor to the Minister
The Governor of the state where ITESU operates
The Mayor of the city where ITESU has its headquarters
Community Sector
President of the citizens group in the community where ITESU
Spokesperson for the country's largest Non Governmental
Spokesperson for the country's largest newspaper
Public hearing official

Points for the Public Hearing Official
1.	Emphasize to the group that the public hearing is the only official
opportunity to be heard before the act is drafted.
2.	Identify and note overlaps in sector priorities.
3.	Identify and note the barriers that exist between the different sectors.
4.	Before the hearing begins, check who is playing which specific roles
5.	Are they working towards consensus building?
6.	Keep the group within the allotted time.

Case Study/Role Play
April 14, 1994
Pollution Prevention Program
Caracas, Venezuela
1.	Introduction to case study and role play.
2.	Objectives:
A.	Use this activity as a model educational experience • our role as change agents
B.	Bring resolution to this case study by answering the question, what the content of the
environmental manag»»m«it planning act should look like?
C.	Promote an understanding of the different and similar perspectives that variuos sectors
in a country have towards environmental management.
3.	Definitions
Case study
Role play
i TnfWtifir-atinn nf the rao? - Metal fabrication in the country of San Juan
3. Describe the common priorities identified by the various country sectors
• about the the metal fabricating industry
- anH tnaanl« ptvimrniiwiwl planning anA managwn^nt
6.	Role play • Strategic meeting by section; Public, Private, Community
7.	Assign specific roles within each sector
8.	Public bearing - Aaembtea
9.	Report results of each (3) public hearings
10.	Closure

Metal Fabrication in the country of San Juan
Where: The very small country of San Juan
In recent years. San Juan has seen incredibly rapid growth of their metal fabrication industry, to the point
where the metal fabrication industry represents the greatest source of national revenue and employment
The government of San Juan has promoted the development of both publicly held and pricvately owned
metal finding enterprises. The publicly held and privately owned enterprises are split 30% and 50% in
terms of production capacity and revenue.
The government Ministry for the Environment has recently started pushing for a comprehensive
envrionmental managament planning legislation (act) and the power to enforce such regulation.
Four types metal fabrication are practiced in San Juan; machining operations, parts cleaning and stripping,
metal surface treatment and plating, and paint application. These processes use a variety of hazardous
materia it inHnriing m*^»i working fluids, solvents, "iiraiim» and acid cleaning solutions,and
plating cnhirtftnc that mntain ha-rarrfmic nvtalc oirh a« rarfminm « wll as ryanirf* and mhw chwwieak
anH paintc mimiining solvents and heavy metals.
The three most important sectors of the country (public, private, and community sector) agree on the
impnUaiw q£ <*gfflhliching an p^wnwrnwital iMnagamwrt pmgram anA that fh* jihi^iiiiii rimaibf (g
administered by the Mininstry for the EvironmentaL However, each sector has their own idea of what the
pivimmiiwml manag»im»nt nr planning art tlimM lnnir lilr» awl ling tht Minictry dimlH iwmiiwr nr
enforce the act.
A public hearing has been planned by the commision to allow each sectoral group to describe how they feel
the act should be written and enforced. The results of the public hearing will have a great impact on the
shape of the act.

Common priorities of San Juan
1.	Respect for the importance of the Metal Fabricating Industry to the country' of San Juan.
2.	Support for the development of environmental management and pollution prevention approaches and
technologies appropriate for San Juan.
3 .Desire to diversify the economic activity in San Juan.
4.	Promote the particpadon of the community to monitor the impact of industrial activity on the
5.	Desire to reach international markets, while complying with newly established international standards.

Strategic meetings of the Private, Public, and Community sectors
A commission has been established in San Juan to provide the government with a comprehensive
environmental management act, which may establish pollution standards, regulations, or pollution
prevention incentive programs.
The purpose of this strategic meeting is to prepare each sectoral member for a public hearing (asemblea) that
has been called by the commision established to reach some consensous towards identifying the most
appropriate type of environmental manag»»nM»nt act for San Juan.
Tasks for the sectoral groups:
1.	Define the environmental priorities of the sector.
2.	Prepare an opening	to be offered during the public hearing. This opening statement should
represent the sector's recommended environmental management program for San Juan.
3.	Discuss and identify two priority issues they would like to see refelcted in the act
4. Prepare a series questions to be asked during the public hearing

Moving from Managing for Environmental
Compliance to Managing for Prevention
and Environmental Excellence
Cornelius C. Smith, Jr.
ENVIRON Corporation
Princeton, New Jersey
The bad news is that only a limited number of
U.S. corporations can credibly boast that they
have an outstanding environmental compliance
program. The good news is that each day, more
companies recognize that compliance alone is not
enough, because environmental performance excel-
lence is a necessary ingredient of overall business
Companies that manufacture, handle, or use
chemicals and hazardous materials are beginning to
realize that corporate environmental excellence is a
critical business objective that should be viewed as a
condition of success and profitability, rather than as
a cost of doing business. Their chief executive offi-
cers (CEOs) are sounding like the environmental in-
terest group leaders whom they considered their
political adversaries only 10 to 15 years ago. Thus,
Frank Popoff, Dow Chemical CEO, has emphasized
his company's commitment to 'integrate environ-
mental considerations into all business decisions
and design or modify our products to minimize
their environmental impact" And Bob Allen,
AT&T's chairman, has told his managers: 'If we are
going to be a global leader in helping our customers
use information technology — and thaf s our mis-
sion as a company — then we'd better be a global
leader in the way we treat the environment too.'
Lef s assume that your company, the Star Cor-
poration, has a reasonably good compliance pro-
gram, including a sound internal environmental
policy and auditing function. Let's further assume
that your CEO played golf over the weekend with
Frank Popoff and Bob Allen, and calls you up to his
office on Monday morning to request that you pre-
pare a proposal to upgrade Star's environmental
management system to one that moves beyond
compliance to emphasize prevention and perform-
ance excellence. Where should you start? What
should you do? What are some of the differences
between a system that manages for compliance and
one that strives for excellence? What are some of
the roadblocks to achieving excellence? How can
they be overcome?
Compliance vs. Excellence
An environmental excellence system differs from a
compliance system in several respects, including its
objectives, staffing, environmental programs, moti-
vation, resources, organization and integration, and
legal emphasis.
Compliance System: Seeks the absence of several
negatives, such as fines, penalties, image problems
and other liabilities.
Excellence System: In addition to compliance,
seeks to achieve "world class" environmental per-
formance excellence. Benchmarking against indus-
try leaders is practiced, and success is measured by
the degree of continuous improvement
Environmental Technical and Legal Staff
Compliance System: Often considered by line
management as an internal police force, a necessary
evil, or only as an overhead cost that detracts from
bottom line profitability.
Excellence System: Line management recognizes
and accepts primary accountability for environ-
mental performance and values its staff for their ex-
pert advice and assistance.
Environmental Programs
Compliance System: Limits its activities to pro-
grams necessary to meet applicable legal require-
ments. Such programs are generally reactive and
tend to minor the governmental command and
control requirements to which they relate.

Corporate Quality/environmental Management III, 1993
leadership — vision to Reality
Excellence System: Initiates programs to mini-
mize or eliminate pollution and to eliminate or con-
trol safety and health hazards. Thus, its vision is
complete avoidance of traditional compliance and
liability risks.
Compliance System: Fear of fines, penalties, rep-
rimands, or personal liability is the primary impe-
tus for legal compliance.
Excellence System: Managers and employees rec-
ognize and believe in the business and ethical val-
ues of compliance and environmental performance
excellence. They "do the right thing" because they
want to, not because they have to.
Compliance System: Staff professionals frequently
express concern about the adequacy of resources
necessary to assure full compliance. They often
complain about being overworked and underpaid.
Excellence System: Staff professionals recognize
that resources are necessarily limited, and, there-
fore, seek to leverage company programs into line
organizations, provide expert assistance only, rank
objectives, and measure success by continuous im-
Organization and Integration
Compliance System: Frequently organized along
traditional governmental regulatory lines. Issue
areas such as the environment, employee health
and safety, process safety, medical, and community
affairs are poorly integrated. Often, poor coordina-
tion exists among related company departments
and activities, such as training, communications,
purchasing, distribution, and marketing.
Excellence System: Management of environmen-
tal protection is well integrated with related issues
and activities. The organization reflects the com-
pany culture and mirrors that of line management
Legal Emphasis
Compliance System: Often, the company's legal
department tends to dominate its environmental
management system. The chief environmental
manager frequently reports to the general counsel.
Sometimes, the compliance audit program is con-
sumed by legal reviews, confidentiality considera-
tions, and the like.
Excellence System: Attorneys act as valuable ad-
visors on legal issues. They are key members of
quality teams that develop, upgrade, and monitor
the success of environmental programs.
How to Achieve Excellence
These comparisons are illustrative rather than ex-
haustive. They demonstrate the substantial gulf
that exists between environmental compliance and
excellence management systems. Assuming that
you and other Star staff professionals concur, how
can that gulf be breached? How can the roadblocks
to system excellence be removed? How should you
go about designing a proposal for the Star Com-
pany that will satisfy your CEO's expectations?
Time permitting, I recommend that you start by
comparing the Star system to that of the competi-
tion, industry leaden, and voluntary industry
codes and best practices. Once you have defined
the differences between Star's "current reality" and
"best in class," you must identify the short- and
long-term environmental objectives that will be-
come the basis of your strategic plan. Existing pro-
grams (such as pollution prevention, training, and
auditing) must be examined and upgraded appro-
priately, and new programs (for example, life cycle
analysis) will probably have to be designed and im-
Results, as compared against objectives, must
be measured and analyzed. Be sure die system rec-
ognizes and rewards performance excellence and
integrates environmental performance incentives
into your company's compensation and promotion
systems. And, lastly, corporate environmental man-
agement and performance results and develop-
ments should be monitored on a global basis.
But suppose you only have a week because the
CEO wants a proposal by next Monday. Under
these circumstances, I suggest that you limit your
proposal to benchmarking and strategic planning.
In this regard, you may be well advised to include
in your proposal the establishment of a team of
company experts from various disciplines (for ex-
ample, law, public affairs, and communications)
and environmental staff organizations, with a char-
ter to perform these tasks. To strengthen the proc-
ess, use an outside environmental management
expert as a facilitator.
The transition from an environmental compli-
ance to an excellence system is not a simple task for
any company. It is, however, a task worth doing.
Define the realm of the possible, set your goals,
work to achieve them, measure success in terms of
continuous improvement, and reward performance
excellence. The fear and frustration so often associ-
ated with a compliance system will be replaced
gradually by the satisfaction of being part of a sys-
tem that emphasizes and achieves quality and per-
formance excellence.


Martin A. Spitzer
Robert Pojasek
Francis L. Robertaccio
Judith Nelson
Presented at the Engineering Foundation Conference
"Pollution Prevention - Making It Pay: Creating a Sustainable
Corporation for Improving Environmental Quality"
San Diego, CA
January 24 - 29, 1993

For some time now, advocates of pollution prevention have vehemently argued that pollution
prevention pays. Industry leaders, who ordinarily are not thought of as aggressive environmentalists,
have also begun to echo similar sentiments. In a recent Washington Post article, for example, Dow
Chemical Corporation Chairman, Frank Popoff, said "I find that the premise [of] pollution prevention
carries a heavy, heavy burden. But sometimes there is a direct and obvious payoff" (p. HI, 11/29/92).
For those of us in the pollution prevention business who try to make it happen on a day-to-day basis these
signs are encouraging. But despite the logic of pollution prevention as a concept, the aggressive uigings
of many advocates, and the increasing chorus of business executives who believe that pollution prevention
can pay, a nagging question remains: If pollution prevention pays, why aren't more firms doing it?
As we all know, there is no simple answer to this question. Two commonly recognized answers
are that firms do not have any idea of what their true environmental costs are, and that they do not have
any way of incorporating those costs into their investment decisions. Both arguments are compelling:
if a firm doesn't know what environmental costs it is incurring, it can't possibly figure out how to reduce
or eliminate them. Additionally, if a firm ignores environmental costs particularly the less obvious costs
such as indirect costs, future liabilities, and other social costs) when it does a financial analysis of a
prospective new product or technology, the new product or technology may actually cost more in the long
run than was initially projected.
Purpose of this Paper
The purpose of the paper is to begin to review the state of affairs and die range of issues
involving accounting for environmental costs and capital budgeting for pollution prevention investments.
By collecting this information in one place, we hope to educate the diverse audiences interested in these
issues and to facilitate communication between the many players who must work together if we truly want
progress in pollution prevention.
This paper is a strawperson and a living document that has been developed with the input of many
of you attending this conference as well as others interested in these issues. Currently, it is in a mixed
text and outline format. Following the conference, and based on your additional input, it wQl be
developed further for publication.
To gather this information we collected as many articles, reports, and case studies as we could
find. We also solicited comments from people who have written on these subjects or have personal
experience with them. We by no means believe the current outline is complete. But it is a starting point.
This draft paper covers a variety of issues:
(1)	it identifies the important players involved in accounting and capital budgeting decisions and describes
some of the reasons why each should be concerned about these issues;
(2)	it reviews some of the basic terminology found in the literature and some of the differences of opinion
which have emerged;
(3)	it identifies some of the issues involved in doing innovative accounting and capital budgeting and
highlights connections to the larger social and life cycle cost issues.
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I.	Why is pollution prevention important?
(attach the pollution prevention hierarchy - i.e., source reduction, etc.?)
II.	Why is Improved Accounting for Pollution Prevention Important to You?
A number of players have an interest in this issue and some have contributed information for this
paper; these include engineers, facility or production managers, corporate environmental staffs, financial
managers and officers, corporate decision makers, accountants, bankers and lenders, educators and
academic institutions, environmentalists, EPA and the public. It is and of interest to each of these groups
for a number of reasons:
A.	For industry
•	An important part of the overall strategic direction that businesses must take to
be competitive in the 21st century
•	Step toward sustainability
•	More accurately reflect costs and benefits of products/processes
•	Reduce the cost of production
•	Decrease costs & increase revenues
•	Minimize compliance costs
•	Open new market opportunities
•	Increase "bottom line" & shareholder value
•	Decrease liabilities, insurance & other future costs
•	Create positive corporate image
B.	For academics
•	Better understanding of environmental issues
•	Develop methods and improve curriculum
•	Better educate students (engineers, business students, etc.) regarding the issues
and range of alternatives for environmental protection
•	Step toward sustainability
C.	For accountants
•	Better understanding of environmental costs and the businesses they serve
•	Better service to their clients
•	Improve competitiveness
•	Increase profits
•	Step toward sustainability
D.	For bankers and lenders
•	Better investment decisions
•	Increase profits
•	Improve sustainability
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E. Why is this important to EPA?
•	Assists in identifying pollution prevention technologies as an alternative tr
command and control regulation
•	More efficient and effective way to achieve environmental protection (can achieve
greater environmental clean-up at less cost)
•	Provides a means for "enlightened" corporate decision making that achieves the
twin goals of environmental protection and increased profits
•	Puts industry and EPA on the same side
•	Links environmental protection, economics and sustainable development
•	Improve sustainability for EPA, the U.S. and the planet
In the past, die "bottom line" has always driven corporate america, as well as many of those who
serve them (i.e., bankers, accountants). Further, the general consensus is that current accounting and
capital budgeting methods are biased toward end-off ipe technologies. However, today and for the
future, long term competitiveness in global markets and sustainability of the corporation will depend upon
making innovative changes in all sectors of corporate america. Developing pollution prevention
technologies alone will not do it; for pollution prevention to work, we must also analyze process and
materials flows, improve relationships between all stakeholders, and develop fair, unbiased accounting
methods that accurately reflect the "true" and full costs and benefits of environmental protection. Each
of the above groups has a role to play in discussing and developing these accounting methods.
m. The Context for Accounting and Capital Budgeting
There are many factors affecting whether a firm understands or can identify the benefits
of pollution prevention sufficiently to justify investing in it Two important ones are a firm's
accounting system and capital budgeting process. Though accounting and capital budgeting are
distinct activities within a firm, they each affect how a firm understands its cost of doing
business and how it decides to invest capital. To facilitate a discussion of current perspectives
on these issues, the next section presents some of the terminology common to these issues. The
development of a common understanding of terms and concepts is essential because many
different communities participate in decisions that affect accounting and capital budgeting
decisions. It is important for all of the players listed above, including environmental
professionals, plant operation personnel, corporate accountants, finance personnel, the external
accounting community, and the lending community to understand each other's language
(MacLean, May 10, 1989 and NEWMOA/MAOTA, 1992).
Before describing specific environmental accounting terms, consider for a moment the
distinction between private costs and benefits and social costs and benefits. The distinction is
an important one. Whenever a firm produces or sells a product, it incurs costs and reaps
revenues that affect the firm. The difference between the cost and revenues is the firm's profit.
That same activity, however, also has consequences for society as a whole, beyond the
boundaries of the firm. Economists call the social costs externalities. Government regulation
(e.g., RCRA, Superfund, and the Clean Water Act) try to internalize to the firm some of the
social costs. The chart below graphically represents the distinction between private and social
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costs and benefits.
Private Costs
Societal Costs
In this traditional, model of the world, the firm cares about the costs and revenues inside
the inner box. Those outside the box are of no consequence to the firm's "bottom line." Over
time, government regulation has shifted the firm's boundaries outward. Additional regulation
will continue to do so. Today, other pressures are also forcing the firm's boundaries outward,
compelling the firm to consider costs that in the past it would have typically ignored. For
example, as more and more consumers are interested in "green" products that minimize harm
to the environment, firms are finding it in their own self-interest to incorporate costs that once
would have been considered societal costs. Many of the issues concerning the economics of
pollution prevention are caught up in how the firm accounts for (i.e., identifies, measures, and
analyzes) environmental costs, including private and social costs. In addition, the definition of
terms like "full cost accounting," "total cost accounting," and "total cost assessment," and the
different usages given to them can be best understood in this context.
IV. Accounting and Capital Budgeting Terminology and Issues
Clarification of terms is the first step in facilitating a dialogue on issues. As in other
areas of pollution prevention, not every one agrees on the definition of terms or the appropriate
use of terms. For this reason we present some of the generally recognized terms, and where
appropriate, some of the different uses of terms. Throughout the section, we also try to cut
through some of the rhetoric to ensure that everyone clearly understands the conceptual issues.
A. Accounting
As a general matter, all firms, big or small, collect information to help them make
decisions and prepare necessary financial reports or tax returns. Firms also report data publicly
to stockholders, the Securities and Exchange Commission (SEC), banks, etc. The two terms
commonly used to refer to these activities are "managerial accounting" and "financial
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Managerial Accounting (NEWMOA/MAOTA Curriculum, 1992; White and Becker, 1992
New Solutions; and Todd, July, 1992)
•	The process of collecting, preparing, and analyzing information principally for internal
decision making.
•	In practice, all Arms collect some information, but its structure and use varies from
company to company. Typically, such systems collect information on the cost of
materials and labor, as well as other costs such as overhead, employee benefits, etc.
Financial Accounting (NEWMOA/MAOTA Curriculum, 1992; White and Becker, 1992
New Solutions', and Todd, July, 1992)
•	The process of preparing financial reports relative to an enterprise as a whole for external
parties (e.g., stockholders, creditors, bankers, and government).
•	Unlike managerial accounting, there are strict rules governing what information is to be
collected and how it is to be reported. The ground rules are set by Financial Accounting
Standards Board (FASB) and the (Securities and Exchange Commission (SEC).
•	Firms report publicly only a subset of the information they collect for internal decision
Several terms have emerged to describe the process of more accurate environmental accounting.
Full Cost Accounting
•	A method of "managerial cost accounting" that allocates environmental costs (direct and
indirect) to a product, product line, process, service, or activity. Cost items can be
divided into direct and indirect costs. (NEWMOA/MAOTA Curriculum, 1992; White
and Becker, 1992 New Solutions; and Todd, July, 1992)
•	Full cost accounting can help managers decide on product costing and pricing, inventory
valuation, profitability, and other decisions. It is not by definition limited to
environmental costs, although, the term has taken on increasing significance for
environmental professionals (NEWMOA/MAOTA Curriculum, 1992; White and Becker,
1992 New Solutions; and Todd, July, 1992)
•	Different Uses of the Term. Not everyone uses the term "full cost accounting" the same
way. Some include only a firm's private costs (i.e., those costs that affect the firm's
bottom line) (NEWMOA/MAOTA and White and Becker) while others (MacLean, 1989)
include the full range of costs throughout the life cycle of the product, from raw material
extraction to product disposal, some of which do not show up directly or even indirectly
in the firms "bottom line" (see definition of life cycle costing below).
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Total Cost Accounting
•	A hybrid term sometimes used as a synonym for either of the definitions given to "full
cost accounting, or as a synonym for "Total Cost Assessment" (see below the definition
of Total Cost Assessment under the Capital Budgeting section).
Full-cost Pricing
•	A less-used term again used as a synonym for Full cost accounting or life cycle costing
(see e.g., Washington Post 11/29/92, page, HI.)
Activitv-Based Costing (ABO (See Appendix A for charts explaining ABC)
•	"ABC [is a product costing system] that allocates [costs typically allocated to] overhead
in proportion to the activities associated with a product or product family." (T. Gunn,
21st Century Manufacturing 1992:104-105)
•	"(TJhe real value of this costing methodology is that it promotes understanding of the
total business process associated with each product and of the company's buildup of value
added in that product." (Gunn, 1992:105)
•	It is a tool to "identify and reduce resource consumption by increasing efficiency
(productivity) and effectiveness (T. Gunn, 1992:107).
•	Todd, July, 1992:12-13 calls this ABC approach an "Environmentally 'Enlightened' Cost
Accounting System."
Life Cvcle Costing
•	A method "in which all (both private and social) costs are identified with a product,
[process, or activity] throughout its lifetime, from raw material acquisition to disposal
•	Where possible, social costs are quantified; where not possible, they may be addressed
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B. Capital Budgeting
Distinct from the process of collecting, analyzing and reporting of costing data, a firm
must decide how to invest its available capital resources. Typically, projects must compete for
a limited pool of resources. The process by which projects are evaluated and approved is
usually referred to as the "capital budgeting process." In a small firm, this might amount to one
or two people doing a back of the envelope calculation that will determine whether to buy a new
piece of equipment. In larger, more sophisticated firms, the process can be elaborate, involving
sophisticated financial analysis, rigorous procedures, and approval by many layers of
management. No two companies have the exact same capital budgeting process.
The basic premise of efforts to improve capital budgeting is to develop financial decision
tools for comparing a new technology to an existing technology or one new technology to
another new technology. In this process, if one includes environmental costs in the analysis of
investment alternatives, then pollution prevention technologies may appear more attractive than
end-of-pipe oriented investments. By reducing environmental costs such as raw material
purchases, waste disposal, regulatory compliance, and future liabilities, and increasing revenues
through more competitive "green products," pollution prevention investments may outperform
end-of-pipe investments, which waste raw materials, shift pollutants from one media to another,
and result in long term compliance costs and future liabilities. To understand these advantages
one needs to take steps to identify and analyze them.
A number of methods and terms have emerged since the late 1980s to conduct this sort
of analysis — "Benefits Analysis," Financial Analysis of Waste Management Alternatives,"
"Economic Feasibility," "Total Cost Assessment," and "Costing and Financial Analysis of
Pollution Prevention Investments." Of these terms, two have readily available definitions:
Total Cost Assessment
• Long-term, comprehensive financial analysis of the full range of internal (i.e., private)
costs and savings of an investment (White and Becker).
Costing and Financial Analysis of Pollution Prevention Projects
• "[i]nvolves the collection of costs from the corporate cost accounting system, the
application of a financial tool, and analysis of the quantitative and qualitative aspects of
the project." (NEWMOA/MAOTA).
Though each of the methods has different emphases and each of the authors use different
terminology, the methods have utility because they highlight many of the issues involved in
"leveling the playing field" between pollution prevention technologies and end-of-pipe oriented
technologies. At the same time, however, they have led to some confusion among practitioners.
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Let us briefly clarify some issues: What are the basic elements of these approaches? How do
they relate to accounting issues? And, how do they relate to life cycle cost analysis?
What are the basic elements of these "innovative" capital budgeting evaluations?
(1)	Identify environmental costs and benefits (different methods have different terms for the
cost categories) Genetically the categories are:
-	direct
-	indirect
-	future liabilities
-	intangibles or difficult to measure
(2)	Collect or assemble the environmental cost data
(3)	Allocate environmental costs to the products and processes responsible for them
(4)	Conduct financial analysis using decision tools that take account of the time value of
money (i.e., that a dollar today is worth more than a dollar tomorrow)
(5)	Consider cash flows and the profitability of a project over a sufficiently long time
horizon to reflect the long-term benefits of pollution prevention alternatives
(6)	Analyze qualitatively those data and issues one can not quantify;
(7)	Prepare the data and information in a format that managers and lenders can understand
and find useful.
How does the capital budgeting process relate to managerial accounting?
•	Data collected in a full cost managerial accounting system or an activity-based costing
system is needed to support the financial analysis of a pollution prevention investment.
Steps 1, 2 and 3 above are part of "full cost accounting" and "activity-based costing."
•	Sometimes the data are collected on a project-by-project basis. Thus, data may be
collected solely to support a capital budgeting decision. In other, far fewer, instances,
data are collected routinely and periodically as part of a managerial accounting system.
Data collected in this way can inform both routine management decisions and capital
budgeting decisions.
How do these methods relate to Life Cvcle Cost Analysis?
• They are different from Life Cycle Cost Analysis - A life cycle cost analysis of an
investment alternative includes private and social costs and benefits of an investment.
Many of the other methods mentioned above and listed in Appendix B include only
private costs and benefits.
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Whv are these tools beneficial?
•	They allow better investment decisions by incorporating the environmental costs and
benefits of alternative investments.
•	They allow a pollution prevention investment to compete more effectively and on equal
terms with other investment options (e.g., end-of-pipe controls).
V. Issues for Discussion
Given the above information as background, a number of issues may emerge for
discussion at the conference. Listed below are some of those issues, extracted from the
information we reviewed. The lists are not complete; one purpose of the discussions at the
conference is to develop a more complete list, as well as to determine which issues are the most
significant problems for implementing pollution prevention technologies and what is needed (
by whom) to resolve the issues.
A. Financial Accounting Issues
•	For financial statement purposes it is not necessary to associate indirect costs and
most "hidden" costs with products or processes since only the "bottom line" is
•	Future costs (e.g., liabilities, legal costs, potential tort litigation) are often not
assessed (exception is "material" or significant liabilities - e.g., Superfiind).
•	SEC requirements discourage assessing potential liabilities and other future costs.
•	Uncertainty about future environmental compliance problems and future liabilities
make estimates difficult, if not impossible.
•	Traditional accounting methods do not account for social costs and benefits.
•	Social and life cycle accounting for financial purposes is int its infancy.
•	Lawyers and accountants are only interested in these issues to the extent they
impact financial reporting requirements. Their interest is in ensuring that these
costs are never reported, even if it means continuing to mask environmental costs
in overhead accounts.
•	"Some estimates and analyses, which would be helpful to some companies, are
presumably not made." Informal estimates of future remediations costs could be
construed to be firm costs which must be reported to the SEC and stockholders
or an admission of guilt in any legal proceeding.
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B. Managerial Accounting Issues
•	Activity Based Costing (ABC) is not used by most firms.
•	ABC can be very expensive and probably involves a major overhaul of existing
managerial accounting systems.
•	Some question whether there is a need, or a lack of incentives, to determine
which products, product lines or activities are profitable & should be pursued,
and which should not.
•	To accurately assess the true cost of a product or process, there is a need to
flowchart the processes; such processes are often not well understood, and it can
be difficult to develop these flowcharts.
•	There is usually a lack of data on:
-	sources & amounts of pollutants
-	pollution prevention options
-	"hidden" costs (monitoring, paperwork, inspections, etc.).
•	Accounting methods traditionally attribute indirect costs to overhead.
•	We are often myopic and concerned with only our individual self-interest; as a
result, many may question the need to make the corporation more competitive.
•	There is a fear that a fair, unbiased assessment of a product's costs will have
unintended consequences (e.g., plant or firm closure, job losses, etc.).
•	Inability to see how pollution prevention technologies and accounting method
changes can contribute to sustainable development.
•	"Accounting and accounting systems are completely separate from economic or
engineering evaluations."
•	How are mangers incentive systems set up? Incentive systems for managers are
often based on "return on assets (ROA). ROA can discourage managers from
wanting to uncovering the true environmental costs of a product because doing
so could decrease their compensation.-
C. Capital Budgeting Issues
•	There is confusion over terminology amongst the groups (or disciplines) needed
to assess pollution prevention investments.
•	There is confusion over the relationship between accounting systems and the
capital budgeting process.
•	There is a lack of evaluation infrastructure and adequate methods (MacLean,
•	Is process hazard reduction a good model for what is needed? (MacLean,
Motivating, 1989b)
•	Lack of education in terms and methods for fair, unbiased assessment of
environmental expenditures.
•	"A strong technical basis is required to evaluate alternatives correctly...
Technical resources capable of such evaluations are more and more difficult to
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•	Plant personnel do not understand the internal review process for capital approval.
•	Managers do not understand engineers and engineers do not understand needs oi
managers (MacLean, Motivating, 1989b). "From the perspective of the business
manager making a resource decision, however, the often repeated claims of
economic benefit seem like nothing more than a hollow drum beat." (Id. a 4)
'Advocates must articulate." (Id.) They must satisfy their customer, who include
business managers. (MacLean, 1989:1)
•	Command and Control Regulation has led to an infrastructure, even in small
companies, that is outside the management decision process for allocating
resources (MacLean, Motivating, 1989b).
•	Thirty 'upstream* source reduction studies are more taxing on an organization
than one end-of-pipe wastewater treatment plant"
•	Discount Cash Flow (DCF) or Net Present Value (NPV) Analysis:
-	methodology is not widely known
-	method is not used by many firms.
•	Time horizon used for project evaluation biases decisions to end-of-pipe controls
•	Hurdle rate (or discount rate) discourages pollution prevention investments.
"[A]ny investment [to reduce pollution] beyond the bare minimum (incremental
investment) must be economically justified at a rate significantly higher than the
cost of capital...because that incremental investment could have been spent
elsewhere in the company, and earned a profit."
•	Current practice of using a high opportunity cost of capital favors alternatives that
have a low initial cost.
•	"No additional 'credit* is accrued to a pollution prevention project that goes
beyond die regulated limit."
•	What are the appropriate financial indicators for investment decisions - Net
Present Value (NPV), Internal Rate of Return (IRR), Payback/break even point?
•	Inability to identify and estimate "hidden" costs (monitoring, paperwork,
inspections, training, taxes).
•	"Is it worth the effort to quantify uncertainties, soft costs, etc.?"
•	Can "decisions...be based on both the tangible economics as well as less tangible
things, such as environmental impact, corporate strategy, etc."?
•	Although "a good evaluation does not rely solely on accounting data, [but also]
uses estimates of future cash flows for the entire company...it is very difficult to
look beyond one business' accounting cost sheet."
•	"In most cases, the use of decision/risk analysis is cost prohibitive."
•	Every company has a different internal capital approval process
•	Some firms centralize decision making more so than others.
•	Some firms allocate a percentage of their capital budget for environmental
expenditures; in some firms smaller environmental expenditures are not subject
to a full management review process. In some firms, all projects, environmental
or not, have to compete for the same limited pool of capital.
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•	Qualitative issues should also be included in the project justification
(NEWMOA/MAOTA, 1992; Wittman, 1991/1992).
•	There is a need for an appropriate format and justification to present to managers
•	The inability of those conducting a project analysis to cull information out of the
existing information systems can be a significant barrier to conducting an analysis
including the full environmental costs (NEWMOA/MAOTA; Wittman,
•	Plant personnel responsible for putting together a project analysis need to know
what kind of information they can readily draw out of existing data and
accounting systems.
•	Product/Production Issues:
• there may be concerns that new, or different, technologies will
negatively affect product quality.
-	competing production priorities can affect ability and/or willingness to
make innovative changes.
•	Organizational issues:
-	lack of management support to assess M range of alternatives
-	administrative systems which discourage innovation
-	lack of rewards/positive feedback for technological or accounting
-	lack of communication among operating, engineering, environmental &
accounting/financial personnel.
•	Cultural or Attitudinal Issues:
-	belief that environmental expenditures are inherently losing propositions
with negative returns
-	complexity of the analysis - it requires examination of multiple linkages
and flows and their relationship
-	technological complexity of materials, product or process changes make
such innovations more difficult to implement
-	sheer scope of change can be overwhelming
-	lack of perceived need for change - i.e, belief that "the 'minimum
essential investment* is generally synonymous with
what is required by regulation"
-	fear of change or resistance to change
•	Inherent uncertainties in changing products, processes, etc. - i.e., uncertainties
in implementing technological changes
•	Uncertainty that implementing pollution prevention will truly mitigate liabilities
for past or future actions due to changing understanding of environmental issues,
changing legal requirements, and other factors
•	How important is "finance" as a common thread between business units in a
decentralized company? MacLean, 1989:2)
•	"Environmental Professionals work outside.. .managementdecision processes; they
are less skilled at negotiating for limited resources." (Id. at 4)
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•	Lack of a methodology for estimating future environmental liabilities.
•	Don't discount significant future liabilities (MacLean, Motivating, 1989b)
•	Government regulations:
-	often prescriptive, and limit the options
-	media specific approaches discourage taking a holistic view
•	Financial incentives - grants, loans, interest subsidies, state issued loans, tax
credits and deductions are not available or designed to encourage pollution
prevention investments (MacLean, Motivating, 1989b:5).
D. Global Cost/Benefit Analysis
•	"Why limit the boundaries to the corporation?"
•	Only limited tools are available to determine human health costs
•	Lack of methodology and tools to quantitatively assess natural
resource/environmental costs and benefits
•	Life Cycle Analysis (LCA):
-	lack of standard, universally accepted, tested methodology
-	lack of data (see above)
•	The size of the global market has been forever increasing due to population
growth and the concept that quality of life is measured by the magnitude of
individual consumption of goods an services.
•	"Most people and their organizations (companies, countries, etc.) have a fairly
myopic, short-sighted, and personal strategy that controls their decision making
processes... Not much conscious thought is given to the collective needs of the
world community of today...much less tomorrow."
VI. Next Steps?
This paper and the Tuesday session have several purposes. The first is to fully articulate
the issues on accounting and capital budgeting. The second puipose is to begin to identify what
needs to be done, and by whom.
What is an appropriate industry response and role to these issues?
Financial institutions?
What is an appropriate government role?
- Presently, EPA, and several cosponsors (to be named later) plan to hold a
workshop exclusively on the accounting and capital budgeting issues in
Washington, DC in June, 1993.
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Local Government?
What is an appropriate role for environmentalists?
National organizations?
Local organizations?
•	Do we need basic academic research?
•	Should user-friendly computer systems be useful?
•	Should EPA modify its Benefits Manual?
•	Should the accounting community take a leading role?
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APPENDIX A - Activity-Based Costing (Figures taken from Todd, 1992)
Activity-Based Costing has been suggested as a means to allocate environmental costs to
the products and processes that cause them. The following charts demonstrate the problem with
many traditional managerial accounting systems, and how activity-based costing may be able
remedy the problem.
Figure 1 below depicts a traditional accounting system collects many costs and attributes them
to overhead. Environmental costs, among other costs such as supervisors' salaries, paint, and
rent, are examples of costs often attributed to overhead.
Figure 1 - Traditional Cost Accounting System
Figure 2 demonstrates the misallocation of environmental costs. Widget B is responsible for
waste costs. Widget A has no waste costs. The misallocation occurs because the waste cost is
lumped together in an overhead account that is allocated to both Widget A and B equally, or
according to a formula usually linked to the labor input going into Widget A and B. The effect
is that the cost of producing Widget A reflects environmental costs of Widget B.
Figure 2 -Misallocation of Environmental Costs Under Traditional Cost Accounting System
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Figure 3 demonstrates an activity-based costing system that attributes the environmental
costs of Widget B only to Widget B. By breaking environmental cost out of overhead and
attributing directly to products, decision makers will have a much clearer view of what the true
costs of producing Widget A and B.
Figure 3 - Activity-Based Cost Accounting System
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APPENDIX B - Methods and Tools
Capita! pydggting
Available methods for conducting a financial analysis of a potential pollution prevention
•	"Pollution Prevention Benefits Manual," USEPA
•	"Financial Analysis of Waste Management Alternatives," General Electric Corporation
•	"PRECOSIS," George Beetle Company
•	The "Economic Feasibility" Section of U.S. EPA's Waste Minimization Opportunity
Manual and the revised Facility Pollution Prevention Guide
•	Waste Advantages Inc.'s guide, "Industrial Waste Prevention, Guide to Developing an
Effective Waste Minimization Program." (See new software — Green Star)
•	"Economic Analysis of Pollution Prevention," Washington State Department of Ecology
•		 American Institute of Pollution Prevention
•	"Total Cost Assessment" - Tellus Institute (P2 Finance Software)
•	NEWMOA/MAOTA "Costing and Financial Analysis of Pollution Prevention
Investments," curriculum
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American Institute of Pollution Prevention,
Becker, Monica (1991). "Total Cost Assessment: An Overview of Concepts and Methods,"
prepared for Northeast Waste Management Officials' Association^ Boston, Massachusetts,
September 1991.
Burchell, Stuart, et al. (1980), "The Roles of Accounting in Organizations and Society,"
Accounting, Organizations, and Society, Volume 5 (527).
Cooper, David, J. and Michael J. Sherer (1984), "The Value of Corporate Accounting Reports:
Arguments for a Political Economy of Accounting," Accounting, Organizations, and
Society, Volume 9, No. 3/4 (207-232).
Davis, Stanley, W. Krishagopal Menon and Gareth Morgan (1982), "The Images That Have
Shaped Accounting Theory," Accounting, Organizations, and Society, Volume 7,
No. 4 (307-318).
Ewer, Sid, R. Jon R. Nance and Sarah J. Hamlin (July 1992), "Accounting for Tomorrow's
Pollution Control," Journal of Accountancy, (69-74).
General Electric Corporation, Corporate Environmental Programs (1987), Financial Analysis
of Waste Management Alternatives.
Gray, Rob (1992), "Accounting and Environmentalism: An Exploration of The Challenge of
Gently Accounting for Accountability, Transparency, and Sustainability," Accounting,
Organizations, and Society, Volume 17, No. 5 (399-425)
Gunn, Thomas, G. (1992), "Creating Winning Business Performance," 21st Century
Manufacturing, Harper Business, New York.
Hankshaw, Anthony (March 1991), "Status Quo Vadis," CA Magazine, Volume 124 (22-28).
Harding, John, T. (1990), "Actuaries Are Focusing On Environmental Area," Newark Star
Ledgar, July 8,1990.
Hines, Ruth, D. (1988), "Financial Accounting: In Communicating Reality, We Construct
Reality," Accounting, Organizations, and Society, Volume 13, No. 3 (251-261).
MacLean, Richard (1989a), "Economics of Waste Minimization," presented at the Waste
Minimization Conference, New Jersey Department of Environmental Protection, New
Brunswick, New Jersey, May 10, 1989.
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MacLean, Richard (May 30, 1989b) "Motivating Industry Toward Waste Minimization and
Clean Technology," Presented at the Waste Minimization and Clean Technology: Moving!
Toward the 21st Century.
Morgan, Gareth (1988), "Accounting As Reality Construction: Toward a New Epistemology for
Accounting Practice," Accounting, Organizations, and Society, Volume 13, No. 5 (477-
Northeast Waste Management Officials' Association/The Massachusetts Office of Technical
Assistance (1992), "Costing and Financial Analysis of Pollution Prevention Projects: A
Training Packet," Workshop Agenda, Workshop Curriculum, Case Studies and Report.
PRECOSIS, Peer Consultants, and George Beetle Company, (1990) User's guide fir Pollution
Prevention Economic Assessment (PPEA) Version 1.1, prepared for U.S. EPA, Center
for Environmental Research Information, Cincinnati, OH.
Rich, Gerald (August, 1989), "Cost Estimating Spreadsheet for Pollution Control Equipment,"
Pollution Engineering, 85-91.
Rubenstein, Daniel, B. (1992), "Bridging the Gap Between Green Accounting and Black Ink,"
Accounting, Organizations, and Society, Volume 17, No. 5 (501-508).
Surma, John, P. and Albert A. Vondra (March 1992), "Accounting for Environmental Costs:
a Hazardous Subject," Journal of Accountancy, (51-55).
Todd, Rebecca (July, 1992), "Accounting for the Environment: Zero-Loss Environmental
Accounting Systems," Presented at the National Academy of Engineering, Industrial
Ecology/Design for Engineering Workshop, Woods Hole, Massachusetts, July 13-17,
United States Environmental Protection Agency (1989) Pollution Prevention Benefits Manual:
Vol. 1, The Manual Phase II.
United States Environmental Protection Agency (May 1992), Facility Pollution Prevention
Guide, EPA/600/R-92/088.
United States Environmental Protection Agency (May 1992), Total Cost Assessment:
Accelerating Industrial Pollution Prevention through Innovative Project Financial
Analysis, EPA/741/R-92/002.
Waste Advantage, Inc. (1988), Industrial Waste Prevention, Guide to Developing an Effective
Waste Minimization Program, Waste Advantage,Inc., Southfield MI.

White, Allen, L. and Monica Becker (April 1992), "Total Cost Assessment: Revisiting the
Economics of Pollution Prevention Investments," presented at the Conference on
Pollution Prevention in the Chemical Process Industries, April 6-7, 1992.
White, Allen, L. and Monica Becker (Winter 1992), "Total Cost Assessment: Catalyzing
Corporate Self-interest in Pollution Prevention," New Solutions, (34-39).
Washington State, Department of Ecology,	, "Economic Analysis of Pollution Prevention
Wittman, Marlene, R. (July 1991a), "Costing and Financial Analysis of Pollution Prevention
Projects," prepared for the Sutton Facility, Wraybum Jewelry Company, Inc.
Wittman, Marlene, R. (July 1991b), "Costing and Financial Analysis of Pollution Prevention
Projects," prepared for the Fall River Division, Lightolier, Inc.
Wittman, Marlene, R. (1991/92). "Costing and Financial Analysis of a Pollution Prevention
Project," Environmental Finance, Winter 91/92 (433-452).
vcr. 1-15-95
Engineering Foundation
January 24-29, 1993

The evaluation of pollution prevention options involves a five step process:
>	gathering complete, relevant cost information for the current process;
>	estimating relevant cost information for the proposed pollution prevention
>	listing all differential costs resulting from the options;
>	applying financial analysis tool(s);
>	interpreting the quantitative result; and
>	considering the qualitative factors.
In this section, we shall address the steps involved in the costing portion of the
A financial analysis is only as accurate and realistic as the costing information used
in it For example, no amount of mathematical manipulation can compensate for the
distorted effects of outdated, incomplete costing information. Likewise, the financial analysis
cannot "fix" the lack of appropriate costing information. Therefore, the purpose of this
module is to provide guidance on gathering relevant cost information. For example, let us
assume that you work for a business that is are considering the purchase of pollution
prevention equipment First, you should be familiar with all the costs associated with the
current process. In order to ensure completeness, we suggest that you draft a process flow
diagram for the process, indicating the progression of product through the facility. This
visual representation allows you to attach costs at each individual operation.
The purpose of the process flow diagram is to prepare for the second step: assigning
of cost categories to the appropriate points in the process flow diagram.
Some cost categories are fairly easy to identify and collect, such as the cost of raw
materials and the cost of production labor, both known as direct costs. For the cost of raw
materials, you might go to the company's purchasing agent or cost accountant Likewise, the

cost of equipment, such as forklifts and
spare parts, might be obtained from the
company's purchasing department or its
staff of cost accountants.
Many cost items may be difficult to
obtain because they are most likely "hidden"
in the company's cost accounting system.
This is due to the traditional method of
classifying manufacturing costs. For
example facility-wide cost items such as
heat, lighting, maintenance, depreciation
and insurance may be difficult to find.
Most manufacturing costing systems
lump production costs into three major
I. Where do you go wthin the company to
find costing rfornaiiun?
1 Which costs'are relevant? Whatquaffiesas
•relevant* costing information?
DL Hour do you obtain costing information 9
the company's costaccounting system does
not istthe ones youare specScaDy seeking
for an analysis of your PP project?
IV. Which are the dMerenUal costs invoked in
a PP project?
1.	Direct Material
2.	Direct Labor
3.	Overhead (indirect materials and indirect labor, including
hidden environmental costs).
Additionally, a share of the non-manufacturing costs are
allocated to the cost object (See Exhibit A for some typical
manufacturing cost categories). For the evaluation of a pollution
prevention project, you want to analyze same of the hidden costs.
Many of the labor items that you might be interested in (Le^
manifesting, labelling, reporting, training) are lumped into a
category labelled overhead. Abo, you might be concerned with a
number of the indirect materials, such as protective equipment and
training materials; these would also be lumped into the overhead
category. In fact, a majority of the items crucial to a discussion of
the current process and the proposed pollution prevention project
would fall into the overhead category
Many environmental activities are hidden in the overhead
category. Exhibit B lists a number of these hidden environmental
costs for a sample poDution prevention project These hidden
environmental costs are divided into two categories: indirect labor and indirect material
Direct Costs
Direct Materials:
at raw materials
used in the
<_ production
process which
; can be traced to
r Individ u a I
•• products
Direct Labor
earnings of
; workers: who
and/or operate
w macnras m
the- process of
I; production -
The collection of costs is often not a simple matter of consulting the company's cost
accounting system. Depending on the company's cost accounting system, environmental costs

are masked by the use of the overhead category. Also, the
collection of cost data might be hindered by the different
production processes within the plant Because
companies design cost accounting systems that match the
generation of product costs to the production process,
tracing of individual costs is difficult (See Exhibit C for a
description of these different manufacturing costing
systems). In these cases, it is difficult to track costs to
units of product or to specific activities.
If you are seeking information on activities that fall
into the overhead cost category, you will have to obtain
the information from the cost centers themselves. For
example, if your proposed PP project is estimated to
eliminate time spent on manifesting and disposal activities.
Because of the economic justification requirements of
your company, you may need to know how modi time
and money will be saved as a result of installing this new
equipment The environmental staff should have this
information; they should be able to identify the number of
hours -each environmental professional spends per week
or per month, on manifesting activities. Likewise, they
should be familiar with disposal costs if they are
responsible for designating a certified disposal firm and
Overhead Category
Indirect Labor Costs:
environmental personnel
material nananrs
stockroom personnel
inspectors (QA/QC)
foric&t operators
Indirect Material Costs:
• equipment
safety equipment
training materials
office suppfies
process water
Finding cost information is not, therefore, a simple matter of extracting numbers from
the company cost accounting system. An accurate cost analysis requires the collection of
information from many different sources, some accounting and some non-accounting.
Exhibit D indicates some of the non-accounting sources of cost information. For example,
many of the hidden environmental costs can be derived from the engineering staff and/or
environmental department Disposal costs, chemical costs, and the cost of protective
equipment can be identified from vendor receipts or departmental records.

The cost information you are seeking is a total annual amount, which may be
represented as the following:
Wage Rate (WR) x Number of Hours Spent on the Activity x Number of
Occurrences per Year for the Activity
For example, if you are seeking a definite dollar value for the manifesting costs that would
be saved as a result of your proposed pollution prevention strategy, you should consult with
the environmental staff. A typical case may reveal that an environmental engineer spends
1.5 hours completing each manifest, that barrels of toxics are manifested twice per month,
and that each shipment requires two manifests. His/her wage rate, including labor related
costs, is approximately S30 per hour. Labor related costs include the costs of paid holidays,
vacations, pensions plans, benefits, and other fringe benefits. As a ball park figure, we
suggest adding 5 -7 percent to the gross hourly wage to account for labor-related costs. The
total annual savings resulting in the elimination of this manifesting activity can be calculated
as follows:
$30/hour x L5 hours/manifest x 2 manifests/month x 2 occurrences/month x 12
months/year = $2160 per year
Other labor costs can be calculated in the same manner.
Finding the personnel responsible for some activities may be difficult in a large
company. An organizational chart might provide the necessary guidance. In a small
manufacturing operation, where there are some overlapping job functions and
responsibilities, one person might perform a number of the environmental activities in
question. For example, the plant manager might also perform the purchasing and
environmental functions; therefore, only one person need be consulted for cost information.
Depreciation is a cost hem that is often overlooked in project evaluation.
Depreciation is an accounting convention used to indicate the using up of assets - plant and
equipment - in the normal course of business operation. Most plant and equipment items
have a limited useful life; in other words, these items wQl provide service to the entity for
a limited number of years. To indicate a company's use of these assets, a fraction of the
asset's cost is charged as an expense in each of the accounting periods it provides service to
the business. This gradual conversion of plant and equipment into an expense is called
depredation. The annual amount charged as an expense is the depreciation expense.
The use of a long-lived tangible asset is limited by either deterioration or
obsolescence. The service life of an asset is the time, in years, until it is expected to be

disposed of or until it becomes obsolete. There are a number of methods for calculating the
annual depreciation expense, but this curriculum only considers the straight line method.
The straight line method assumes that the asset provides its services to the business in a
level stream from year to year. This method charges as an expense an equal fraction of the
cost of the asset each year. Consider a piece of equipment costing $16,000, with no salvage
value, and a service life of five years:
Animal Depreciation = (Machine Cost - Salvage)/Lifetime of Machine
= $16.000 - 0
Depreciation Charge = $3,200 per year
Depreciation is considered a tax shield because it shelters earnings from tax.
Contrary to popular impressions, depreciation is not a source of money and no check is ever
written for it However, because depreciation does decrease taxable income, it should be
accounted for in the project evaluation.
After collecting cost categories, we suggest you follow these steps:
1. Graph a process flow diagram for the current process. Attach to the
diagram the cost categories you have -collected, including direct and indirect
labor and materials and the hidden environmental cost categories.
2 List the total costs for the current process on an annual basis. The list
should include only those costs that are directly related to the current process
and are measurable and verifiable. The test for relevance is whether the cost
information is meaningful and useful to those who are going to act on the
pollution prevention decision.
3.	If the pollution prevention project is an equipment purchase, list all the
costs involved in the purchase, delivery, installation and start-up of the
machinery. These related start-up costs are necessary for the operation of the
equipment and are referred to as capital costs. Exhibit B lists the capital costs
associated with the purchase and installation of a replacement degreaser.
4.	Review the process flow diagram, noting the costs that are expected to
change substantially as a result of the project The costs representing the
changes are known as differential or incremental costs.

For example, an environmental engineer at Cummings Plastic-Works currently
manifests barrels of spent ethyl acetate once a month, spending two hours on
each manifest His/her current wage rate (WR) is $25/hour. With the
installation of a piece of equipment, s/he only has to manifest barrels three
times per year. The differential cost is as follows:
Current: $25/hour x 2 hours/manifest x 12 manifests/year =
$600 per year
Alternative: J25/hour x 2 hours/manifest x 3 manifests/year =
$150 per year
Differential: $25/hour x 2 hours/manifest x 9 manifests/year -
The differential cost, in this case, indicates a saving of $450 per year. This represents
the dollar amount saved as a result of the pollution prevention project
The following group exercise is designed to stimulate your thinking about the
generation of costs in the manufacturing process. The case describes a very simple
manufacturing process. Follow the process outlined above: draft a process flow diagram and
list the cost categories for each of the processes. Try to be as complete as possible,
including direct labor and materials, indirect labor and materials, and any hidden
environmental costs. After listing as many cost categories as possible, review the list for
Note to the Facilitator We did not include an "answer sheet" for this exercise because there
are various correct ways to diagram the manufacturing process and list the direct and
indirect costs. We suggest that you break the workshop participants into groups of four to
five people and ask each group to develop a process flow diagram and cost list This should
take the groups about 15-20 minutes. As a facilitator, we suggest you sit with each group
briefly to check whether they understand the exercise and are malring progress. After all
the groups have finished, select the group that appears to have done the most thorough
diagram and list Ask this group to present their results to the entire group. When they
have completed their presentation, ask the other groups to add items to the diagram and'
list that may have been overlooked. The entire group should be able to produce a complete
list by the end of the exercise.

Frank Buchanan, manufacturing
vice-president for Hudson Ice Cream
Company, was pleased when he
reviewed the final earnings statement for
the company for 1990. Hudson, founded
in 1973, had managed to maintain steady
sales revenues despite the economic
slowdown in the Northeast
Buchanan credited this success to
the finely tuned manufacturing procesl
All of Hudson's ice cream manufacturing
operations are centered in its Compton
facility. Here, the ice cream ingredients
• milk, sugar, milk powder, whey powder,
and flavorings - are purchased, stored
and processed according to an old-
fashioned recipe. While one portion of
Hudson's warehouse accommodates its
raw material inventory, its refrigerated
portion stores two days worth of
packaged Hudson ice cream products
awaiting transportation. An additional
warehouse stores Hudson's ice cream
containers, which come in the following
sizes and materials: a one gallon plastic,
a one-gallon paper, a two-gallon plastic
and a two-gallon paper.
The actual ice cream
manufacturing process involves a number
of large mixers and dispensers operated
by the shop floor workers. The
dispensers add the appropriate amounts
of dairy ingredients, flavorings and sugar
at different stages as the large bowls are
rotated and the ingredients mixed.
(Sample flavorings include nuts, fruit,
and candy). Given the large number of
moving parts, the dispensers and mixers
require frequent preventive
maintenance. Large amounts of water
are used for rinsing and then discharged
as wastewater.
Hudson ships its ice cream to
retail and grocery stores in
Massachusetts, Connecticut, Rhode
Island and Vermont In order to
convince grocery stores and supermarket
chains to cany Hudson ice cream,
Hudson maintains a salesforce of ten
representatives. Once a grocery store
agrees to cany Hudson ice cream, a
schedule is drawn up which indicates the
delivery schedule and order contents.
Hudson maintains a fleet of 12
refrigerated trucks for this delivery
Hudson's marketing department
tnflintam* an active marketing strategy
that includes print and radio advertising
and sales promotions (Le^ a coupon deal
with the retailers).

As discussed in the overview to this manual, the financial (quantitative) analysis of a
pollution prevention project should be augmented by the evaluation of other factors that are
difficult to quantify but that may have strategic significance. Although these factors are often
referred to as 'qualitative' or 'intangible', such a strict either/or classification (quantitative/
qualitative or tangible/intangible) is often misleading. Many issues fall between these end
points and may be subject to some form of quantification or projection, especially given the
ease of using a computer spreadsheet to perform sensitivity analysis1. A pitfall of defining
issues too simplistically as 'qualitative' or 'intangible' is the tendency to pay less attention to
those items that are not expressed in numerical terms. Because of the current emphasis on
'measurement1 ("You are what you measure"; "You can't change what you can't measure"),
issues that are outside the quantitative domain may not receive sufficient emphasis, even
though their significance to the long-term success of an enterprise may be high. This section
presents approaches and suggestions for ways to evaluate and highlight less tangible issues in
a pollution prevention project proposal.
A Framework for Analyzing Issues
Figure 4.1 provides a mapping framework for considering the strategic and
quantifiable dimensions of issues that a business must address in assessing a pollution
prevention project. An item is plotted on the Y axis according to its relative strategic
significance and on the X axis based on the feasibility of quantifying it.
Figure 4.1
Conventional Hidden
Costs	Casts
Less Tangible Costs
Raw Materials
Waste Disposal
Mgmt Resources
Financial Liability
Market Share
Product Quality
Employee Reltns
Public Image
Criminal Liability
Shareholder RUns
1 See the Appendix titled "Spreadsheet Building" for ;ui explanation and example of (his term.

The map also groups items into three cost categories. The first vertical section
indicates the realm of "conventional costs" that are included in a typical capital budgeting
analysis, and the second section shows the expansion of the capital budgeting model to
include the indirect "hidden costs" that are usually buried in overhead accounts. The Costing
Information section of this manual focuses on the identification and determination of these
two costs areas. The right vertical half of the map includes impacts whose costs are more
difficult to project yet which may have quantifiable ramifications. We label these issues less
tangible, as opposed to purely intangible or qualitative.
The framework can help to guide project assessment and inform the development of a
justification package by clarifying the relative significance of issues and to assist a pollution
prevention project team in determining what items it will attempt to quantify. We
recommend that a team make a first pass' effort to fill in the map prior to performing any
detailed analysis and then repeat the process later in their work. By highlighting the fact the
many less tangible* issues are often of high strategic significance, the map can help to focus
attention on some of the benefits of pollution prevention projects that may tend to be ignored
or undervalued.
Figure 2 offers one example of how issues might be mapped for a particular project
and business. The placement of these factors is not an absolute ranking of the importance of
these issues for an organization; rather it is relative and project specific and thus will vary
considerably even within the same company for different projects. We emphasize that this is
a subjective process and that the example is presented to illustrate how the mapping
framework can be used. NOT to establish a pattern of interpretation to be copied.
Figure 4.2
Less Tangible Costs

• Managem
•Criminal Lib
• public
• Prd Quality/
Market Share 8
* Financial Liability
nt Resources 'Shareholder

* Training
• Recordl
*	Employee Health & Safety
•	Fines
Raw Materials
Waste Disposal
Mgml Resources
Financial Liability
Market Share
Product Quality
Employee Reitns
Public Image
Criminal Liability
Shareholder Rltns

Once a team has identified the project impacts that are less tangible but strategically
significant, it needs to assess those impacts and incorporate them into a justification package.
The following section provides guidance on some of the more common issues that businesses
need to address.
The Assessment Map provides a general framework for thinking about the issues on
which a pollution prevention project may have an impact. This section explains why these
issues may be important and suggests ways that a project team can focus attention on them
to emphasize their significance. Some of these issues, such as "pubic image", tend to be
straightforward: the impact of a P2 project is presumed to be positive, and the question is 'to
what extent and how quickly?*. Other issues, such as product quality, arise as (possibly)
unintended consequences of the effort to reduce waste. In these cases pollution prevention
changes may have either a positive or a negative impact. After determining the nature of the
impact, the project team must figure out how best to communicate fully the positive benefits,
or it must consider ways to restructure the project to minimize unwanted consequences.
• Product quality: Customers are increasingly demanding environmentally-friendly
products yet are rarely willing to surrender price or quality levels to achieve their
demands. A pollution prevention project that is detrimental to product quality (e.g.,
through inferior material substitution or process changes that fail to meet design
specifications) will rapidly translate into lost sales or into increased costs of rework and
downtime. Alternatively, a pollution prevention initiative may improve quality and/or
enable a product to be marketed as 'green', a benefit that may engender greater market
acceptance and boost sales. Concerns about impacts on quality need to be addressed
upfront by:
>	conducting sufficient engineering review and testing before specifying equipment or
changing a product or process;
>	securing guarantees by the vendor, perhaps in the form of a performance bond;
>	planning for incremental ramp-up of production using the new process or new
>	securing customer feedback to determine what impact changes may have on consumer
A project proposal should include a section on product quality that outlines possible
concerns and describes in detail the measures that a team has taken to ensure that these
concerns have been anticipated, addressed and resolved. Almost nothing will kill a project
faster than the fear that it may harm product quality, and the justification package must
allay those fears as well as possible.

•	Impact on Productivity/Capacity: Process changes resulting from the implementation of
a pollution prevention project could potentially increase or decrease the productivity
and/or effective capacity of a plant. For example, an aqueous degreaser may reduce
solvent use but may require a longer cycle time to remove contaminants effectively,
thereby increasing throughput time and lowering productivity. On the other hand,
installing new equipment to add a parallel process line might both reduce solvent use
required for product changeovers and increase productive capacity. As with determining
effects on product quality, engineering review of new process specifications is crucial to
assess a project's effect on production. Thorough review should enable the impact on
productivity/capacity to be estimated with sufficient accuracy to permit its inclusion in
the financial analysis. If this is not possible, the potential impacts should be explored and
described qualitatively, perhaps using sensitivity analysis to quantify their effect.
•	Public image: The importance of an environmentally-correct image has greatly increased
in the past decade, and many companies now tout their 'green' credentials. (Recently, Sun
Oil Company launched a major ad campaign to publicize its signing of the CERES
(formerly Valdez) principles, the first Fortune 500 company to do so.) While a good
public image is important for its own intangible reasons, its value is increasing as the link
between public image and financial success becomes stronger. As discussed below, a
company's image now often has a direct bearing on the market acceptance of its products.
Image can be especially important to a company which has suffered a poor environmental
reputation. For example, Polaroid, which had received a lot of negative publicity for its
toxic discharges, now promotes its pro-active strategies of pollution prevention and
recycling. The company has received widespread recognition for many of its innovative
environmental programs.
Although almost any pollution prevention project can bolster the environmental record of
a business, one that directly addresses a publicly-recognized problem can be especially
valuable. If a proposed P2 project eliminates a source of bad publicity, such as the
discharge of effluent that discolors a waterway, the pubic relations benefits of the project
should be strongly emphasized in the justification package. To demonstrate the impact
on this issue, a team might include a brief description of a similar company that used its
environmental activities to strengthen its image and improve its financial position.
•	Market share (I.e.. consumer acceptance): Numerous surveys have documented the trend
of'green' consumerism, and companies have responded by emphasizing environmental
attributes in new product development. The growing inclination of consumers to buy
'green' refers to purchases of products or services that are environmentally-benign or that
are offered by companies with good environmental records. A pollution prevention
project that 'creates' a green process or product may have a. significant impact on sales,
depending upon customer demand. A project justification proposal could promote the
value of this factor by including survey data related to the particular industry or product
type. Additionally the report could show how a specific product or company, in a
similar situation or industry, either gained market share after emphasizing its 'green'
qualities or lost market share due to a poor environmental record. To further demonstrate
the significance of this issue, it would be valuable to develop computer-generated

scenarios, based on experiences of similar companies, to show how even small impacts on
market share can generate large returns on the bottom line .
•	Stakeholder relations: The term "stakeholders" can broadly include almost any person,
group or organization with which a business has dealings: employees, stockholders,
lending institutions, customers, suppliers, surrounding communities and others. Though
small, privately-held firms may not be as susceptible to shareholder pressure as large
corporations, they may be equally or more sensitive to the interests of such other
stakeholders as the surrounding community and employees. For businesses in small
towns where they are one of the major employers, many of these interests overlap. The
benefits of a pollution prevention project may affect relationships with these groups in
different specific ways, as detailed in some of the other issues (pubic image, employee
health and safety, market share). Generally, the value of being recognized as a "good
neighbor" is one that most people recognize as having increased importance.
•	Employee Health and Safety: Improving working conditions can have both substantial
short and long-term benefits, including lower worker compensation rates due to safer
conditions, lower health care payments, increased productivity and reduced OSHA
regulatory oversight. If a project enables immediate reductions in insurance or OSHA
regulations, those projections can be incorporated into the financial analysis.
Additionally, one can use this issue to build support for a project by citing the gains other
companies have realized by improving employee health and safety. Combining
equipment/process specifications with occupational health & safety data can provide
documentation of expected improvements in working conditions.
•	Pro-active environmental strategy: Environmental regulation shows a clear trend toward
increasingly stringent discharge limitations for contaminants in air emissions, wastewater,
and hazardous waste. Companies that incorporate these anticipated tougher levels in
their strategic planning will have advantages over those that are content to comply with
current standards. P2 projects have the ability, inherent in their prevention philosophy,
to position a company to meet or surpass projected future toxic use and discharge limits.
A strong argument for a pollution prevention project is its capacity to alleviate such
unknown factors as purchase price, disposal costs, or new health issues, that accompany
the use of substances known to be environmentally damaging.
Financial liability: The potential financial liability from using and disposing of
hazardous substances is virtually unlimited. One of the greatest benefits of a pollution
prevention strategy is its capacity to reduced exposure to potential liability: Activities and
other sources of financial liability that firms have encountered are:
>	Disposal	> Storage
>	Transportation	> Real property damage
>	Civil actions	> Toxic tort suits
>	_ Economic loss (from remediation)	> Fines/penalties

Although reduction of liability can be one of the most significant advantages of a
pollution prevention strategy, this benefit is usually difficult to characterize and thus may be
'underweighted' in a project assessment. The monetary estimation of potential liability is
problematic both because of the difficulty of making the estimates realistic and reliable and
because of disclosure requirements by The Securities and Exchange Commission (SEC) and
the Financial Accounting Standards Board (FASB). Those agencies may require companies to
establish accounting reserves to cover liabilities that are expressed in monetary terms. For
example, the consequences of such requirements dissuaded General Electric Corporation from
fully implementing a detailed liability model that h had developed for use in-house.
Companies, environmental consultants, the academic community and others have
developed a variety of methods that attempt to characterize potential liability risk. These
range from precise projections of financial exposure based on historical data of actual
occurrences, such as the model developed by GE, to current work at a university that
attempts to use 'fuzzy logic' to translate mangers' qualitative responses into quantitative
assessments. As no method has gained wide acceptance and many are complex and require
considerable time and expertise to employ, it is beyond the scope of this manual to describe
their design or use in detail. (For further information on this subject see the References
section of the Appendix.) However, even without a quantitative projection, it is possible for
a pollution prevention project team to develop a fairly concrete picture of the nature and
potential consequences of specific sources of liability.
Liability Risk Assessment
The following steps provides a framework for thinking about liability risk and
balances the need for accurate information with the cost of conducting an analysis:
(1)	Draft process flow diagram for current process, marking potential liability sources;
(2)	Arrange liability sources into risk groups;
(3)	List various exposure events for each risk group;
(4)	Assign probabilities for each event;
(5)	Estimate severity of event;
(6)	Assign high, medium, low degree of risk to overall liability.
To assemble information about sources of risk and to define risk groups, we suggest using a
table such as the one illustrated in Figure 4.3. The types and sources of pollution and waste
are listed along the vertical axis and the activities associated with use and disposal along the
horizontal axis. The categories listed here are examples onlv: every company and process
would have its own. The intersection of these categories defines a 'risk group".

Financial and managerial accounting employ many specific terms in their practice. Although
many of these remain precisely defined, some acquire several different meanings as they come
to be used in a variety of contexts. The advent of "environmental accounting" has exacerbated
this trend, creating widely variant definitions of such terms as "full-cost", "life-cycle" and
"cost-benefit". This Glossary & Terminology appendix presents definitions and explanations
of some of the most common terms used in accounting.
Accounting Rate of Return - The rate of return of an investment, over its lifetime, based on
the net income that the project generates. Average net income of the project divided by the
initial investment.
Annuity - A level stream of equal dollar payments that exists for a fixed period of time.
Depreciation - A non-cash expense that is used to allocate the cost of a piece of equipment
over its economic lifetime. The only impact of depreciation is to reduce the taxable income of
the firm.
Depreciation Tax Shield - This represents the tax savings that are created each year, in a
profitable firm, due to depreciation. The depreciation tax shield is calculated by multiplying
the annual depreciation figure by the firm's tax rate.
Discount Rate - The interest rate used to discount future cash flows to their present values.
This represents the rate of return that could be earned by investing in a comparable risk
project instead of the project being considered.
Future Value - Value of a sum of money at a future date when it is grown at a periodic
interest rate.
Hurdle Rate - The minimum rate of return that a project must generate in order to be
accepted by the firm. Projects that provide a rate of return below this rate will not be
undertaken by the firm.
Incremental Cash Flaws - The difference of a firm's cash flows with and without a project.
Only cash flows that change with a particular project are relevant to the analysis.
Internal Rate of Return - The discount rate at which the net present value of an investment
is zero. The IRR of a project can be compared to a firm's hurdle rate to determine economic
attractiveness. The General IRR rule is:
If IRR > hurdle rate then accept project
If IRR < hurdle rate then reject project.

Net Present Value - The initial investment of a project subtracted from the present value of
future cash flows, discounted at the opportunity cost of capital. NPV shows how much
value will be created (destroyed) if a project is undertaken by the firm. The general NPV
Rule is:
If NPV > 0 then accept the project
If NPV < 0 then reject the project
Nominal Cash Flows - A cash flow is nominal if it represents the actual dollars that are
expected received (paid out) in future periods.
Nominal Interest Rates - The interest rate is un-adjusted for the inflation rate, this is the
actual rate that an investment would earn. (c./Real interest rates)
Payback Period - The number of years required for a firm to recover a project's initial
investment from the cash flows generated by that investment.
Present Value - The value of a future cash flow discounted at the appropriate interest rate.
Real Cash Flows - A cash flow is real if it is expressed in terms of current purchasing power.
Deflated dollars, or dollars adjusted for inflation.
Real Interest Rates - The interest rate does not include the effects of inflation. This
represents how much the purchasing power of a sum of money has increased. (c.f nominal
interest rate)
One of the most basic distinctions is between financial and managerial accounting.
• Financial Accounting describes the information that a company prepares in order to
report its financial performance and condition. If a company is privately-held, this
information is only for the benefit of the owners and for a determination of state and
federal tax liability. A publicly-owned company, however, must provide financial
information to external parties such as shareholders, creditors, suppliers, bankers,
government agencies and the general public. The form and substance of financial
statements is set and revised periodically by the Financial Accounting Standards Board
(FASB) and is codified as GAAP - generally accepted accounting principles. Financial
accounting information is presented in three types of financial statements:
>	Income statement: to report sales, expenses and income for a set period of time (e.g.,
one quarter or one year).
>	Balance sheet: to report the financial condition of a company at one point in time (a
snap-shot) - cash, receivables, inventory, debt, equity etc.

> Cash Flow statement: to report the actual flows of cash into and out of a business
during a set period of time. This statement is important because the intricacies of
accounting rules often create a large disparity between the level of income shown on
the income statement and the amount of actual cash that flows into a company.
•	Managerial Accounting: In contrast to financial accounting, managerial accounting is
intended solely for internal use and is not required by any governmental body or
regulatory agency. The objective of managerial accounting is to provide information that
enables managers to make decisions that further a company's pursuit of its strategic
business mission. Because companies operate in vastly different ways and use different
criteria to make decisions, the structure and contents of managerial accounting reports
vary greatly from company to company, even within the same industry. Although
managerial accounting traditionally has involved only financial information presented in
terms of costs, businesses are increasingly collecting, analyzing and using non-financial
operating data in conjunction with cost information to assist in managerial decision-
making. General examples of business issues for which managerial accounting information
is used includes:
~ strategic planning
~ product profitability analysis
~ operational control
~ resource utilization
~ tracking of quality
Cost information, with which we are concerned here, can be organized and presented in a
variety of ways. Conventional managerial accounting seeks to allocate all costs incurred
by an company to the products, product lines, or services produced. Costs, such as labor
and materials, which are directly attributable to the production unit, are labeled direct
costs. Many other costs, which are not easily attributable to particular products, are
lumped together into cost pools labeled 'overhead' that are then allocated to products on
the basis of a cost driver, such as labor hours or material dollars.
•	Activity Based Costing: The practice of allocating overhead cost pools on the basis of
labor hours made sense in the early days of industrial activity when labor was the major
input of a product's cost and overhead was relatively small. Today, however, in most
manufacturing companies, the labor input is dwarfed by the overhead of expensive plant
and equipment and large management, research and sales staff. Activity-based costing
(ABC) seeks to reduce the distortions to product costing caused by using an
inappropriate measure, such as labor hours, to allocate large overhead pools. The
practice attempts to attribute 'overhead' costs to products on the basis of the activities
that are actually performed in production. For example, costs related to inventory
managment might be attributed to products on the basis of the numbers of different parts
in a product. The underlying concept of activity-based costing is central to the costing of
pollution prevention projects: examining the costs of activities related to particular
products or processes.

•	Full-Cost Accounting is perhaps the term with the widest variations of use. As a strict
accounting term defined by GAAP, full cost accounting refers to the requirement to
include all costs (expenses) and revenues in the financial statements of a business. In
environmental accounting, the term denotes the practice of attributing aH costs in a direct
manner to products, production processes or services. As such it is conceptually similar
to activity-cased costing.
•	Life-Cycle Cost Analysis is now commonly used in several related but different ways.
As an environmental public policy tool, life-cycle costing refers to the effort to identify
and quantify the costs of all the components and inputs of a product throughout its
lifetime, from research and development to final dissolution. Although the state-of-the-
art of life-cycle costing is still in its infancy, this type of analysis is gaining currency in
the environmental debate as a means to compare the impacts and costs of competing
products or materials. For example, there have been several studies of the life-cycle costs
of disposable vs. cotton diapers and of polystyrene vs. paper cups.
(Modified) life-cycle costing is also a tool that companies are beginning to use to analyze
the costs of a product or service over its useful economic life, perhaps including R&D and
disposal. It is a more limited analysis than the pure form and used for different reasons.
•	Cost Benefit Analysis is a public policy tool that is used to evaluate the social costs
and benefits of a proposed regulation or project. Analysts assess policies by monetizing
the positive and negative impacts through the use of historically-derived formulae.
Although the term "cost benefit analysis" is occasionally used to refer to the capital
budgeting process, it is not in its strict sense applicable to business decision making.

IV. Case Studies and Fact

A. EP-3 Fact Sheets

a Pollution Prevention Assessment for a Manufacturer
of Starting, Lighting, and Ignition (SLI) Batteries
The amount of pollutants and waste generated by
industrial facilities has become an increasingly costly
problem for manufacturers and a significant stress on
the environment Increasingly companies are looking
for ways to reduce pollution at the source as a way of
avoiding costly treatment and reducing environmental
liability and compliance costs.
The United States Agency for International Develop-
ment (USAID) is sponsoring the Environmental Pollu-
tion Prevention Project (EP3) to transfer urban and
industrial pollution prevention expertise and informa-
tion, establish sustainable programs in developing
countries, and support efforts to improve environmen-
tal quality These objectives are achieved through
technical assistance to industry and urban institutions,
training and outreach programs, and an information
EPS's Assessment Process	
EP3 pollution prevention diagnostic assessments
consist of three phases: pre-assessment assessment,
and post-assessment. During pre-assessment, EP3 in-
country representatives determine a facility's suitabil-
ity for a pollution prevention assessment, sign memo-
randa of agreement with each facility selected, and
collect preliminary data. During assessment, a team
comprised of US. and in-country experts in both
pollution prevention and the facility's industrial
processes gathers more detailed information on the
sources of pollution, and identifies and analyzes
opportunities for reducing this pollution. Finally the
team prepares a report for the facility's management
detailing their findings and recommendations (includ-
ing cost savings, implementation costs, and payback
times). During post-assessment, the EP3 in-country
representative works with the facility to implement
the actions recommended in the report
Objectives o! this Assessment
This assessment evaluated a facility that manufac-
tures lead-acid batteries used in automobiles and
trucks. The objective of the assessment was to
identify actions that would: (1) reduce the quantity of
toxics, raw materials, and energy used in the manu-
facturing process, thereby reducing pollution and
worker exposure, (2) demonstrate the environmental
and economic value of a pollution prevention assess-
ment, and (3) improve manufacturing efficiency and
product quality.
The assessment was performed by an EP3 team
comprised of a battery production specialist and a
pollution prevention expert
Overall, the assessment identified nineteen pollution
prevention opportunities that could save over
$1,875,000 in the first 24 months for an investment of
$687,000. If implemented, these changes could reduce
employee exposure to lead dust, reduce energy and
water use per unit output reduce the amount of lead
purchased, reduce lead-contaminated wastewater,
and improve product quality.
Facility Background
This facility manufactures starting, lighting, and
ignition (SLI) batteries. Most of the facility's output is
sold domestically although about 20% is exported. The
facility operates one, two, or three 8-hour shifts
(depending upon the equipment process, and season)
and employs 220 people. In I993,_they sold 231,000
Manufacturing Process	
Facility operations can be divided into six main steps:
(1) conversion of scrap lead into cast panels, (2)
conversion of virgin lead into lead oxide powder and
paste, (3) pasting and curing of panels, (4) container
formation of batteries, (5) tank formation of batteries,
and (6) laboratory analysis and process controls as
shown in Figure l. The battery making process begins
on two parallel tracks: the facility recovers lead from
used batteries that are collected and brought to the
facility scrap lead is recycled and then cast into grids,
and virgin lead is mechanically converted into a
powdery lead oxide, which is used to make a paste.
These separate feeds merge at the grid pasting
machine where the paste is pressed into the grids.
EP3 is sponsored by the U.S. Agency for International Development.

Figure 1: Overview of Facility's Battery Manufacturing Process
Pasted plates are cured and then take one of two
paths to become battery elements: tank formation or
container formation. These processes convert the
paste into active material that will electrically charge
and discharge throughout the useful life of the
battery. In tank formation, this process takes place in
large tanks, whereas in container formation, the cured
plates are assembled and formed in the battery case
To make the lead oxide paste, lead oxide powder is
mixed with de-ionized water, sulfuric acid, and organic
expanders. One recipe makes a positive plate, while a
slightly different recipe makes a negative plate. The
pasted plates then move on a conveyor belt through a
drying oven. After pasting and drying, the plates move
into a curing chamber for about 48 hours to convert
the remaining lead into lead oxide.
In tank formation, the positive and negative plates are
immersed in tanks of low specific gravity sulfuric acid,
where electrodes pass a current through the plates. In
the positive plates,-the current converts lead sulfate
from the paste into lead oxide. In the negative plates,
the reaction converts the paste into sponge lead, a
very porous, high surface area form of elemental lead.
Container formation employs the same electrochemi-
cal process, but occurs in the plastic battery case
instead of the tank. Cured plates that are not tank
formed must be cut in half and assembled into
battery elements, which are then placed into batteries
for container formation.
After tank formation, the plates go through a washing
and drying process to remove any remaining sulfuric
acid. Overall, the plate washing process accounts for
over 60 percent of the factory's water contaminated
with lead and sulfuric acid.
Existing Pollution Problems	
At the time of the assessment, there were a number
of pollution problems at the facility including (1) waste
acid from the used batteries that are cracked to
recover lead is disposed of on site, (2) uncovered lead
slag and dust piles, (3) excessive energy use in smelt-
ing ovens, curing rooms, and the tank formation
process, and (4) excessive wastewater generation in
the grid pasting and washing processes. In addition,

Table 1: Summary of Recommended Pollution Prevention Opportunities
Unit Operation
Pollution Prevention Action
and Environmental/Product Quality Benefit
Conversion of Scrap
Lead into Cast Panels:
Cover slag and dust piles and clean smelting room
- reduces worker exposure to lead and lead dust
3 weeks
Buy temperature monitoring instrument to adjust
oven -reduces toxic emissions and slag, and
reduces energy costs
1 year
Casting Panels
Purchase improved design mold - reduces waste,
lowers energy use, and eliminates steps in the
See plate
See plate
Conversion of Virgin
Lead into Lead Oxide
Powder and Paste
Shovel spilled lead cylinders back into the
mechanical mill rather than smelting ovens -
conserves lead and energy
Purchase a liquid lead atomization mill • improves
efficiency and reduces emissions of lead oxide
To be
To be
Sell old equipment once the liquid atomization mill
is operating - recovers some of the cost of new
Pasting and Cutting
Panels: Pasting
Shovel spilled paste back into paste hopper rather
than smelting oven - reduces lead purchases,
reduces volume of wastewater, and saves energy
Increase moisture content of the paste - reduces
scrap and extends battery life
To be
Reduce the water flow to thelinishing roller on
paste machine - reduces water use and volume of
To be
Buy a moisture analysis oven • makes better lead
oxide and saves energy
Two years
Pasting and Cutting
Panels: Curing
Install racks to cure larger batches - saves energy
and extends battery life
To be
To be
Install mist sprayers, a heater, and two fans in
each curing room - improves battery quality
To be
To be
Analyze the free lead content after 12 hours of
curing - saves energy and extends battery life
To be
Pasting and Cutting
Panels: Cutting
Eliminate the cutting process • reduces scrap, and
saves lead and energy
Less than 3
Recycle drops to strap casting pot rather than
smelting oven - saves lead and energy
Container Formation
Immediately apply charge to batteries after Tilling •
improves battery performance
Tank Formation: Plate
Eliminate the process - saves water and natural
gas, reduces worker exposure to acid and lead
dust, reduces volume of wastewater, and improves
battery quality
Less than 6
Tank Formation: Plate
Washing and Drying
Stop washing all plates immediately - reduces
Laboratory Analysis and
Process Control:
Laboratory Analysis
Accurately measure individual battery cell voltage
- assures battery quality
To be
To be

over 2,500 kilograms of lead oxide paste was spilled
and fed into the smelting process each day using
virgin lead where scrap lead would suffice. Finally,
several technological problems (e.g., the outdated lead
oxide mill and lack of a moisture analysis oven)
increased raw material use and adversely affected
battery quality
Pollution Prevention
Overall, this assessment identified nineteen pollution
prevention opportunities that could address the
problems identified and produce significant economic
benefits for the facility. If implemented, these oppor-
tunities could save over $1,875,000 in the first 24
months for an investment of $687,000.
The pollution prevention strategy is premised on the
belief that addressing sources of waste and pollutants
also improves the company's economic health by
reducing operating costs and improving product
quality. In this case, product quality is increased by (1)
increasing the lead oxide particle size by buying a
liquid atomization mill, (2) increasing the moisture
content of the paste recipes, (3) increasing the curing
temperature, humidity and air circulation, (4) analyzing
the moisture content of the pasted plates on-site, at
the oven, (5) monitoring the smelting oven tempera-
ture and adjusting to the optimal level, (6) curing
larger batches of pasted plates, and (7) utilizing
cadmium sticks in the laboratory to measure cell
Table 1 lists the opportunities for pollution prevention
recommended for the facility and presents the
environmental and product quality benefits, imple-
mentation cost, savings, and payback time for each.
Because the quantities of pollution generated by the
facility and possible pollution prevention levels
depend on the production level of the facility, all
values should be considered in that context
Additional Recommendation
There is an additional opportunity to prevent pollution
and conserve raw materials in the battery recycling
process. Before cracking the battery case, workers
could pour the acid into a large plastic plating tank.
The acid could be recycled (possibly through ion
exchange) and returned to the production process,
replacing purchases of high concentration acid.
Evaluating Performance	
EP3 has proposed a methodology for measuring and
tracking pollution prevention performance. The
approach uses simple but critical ratios to compare
data among facilities in the same industrial sector.
This assessment identified four critical ratios, as
shown in Table 2. The Assessment Team obtained best
industrial performance (BIP) values for these ratios,
and found that each of this facility's current values
were significantly above the BIP values. The facility
should be able to reduce its ratios and come closer to
the BIPs by implementing the pollution prevention
options listed in Table l.
Table 2: Critical Performance Ratios for
Battery Manufacturing
Current Ratio
at Facility
Kilograms of virgin
lead per battery unit
Kilograms of lead-
alloy feed per
battery unit
Liters of water used
per battery unit
Kilowatt-hours (kwh)
and cubic meters
(m3) of natural gas
per battery unit
7 kwh and
5 m3
10.7 kwh
and 6.6 m3
Implementation Status
The facility has already implemented many of the
low/no cost recommendations, including covering
recycled lead piles, recycling dropped virgin lead into
the lead oxide mill rather than into the smelter,
recycling waste paste into the hopper rather than
sending it to the smelter, and maintaining optimal
temperature and humidity in the curing room. In
addition, the facility has begun to implement several
capital intensive changes. For example, it has placed
an order for boost charging equipment ($100,000) and
requested price quotes for a liquid lead atomization
mill ($240,000).

B. Other Industry Fact

Environmental Pollution
Prevention Project
Distributed by the
EP3 Clearinghouse
1530 Wilson Boulevard
Suite 900
Arlington. VA 22209-2406. USA
Fax: 703/351-6166
United States
Environmental Protection
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/S-92/039 Oct. 1992
Waste Reduction Activities and Options for a
Manufacturer of Finished Leather
Patrick Eyraud and Daniel J. Watts*
The U.S. Environmental Protection Agency (EPA) funded a
project with the New Jersey Department of Environmental
Protection and Energy (NJDEPE) to assist in conducting waste
minimization assessments at 30 small- to medium-sized busi-
nesses in the state of New Jersey. One of the sites selected
was a manufacturer of finished leather. A site visit was made in
1990 during which several opportunities for waste minimization
were identified. Recommendations included 1) changeover to
water-based coatings; 2) installation of a solvent recovery/
reuse capability; 3) use of a hand pump to reduce spillage
during transfer and physical layout considerations to reduce
the distances materials must be moved; 4) reducing the volume
of the container for test mixes; 5) improvements to the computer-
controlled spray-coating operation to reduce overspray; and 6)
the use of covers over formulated coating mixtures to reduce
air emissions. Implementation of the identified waste minimiza-
tion opportunities was not part of the program. Percent waste
reduction, net annual savings, implementation costs and pay-
back periods were estimated.
This Research Brief was developed by the Principal Investiga-
tors and EPA's Risk Reduction Engineering Laboratory in Cin-
cinnati, OH, to announce key findings of this completed as-
The environmental issues facing industry today have expanded
considerably beyond traditional concerns. Wastewater, air
emissions, potential soil and groundwater contamination, solid
waste disposal, and employee health and safety have become
increasingly important concerns. The management and dis-
* New Jersey Institute of Technology. Newark, NJ 07102
posal of hazardous substances, including both process-related
wastes and residues from waste treatment, receive significant
attention because of regulation and economics.
As environmental issues have become more complex, the
strategies for waste management and control have become
more systematic and integrated. The positive role of waste
minimization and pollution prevention within industrial operations
at each stage of product life is recognized throughout the
world. An ideal goal is to manufacture products while generat-
ing the least amount of waste possible.
The Hazardous Waste Advisement Program (HWAP) of the
Division of Hazardous Waste Management, NJDEPE, is pursu-
ing the goals of waste minimization awareness and program
implementation in the state. HWAP, with the help of an EPA
grant from the Risk Reduction Engineering Laboratory, con-
ducted an Assessment of Reduction and Recycling Opportuni-
ties for Hazardous Waste (ARROW) project. ARROW was
designed to assess waste minimization potential across a
broad range of New Jersey industries. The project targeted 30
sites to perform waste minimization assessments following the
approach outlined in EPA's Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003). Under contract to
NJDEPE. the Hazardous Substance Management Research
Center at NJIT assisted in conducting the assessments. This
research brief presents an assessment of a manufacturer of
finished leather (1 of the 30 assessments performed) and
provides recommendations for waste minimization options re-
sulting from the assessment
Methodology of Assessments
The assessment process was coordinated by a team of techni-
cal staff from NJIT with experience in process operations,
Printed on Recycled Paper

basic chemistry, and environmental concerns and needs. Be-
cause the EPA waste minimization manual is designed to be
primarily applied by the inhouse staff of the facility, the degree
of involvement of the NJIT team varied according to the ease
with which the facility staff could apply the manual. In some
cases, MJITs role was to provide advice. In others, NJIT
conducted essentially the entire evaluation.
The goal of the project was to encourage participation in the
assessment process by management and staff at the facility.
To do this, the participants were encouraged to proceed through
the organizational steps outlined in the manual. These steps
can be summarized as follows:
•	Obtaining coiporate commitment to a waste minimization
•	Organizing a task force or similar group to carry out the
•	Developing a policy statement regarding waste minimiza-
tion for issuance by corporate management
•	Establishing tentative waste reduction goals to be achieved
by the program
•	Identifying waste-generating sites and processes
•	Conducting a detailed site inspection
•	Developing a list of options which may lead to the waste
reduction goal
•	Formally analyzing the feasibility of the various options
•	Measuring the effectiveness of the options and continuing
the assessment.
Not every facility was able to follow these steps as presented.
In each case, however, the identification of waste-generating
sites and processes, detailed site inspections, and development
of options was carried out. Frequently, it was necessary for a
high degree of involvement by NJIT to accomplish these steps.
Two common reasons for needing outside participation were a
shortage of technical staff within the company and a need to
develop an agenda for technical action before corporate com-
mitment and policy statements could be obtained.
It was not a goal of the ARROW project to participate in the
feasibility analysis or implementation steps. However, NJIT
offered to provide advice for feasibility analysis if requested.
In each case, the NJIT team made several site visits to the
facility. Initially, visits were made to explain the EPA manual
and to encourage the facility through the organizational stages.
If delays and complications developed, the team offered assis-
tance in the technical review, inspections, and option develop-
Facility Background
The plant produces finished leathers which are sold to manu-
facturers of leather goods such as handbags, belts, shoes, and
other items. The operation of the plant varies according to
customer demand. Many different colors, textures, and designs
must be incorporated into the product to meet varying cus-
tomer requirements, forcing the operation of several special
production steps on an irregular basis. The facility formerly
tanned raw hides, but that process has been phased out as a
result of changing supply and market conditions.
Manufacturing Process
This facility receives tanned leather from various sources and
transforms it into a product of higher commercial value by
applying various coatings and other surface modifications to
make it more usable and appropriate for finished consumer
products. The raw materials include, in addition to the leather
itself, various water- and solvent-based coatings as well aa
some specialized colorants and other surface modification
products. The solvents in the coatings typically are aromatic
and aliphatic hydrocarbons, esters, and alcohols.
The following processes are carried out in the facility but not
every hide necessarily receives each finishing process.
•	Back Coating
•	Base Coating
•	Plating Top
•	Tipping (hand made)
•	Color Top
•	Clear top
A typical hide in the manufacturing process might receive the
following finishing steps.
Newly received hides are prepared for finishing by washing,
retanning if necessary, and drying. The aqueous wastes from
these steps are sent to the POTW with regular monitoring to
assure compliance.
Some hides undergo surface modification by mechanical buff-
ing. The resulting dust is classified as a hazardous waste and
is disposed of offsite.
The back coating step applies essentially the final finish to the
back of the leather while the base coating of the smooth side
serves as the primer for additional finishes to be applied. The
coatings are applied using an automated spray system. The
facility has shifted largely to water-based coating for these
steps resulting in a significant decrease in solvent use. Ar
over-spray is captured by a water-screen or by filters an
disposed of offsite.
The next coating steps are accomplished using solvent-based
materials. No satisfactory non-solvent based coatings have yet
been identified for these finishing steps. The applied finishes
are thermally dried with venting of solvent vapors to the atmo-
The final steps in the manufacturing process are ironing, grad-
ing, measuring, and shipping—operations which are not sig-
nificant waste-generating activities.
Existing Waste Management Activities
The facflity has shifted to the use of water-based coatings where
posstote. Moreover, the technical staff continues to evaluate new
commercial reduced-solvent products in order to make further re-
ductions. An optical/computer interfaced system has been used to
determine the shape and position of each hide presented for coating
which is used to control the automated spray coating system,
resulting in significant reduction of overspray.
Waste Minimization Opportunities
The type of waste currently generated by the plant, the source of the
waste, the quantity of the waste, and the annual treatment and
disposal costs (where known and available) are given in Table 1.
Table 2 presents the opportunities for pollution prevention
which were identified during the assessment. The type o'
waste, the minimization opportunity, and the possible wast

reductions, are presented in the table. When available or esti-
mable, the associated saving, and implementation costs along
with payback times are also given. However, because the
feasibility analysis was to be earned out by the staff of the
facility, that information is not always readily available.
Additional Options Identified
In addition to the options previously discussed two other options
were suggested. It was observed that the wooden pallets and
cardboard used for shipping hides to the facility might have
increased value if recycled. Second, the future use of a spray
coating system based upon supercritical carbon dioxide as a
solvent/carrier was identified. However, such a system depends
not only on the availability of the hardware, but also on the
manufacture of coatings compatible with the spray system and
capable of providing the required quality for the finished leather.
Such coatings are not presently available.
Regulatory Implications
The significant regulatory issue at a facility such as this is the
impending requirement for more efficient air emission control
practices. This concern is driving the interest in pollution pre-
vention. Unfortunately, the apparent best solution—changing to
water based coatings—is not technically feasible. It is unknown
if the perhaps next best solution—solvent capture and recovery
from the process air emissions—would be acceptable to the
regulatory authorities in light of better known thermal oxidation
systems which have less source reduction potential. If a facility
has capital resources to install only one system, it is uncertain
what position and role a regulatory authority will take.
This Research Brief summarizes a part of the work done under
cooperative Agreement No. CR-815165 by the New Jersey
Institute of Technology under the sponsorship of the New
Jersey Department of Environmental Protection and Energy
and the U.S. Environmental Protection Agency. The EPA Project
Officer was Mary Ann Curran. She can be reached at:
Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
Table 1. Summary of Current Waste Generation
Waste Generated
Source of Waste
Annual Quantity
Washing Waters
Buffing Dust
Evaporated Coating
Solvents and Coatings
Cleaning of	130,000gal
incoming hides
Mechanical abrasion	<100 lb
of hide surface
Application of back	130 tons
coating, base coating,
plating top, color top,
and clear top to hides.
Most solvent evaporation
occurs during oven assisted
drying. Some loss also
occurs as a result of
spills and leaks during
material mixing and trans-
Excess coatings and solvent	12,300 gal
from equipment cleaning
These are either
fugitive emissions
or regulated emissions
to the atmosphere, and
therefore have no management
costs except the loss of
potential recovery value.
"US. QwimmU Priming Office; 1992— Mt-OOKOOK

Table 2. Summary of Waste Minimization Opportunities
Waste Generated Minimization Opportunity
Annual Waste Reduction	Net Implementation Payback
Quantity	Percent Annual Savings Cost	Years'
Buffing Dust
Evaporated Solvent
Solvents and
Evaporated Solvent
Sale for beneficial reuse
in resin-based composite
Continue changeover to water
based coatings subject to
development of satisfactory
materials by coating manu-
Prepare test formulations in
smaller quantities.
Reprogram automated spray
coating equipment to compensate
for required angle spraying.
1J tons
The savings will come from avoided treatment
from an air emissions control system not yet
installed The facility is clearly dependent
upon the coating promotion industry and can-
not make progress in this area atone.
up to 65% when
angle spraying is
1Z7tons 9.7%
$25,000	$5,000	0.2
More savings will result from avoided treatment costs
from the new control system not yet installed.
Install covers on coating
reservoir containers during
spray coating operations.
variable depending
upon solvent
5001b	0J%
Install solvent capture
system allowing capture
and reuse. Possibilities
include a carbon system
with steam distillation
regeneration capability
permitting recovery of
the captured solvent
Distillation and reuse
of the solvent is possible
if the solvent mixture is
not too complex. Difficult
mixtures may have to be distilled
offsite where more efficient
columns are available.
up to 90%
depending upon
type of solvent
117 tons
(A system of this type could serve as the emission
control device assuming that the regulatory
authority would approve it instead of more usual
Savings result from reduced raw material, and treatment and disposal costs when implementing each minimization opportunity independently.
United States
Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
Official Business
Penalty for Private Use
PERMIT No. 6-35

United States	Risk Reduction
Environmental Protection	Engineering Laboratory
Agency	Cincinnati OH 45268
Research and Development	EPA/600/S-92/022 May 1992
Waste Minimization Assessment for a Manufacturer Producing
Treated Wood Products
F. William Kirsch and J. Clifford Maginn, Jr.'
The U.S. Environmental Protection Agency (EPA) has funded
a pilot project to assist small- and medium-size manufacturers
who want to minimize their generation of hazardous waste but
who lack the expertise to do so. Waste Minimization Assess-
ment Centers (WMACs) were established at selected universi-
ties and procedures were adapted from the EPA Waste Minimi-
zation Opportunity Assessment Manual (EPA/625^7-88/003, July
1988). The WMAC team at Colorado State University per-
formed an assessment at a plant producing treated wood
products—approximately 1,700,000 ft Vyr. Railroad crossties
and poles are treated with creosote in pressure cylinders to
increase their serviceability under conditions that promote de-
cay, weathering, insect destruction, or exposure to fire. Lum-
ber is treated by Wolmanizing, a closed loop process in which
a 2% chromated copper arsenate solution is used for treatment
in a pressure cylinder. The team's report, detailing findings
and recommendations, indicated that most waste was gener-
ated in the creosote treatment process, and also that cost
savings could be obtained by arranging an exchange of accu-
mulated bark and wood chips with others who use wood scrap
as a raw material.
This Research Brief was developed by the principal investiga-
tors and EPA's Risk Reduction Engineering Laboratory, Cincin-
nati, OH, to announce key findings of an ongoing research
project that is fully documented in a separate report of the
same title available from the authors.
* University C#y Science Center. PNIade*>toa, PA 19104
The amount of hazardous waste generated by industrial plants
has become an increasingly costly problem for manufacturers
and an additional stress on the environment One solution to
the problem of hazardous waste is to reduce or eliminate the
waste at its source.
University City Science Center (Philadelphia. PA) has begun a
pilot project to assist small- and medium-size manufacturers
who want to minimize their formation of hazardous waste but
who lack the in-house expertise to do so. Under agreement
with EPA's Risk Reduction Engineering Laboratory, the Sci-
ence Center has established three WMACs. This assessment
was done by engineering faculty and students at Colorado
State University's (Fort Collins) WMAC. The assessment teams
have considerable direct experience with process operations in
manufacturing plants and also have the knowledge and skills
needed to minimize hazardous waste generation.
The waste minimization assessments are done for small- and
medium-size manufacturers at no out-of-pocket cost to the
client. To qualify for the assessment, each client must fall
within Standard Industrial Classification Code 20-39, have gross
annual sales not exceeding $50 million, employ no more than
500 persons, and lack in-house expertise in waste minimiza-
Envtronmeital Pollution
PrgwiUun Project
Distributed by tbe
EP3 Clearinghouse
1330 Wilson Boulevard
Suite 900
Arlington. VA 22209-2406. USA
Fax: 703/351-6166
Printed on Recycled Paper

The potential benefits of the pilot project include mnimaation
of the amount of waste generated by manufacturers, reduced
waste treatment and disposal costs for participating plants,
valuable experience for graduate and undergraduate students
who participate in the program, and a cleaner environment
without more regulations a/wf higher costs for manufacturers.
Methodology of Assessments
The waste minimization assessments require several site visits
to each client served. In general, the WMACs follow the
procedures outlined in the EPA Waste Minimization Opportu-
nely Assessment Manual (EPA'625/7-88/003, July 1988). The
WMA.C stglf locates the sources of hazardous waste in the
plant and identifies the current disposal or treatment methods
and their associated costs. They then identity and analyze a
variety of ways to reduce or eliminate the waste. Specific
measures to achieve that goal are recommended and the
essential supporting technological and economic information is
developed. Finally, a confidential report that details the WMACs
lirtdngs and recommendations {including cost savings, imple-
mentation costs, and payback limes) is prepared for Bach
Plant Background
The plant produces treated wood products. It operates 8,760
hr/yr to process approximately 1,700,000 fl *fyr of wood.
Manufacturing Process
The plant treats crassties and poles wfth creosote and No. 6 oil
in heated pressure cylinders. Lumber is treated with 2%
chromated capper arsenate solution in a pressure cylinder.
The raw materials used are the wood products, creosote. Nc. 6
oil, and chromated copper arsenate. Steam is used for clean-
ing the surface of the wood in the creosote treatment cylinders,
and ozone is used to destroy phenols in the steam conden-
The following steps are involved in treating the wood products;
•	Crossties and poles are trimmed on the ends and
stacked on rail trams which are pushed into a pres-
sure treatment cylinder.
•	A heated mixture of 50% (vfa) creosote and No. 6 oil
is pumped into the cylinder and pressured to lores the
liquids into the wood cells.
•	The liquid is drained from the cylinder and held lor re-
•	The cylinder is Hooded with steam to clean excess
creosote and oil from the surface ol the wood. A
vacuum is drawn on the cylinder to enhance removal
of the liquid from the wood and the cylinder.
•	Steam condensate drains to a blowdown tank. Re-
sidual creosote and oil that drains when the cylinder is
opened is pumped to the blowdown tank. The creo-
sote is separated Horn the condensate and held for
These steps are involved in treating lumber.
¦ lumber is stacked on rail trams which are pushed into
a pressure treatment cylinder.
•	A closed-loop Wolmanizing process with 2% chromated
copper arsenate is used for treatment. The cylinder is
pressurized to 125 psig.
•	Solution drained from foe cyinder is held for re-use.
Steam condensate from creosote treatment is treated with a
flooculant to settle contained creosote, and the pH is adjusted
to 3.6 • 4.0. An ozone treatment is used to break down
phenols in the steam condensate before it is tischarged as
industrial wastewater. Creosote wastes are also generated
from periodic steam cleaning ot the treatment cylinders. No
steam is used in deaning the Wolmanizing cylinders. Accumu-
lated waste containing chromated copper arsenate is disposed
of as hazardous waste.
Existing Waste Management Practices
•	Cylindrical tanks holding creosote and chromated cap-
per arsenate have been letted with conical bottoms lor
accumulation of sludge, minimizing the need lor peri-
odic cleaning.
•	The Wolmanizing pressure cylinder does not require
steam cleaning, lessening the quantity of contami-
nated waste.
•	Storage tante are heated to maintain proper viscosity
and reduce sludge formation.
Waste Minimization Opportunities
The type of waste currently generated by the plant, the source
ol the waste, the quantity of the waste, and the annual man*
agement costs are given in Table i.
Table 2 shows the opportunities tor waste minimization that fr
WMAC team recommended for the plant The type of wafi
the minimization opportunity, the possbte waste reduction am*
associated savings, and the implementation cost along with the
payback time are given in the table. The quantities of hazard-
ous waste currently generated by the plant and possible waste
reduction depend on Ihe production level ot the plant All
values should be considered in lhat context
Additional Recommendations
In addition to the opportunities recommended and analyzed by
the WMAC team, three additional measures were considered.
These measures were not analyzed completely because of
insufficient data or low projected savings. Since one or more
of these approaches to waste reduction may, however, in-
crease in attractiveness with changing conditions fn tire plant,
they were brought to ihe plant's attention for future consider-
•	Use steam condensate trom creosote treatment as
boiler leedwatsr.
•	CoBect creosote drainage generated when the cylin-
ders are opened lor removal of crossties and poles.
•	Preclean the crossties and poles before treat me it to
reduce the quantity of creosote sludge generated wtien
the cylinders are cleaned.
This research brief summarizes a part of the work done under
Cooperative Agreement No. CR-814903 by the University City
Science Center under the sponsorship of the U.S. Environmen-
tal Protection Agency. The EPA Project Officer was Emma
Lou George.

Table 1. Summary of Currant Waste Generation
Waste Generated	Source of Waste	Annual Quantity	Annual Waste
Generated	Management Cost
Spent chromated copper
arsenate solution
Residual solution coBectad when cleaning
the Wolmanizing pressure cylinder used for
treatment of lumber is ttsposed of as
hazardous waste.
280 gal
Water and creosote mixture
Steam condensate from cleaning of creosote-treated
crossties and poles to remove excess creosote is
treated with a floccutani settled and decanted,
treated with ozone and caustic soda, and
discharged as industrial wastewater.
720,000 gal
Creosote sludge
Cleaning of the creosote treatment cylinders
results in a creosote sludge. Part of the
sludge is shipped for use as boiler fuel,
and the remainder is disposed of as
hazardous waste.
16,550 gal
3ark and wood chips
Chips, bark, and wood trimmings are stored
in an open area on leased property awaiting
9,750 yd>
Table i Summary of Recommended Waste Minimization Opportunities
Waste	Annual Waste Reduction	Net Annual Implementation Payback
Generated Minimization Opportunity	Quantity	Percent	Savings Coat	Yean
Bark and wood Arrange a waste	9,750 yd'	100	t1£00	0	0
exchange with
others who use
wood scraps as
raw material.
~da government hunting omcc: mi -

United States
Environmental Protection
Official Business
Penalty for Private Use $300
Center for Environmental
Research Information
Cincinnati, OH 45268

pan	Envlronmeital PelluUon
prevention Project
Distributed by the
EP3 Qearinghouse
1530 Wilson Boulevard
Suite 900
Arlington. VA 22209-2406. USA
Fax: 703/351-6166
United States	Risk Reduction
Environmental Protection	Engineering Laboratory
Agency	Cincinnati, OH 45268
Research and Development	EPA/600/S-92/030 Sept. 1992
Waste Minimization Assessment for a
Manufacturer of Finished Metal Components
Harry W. Edwards and Michael F. Kostrzewa'
F. William Kirsch and J. Clifford Maginn"
The U.S. Environmental Protection Agency (EPA) has funded
a pilot project to assist small- and medium-size manufacturers
who want to minimize their generation of waste but who lack
the expertise to do so. Waste Minimization Assessment Centers
(WMACs) were established at selected universities and proce-
dures were adapted from the EPA Waste Minimization Oppor-
tunity Assessment Manual (EPA/625/7-88/003, July 1988). The
WMAC team at Colorado State University performed an as-
sessment at a plant manufacturing finished metal components
— approximately 260,000 sq ftfyr. Customer-specified coatings
and surface treatments are applied to prefabricated aluminum
and stainless steel parts. Aluminum parts may be finished by
hard-coat or soft-coat anodizing, and chromate conversion
coating. Stainless steel parts are finished by surface passivation.
Parts are also processed for surface inspection using a fluo-
rescent dye and ultraviolet light The team's report, detailing
findings and recommendations, indicated that most waste was
generated in the aluminum anodizing process, and that the
greatest savings could be obtained by using hot deionized
water instead of nickel acetate solution to seal pores in the
aluminum oxide coating applied by anodizing.
This Research Brief was developed by the principal investiga-
tors and EPA's Risk Reduction Engineering Laboratory, Cin-
cinnati, OH, to announce key findings of an ongoing research
project that is fully documented in a separate report of the
same title available from University City Science Center.
The amount of waste generated by industrial plants has be-
come an increasingly costly problem for manufacturers and an
' Colorado State University, Department of Mechanical Engineering
" University City Science Center. Philadelphia. PA
additional stress on the environment One solution to the
problem of waste is to reduce or eliminate the waste at its
University City Science Center (Philadelphia, PA) has begun a
pilot project to assist small- and medium-size manufacturers
who want to minimize their formation of hazardous waste but
who lack the inhouse expertise to do so. Under agreement
with EPA's Risk Reduction Engineering Laboratory, the Science
Center has established three WMACs. This assessment was
done by engineering faculty and students at Colorado State
University's (Fort Collins) WMAC. The assessment teams have
considerable direct experience with process operations in
manufacturing plants and also have the knowledge and skills
needed to minimize waste generation.
The waste minimization assessments are done for small- and
medium-size manufacturers at no out-of-pocket cost to the
client. To qualify for the assessment each dient must fall
within Standard Industrial Classification Code 20-39, have gross
annual sales not exceeding $75 million, employ no more than
500 persons, and lack inhouse expertise in waste minimization.
The potential benefits of the pilot project include minimization
of the amount of waste generated by manufacturers, reduced
waste treatment and disposal costs for participating plants,
valuable experience for graduate and undergraduate students
who participate in the program, and a cleaner environment
without more regulations and higher costs for manufacturers.
Methodology of Assessments
The waste minimization assessments require several site visits
to each client served. In general, the WMACs follow the pro-
cedures outlined in the EPA Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003, July 1988). The
Printed on Recycled Paper

WMAC staff locate the sources of waste in the plant and
identify the current disposal or treatment methods and their
associated costs. They then identify and analyze a variety of
ways to reduce or eliminate the waste. Specific measures to
achieve that goal are recommended and the essential supporting
technological and economic information is developed. Finally,
a confidential report that details the WMAC's findings and
recommendations (including cost savings, implementation costs,
and payback times) is prepared for each client.
Plant Background
The plant is a metal-finishing job shop that applies coatings
and surface treatments to prefabricated metal parts. The plant
operates 2.448 hr/yr to produce approximately 280,000 sq ft of
finished metal parts.
Manufacturing Process
This plant does hard-coat and soft-coat anodizing, chromate
conversion coating, and surface inspection of aluminum parts.
Processing of stainless steel parts involves surface passivation,
surface inspection, or both. The raw materials used include
aluminum cleaner, NaOH aluminum etch, nitric/hydrofluoric (HF)
acid deoxidizer, sulfuric acid, dyes, nickel acetate, sodium
dichromate, chromate conversion coatings, nitric acid, hy-
drofluoric acid, oil-base penetrant, developer, water washable
penetrant, and hydrophilic emulsifier.
The following steps are carried out in the surface finishir":
•	The aluminum anodizing line involves afltaline cleaning
and etching, acidic deoxidizing to remove smut left after
etching, anodizing in an electrolytic solution of sulfuric
acid, dyeing, and sealing the aluminum oxide layer with
aqueous nickel acetate.
•	Chromate conversion coating of aluminum involves alka-
line cleaning and etching, acidic deoxidizing, clear or gold-
colored chromate conversion coating, and rinsing in debn-
ized water.
•	For stainless steel passivation, parts are degreased, etched,
and immersed in a passivating acid solution.
•	For surface inspection, parts are first degreased and etched.
A fluorescent dye is then applied and the surface is illumi-
nated with ultraviolet light to reveal surface flaws.
An abbreviated process flow diagram is shown in Figure 1.
Existing Waste Management Practices
•	Two-stage and three-stage counterflow rinses in the anod-
izing and chromate conversion lines reduce water con-
sumption and waste generation.
•	Process solutions are made up with deionized water to
reduce sludge formation.
•	Drain boards are used between solution tanks to reduce
•	Spent etching solution is used for adjusting the Ph of
spent rinse water.
Waste Minimization Opportunities
The type of waste currently generated by the plant, the source
of the waste, the quantity of the waste, and the annual man-
agement costs are given in Table 1.
Table 2 shows the opportunities for waste minimization that the
WMAC team recommended for the plant. The type of waste,
the minimization opportunity, the possible waste reduction '
associated savings, and the implementation cost along witl
payback time are given in the table. The quantities of hazaro.
waste currently generated by the plant and possible waste
reduction depend on the production level of the plant. All
values should be considered in that context.
It should be noted that, in most cases, the economic savings of
the minimization opportunities result from the need for less raw
material and from reduced present and future costs associated
with hazardous waste treatment and disposal. Other savings
not quantifiable by this study include a wide variety of possible
future costs related to changing emissions standards, liability,
and employee health. It should also be noted that the savings
given for each opportunity reflect the savings achievable when
implementing each waste minimization opportunity independently
and do not reflect duplication of savings that would result when
the opportunities are implemented in a package.
This research brief summarizes a part of the work done under
Cooperative Agreement No. CR-814903 by the University City
Science Center under the sponsorship of the U.S. Environmental
Protection Agency. The EPA Project Officer was Emma Lou
Figure 1. Abbreviated process How diagram.

Table 1. Summary of Current Watte Generation

Waste Generated
Source of Waste
Annual Quantity
Generated (gal)
Annual Waste
Management Cost
Spent rinse water
Rinse waters from anodizing, chromate conversion
coating, and surface inspection are Ph adjusted
and discarded as industrial wastewater.
Spent anodizing solutions
Aluminum cleaner, alkaline etch bath, acidic
deoxidtzer solution, anodizing reagent solution,
and dyeing and nickel acetate seal solutions are
batch treated (Ph adjusted) and discarded with
rinse water as industrial wastewater.
Spent chromate conversion
coating solutions
Hexavalent chromate solutions are reduced with
sodium metabisulfite: then, with aluminum cleaner,
alkaline etch bath, and acidic deoxidizer solution,
are batch treated (Ph adjusted) and discarded
with rinse water as industrial wastewater.
Spent passivation solutions
Hexavalent chromium solutions are reduced with
sodium metabisulfite and, with nitric acid solutions,
are batch treated (Ph adjusted) and discarded with
rinse water as in&istrial wastewater.
SpentackSc etchant solution
Spent acidic etchant from surface inspection is
batch treated to adjust Ph and precipitate dissolved
metals then discarded as industrial wastewater.
Spent penetrants
Spent dyes, developer, and emulsifier from surface
inspection are shipped as hazardous waste for use
as cement kiln fuel.
Batch treatment sludge
Sludge (metal hydroxides end trivalent chromium
compounds) from treatment of spent process
solutions and rinse waters is disposed of as
hazardous waste.
U.S. Qowmwl Pitotng Oflto* 1032— 648-08WG0073

Table 2. Summary of Recommended Waste Minimization Opportunities
Waste Generated
Minimization Opportunity
Annual Waste Reduction	Net	implementation Paybar'
Quantity (gal) Percent Annual Savings Costs	Yea
Spent nickel acetate
seal solution
Nickel hydroxide
sludge from treatment
of spent nickel acetate
Spent anodizing
Spent reagent solutions
from chromate
conversion coating
Anodizing and chromate
conversion coaling
water nnses
Alkaline etch
water rinses
Anodizing and chromate
conversion coating
water rinses
Use hot deionized water instead	2,275	100	$3,094
of nickel acetate as a seal after
Use hot deionized water instead	104	100	1,109
of nickel acetate as a seal after
Neutralize the spent solutions with	-	2,933
50% aqueous caustic instead of
sodium hydroxide pellets. Use
automated metering equipment to
reduce raw material and labor costs.
Allow increased drainage time above 1,292	20	2,496
the chromate conversion coating
line reagent baths. Increased solution
life will result in waste reduction and
cost savings.
Eliminate the soft-coat anodizing 651,346	42	2,351
rinse (use the hard-coat rinses for
both treatments), and install timer
switches to shut off all flowing nnses
when not in use.
Use spent acidic deoxidzer rinse 259,820	17	756
water instead of tap water for the
anodzing and chromate conversion
coating alkaline etch rinses.
Install flow reducers and flow	144,015	10	419
meters on flowing water rinses m
the anodizing and chromate
conversion coating lines to avoid
excessive use of rinse water.
$ 1,020
United States
Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
Official Business
Penalty for Private Use

Case Studies
SIC 2200-2300: Textile Mill Products &
Apparel/Other Finished Products
Office of Waste Reduction
North Carolina Department of Environment, Health, and Natural Resources
3825 Barrett Drive, Raleigh, NC 27609
Telephone: (919) 571-4100

Case Study: Americal Coip.
Henderson, NC (Vance County)
Produces Nylon Hose (SIC 2342)
Pollution Prevention Application:
Chemical Substitution/Process Modification
Annual Savings:
Payback Period:
5.5 Years
PPP Challenge Grant Awarded:
AL Taylor, Vice President of Manufacturing,
(919) 492-il66
Waste Reduction
The nylon hose that Americal Corporation produces are dyed during
production. The wastewater discharged from the dyeing process to the
POTW in Henderson results in high levels of BOD, COD, FOG, and
NH3-N. Responding to more stringent requirements by die State of North
Carolina concerning the levels of pollutants entering the city's waste
treatment system, Americal sought to develop methods to reduce the
levels of the pollutants.
A survey of the dyeing plant revealed several areas where changes could
be made.
•	Reductions in oil and grease discharges were achieved through more
accurate testing and surveillance of the oil levels in the nylon yarns.
•	In the dyeing process, acid dyes, disperse dyes, and softening
chemicals are used. To help reduce the levels of pollutants, Americal
investigated four dye and five auxiliary chemical manufacturers and
found products with the least amount of BOD, COD, and NH3-N.
These products were implemented in the dyeing process.
•	Americal also experimented with temperature regulation schemes and,
in testing for optimum temperatures, discovered that at 180° F with a
15-minute extension period, the dye exhausted more completely. More
importantly, this temperature allowed for a reduction in chemical use,
which, in turn, resulted in lower BOD, COD, and NH3-N bath levels.
•	To pretreat its waste water, Americal converted a cement tank into an
aerated equalization basin that allowed for reduction in pollutant levels
of effluent
SIC 2200-2300 Case Studio
September 1993

Case Study: Amital Spinning Corporation
New Bern, NC (Craven County)
Acrylic Yam Production/SIC 2281
Pollution Prevention Application:
Water Conservation and Reuse, Solid Waste Reduction,
Energy Conservation
Annual Savings:
Payback Period:
6 months
James Ipock, Plant Engineer, (919) 636-3435
Waste Reduction
Waste Reduction
Amital Spinning Corporation produces packaged, custom-dyed, high-bulk
acrylic yam for the textile industry. Amital has combined a process water
reuse system with a solid waste recycling system to achieve significant
energy and cost savings.
•	To reuse and conserve process water, Amital collected non-contact
cooling water to use in the color kitchen for the preparation of dye
liquors. The use of this water allows the dye liquors to be prepared at
high temperatures; thu, steam requirements during dyeing are reduced.
Process water is recovered, and the expended chemicals are
replenished. These changes reduce water and energy consumption and
costs. Other savings include a reduction in the quantity of batch
chemicals and in the time required for heating by 8 to 10 minutes per
•	Amital also increased its profitability through a solid waste recycling
and reuse program for various cardboard, metal, plastic, and acrylic
fiber components. Waste products are recycled back to the same
process or sold through an outside market. Disposal costs for these
recyclables are, therefore, avoided. A baler was installed to facilitate
program operation. The company recycled approximately 933,000
pounds of solid waste out of a total of 1.1 million pounds generated in
Amital was able to reduce the amount of wastewater generated per pound
of yam dyed from 1934 gallons in 1988 to 3.19 gallons in 1992.
Wastewater volume was reduced from 320,000. gallons to an average of
112,000 gallons per day while production increased from 12 to more than
25 batches of yam per day. Through the recycling program, the solid
waste stream destined for disposal was reduced by 933,000 pounds per
year, or an annual solid waste reduction of approximately 80 percent.
SIC2200-2300 Case Studie

Case Study: Harriet & Henderson Yams, Inc.
Henderson, NC (Vance County)
Manufacture Spun Cotton Yam (SIC 2342)
Pollution Prevention Application:
Annual Revenues:
$240/week all plants by March 1993
Alternative Use:
50 bales/week donated as livestock feedstuff
PPP Challenge Grant Award:
Richard Johnson (919) 430-5121 or
Bud Wortham (919) 430-5381
Research and
Harriet & Henderson Yams, Inc. (HHY), manufactures spun cotton yam
at four plants in Henderson, N.C., two plants in Clarkton, N.C., and
another plant in Summerville, Ga. Part of the manufacturing process
involves cleaning the raw cotton to remove bits of crushed cotton stalks
and seeds, dust, and short cotton fibers. All this cleaning by-product was
formerly baled and sent to the local landfill. The four Henderson plants
generate 80 bales (44,000 pounds) of the cleaning by-product per week.
Landfilling the material costs approximately S 10.00 per bale in Vance
HHY sought alternative ways to use or manage the material to avoid
landfilling. By modifying the cleaning operations so that more of the
short fibers could be recovered, HHY is able to currently sell about 5,300
pounds per week (10 bales) to textile by-product brokers at 1.5 cents per
pound. Once modifications are completed at all plants in March 1993,
they expect to be able to sell 16,000 pounds per week.
Agents with the Vance County Cooperative Extension Office advised that
the material has potential uses in agriculture and identified three potential
uses: as a soil amendment and nutrient source for crops, as a soil stabilizer
for erosion control, and as a feed source for livestock. To research and
test these applications, HHY received a Challenge Grant from the
Pollution Prevention Program to evaluate these potential uses. HHY
matched the grant with its own funds.
The by-product can feasibly be used as a soil amendment to supplement
commercial fertilizer or as a soil stabilizer to replace wheat straw and
asphalt, but it must first be milled to permit even distribution for either of
these applications.
SIC 2200-2300 Case Studies
Septembcr 1993

Case Study: Neuville Industries, Inc.
Location:	Hildebran, NC (Burke County)
Industry:	Textile Processing (SIC 2252)
Pollution Prevention Application:	Solid Waste Reduction/Recycling
Annual Savings:	$15,000
Contact:	Jack DeBev'e, Safety Director, (704) 397-5566
Waste Reduction
Waste Reduction
The cotton and blended hosiery manufacturing process at Neuville
Industries consists of knitting, dyeing, and boarding the hosiery products.
The purchase of fabrics and chemicals used in this process, as well as
fabric processing, produces large solid waste streams comprised of
cardboard, plastic, and paper cones and polybags from packaging.
Neuville Industries set up a recycling committee to evaluate, organize and
implement solid waste reduction techniques to reduce the cost burden of
solid waste disposal. The committee, which comprised the facility safety
inspector and members from each of the housekeeping, accounting,
knitting and seaming, and training staffs, first established a recycling
program in 1990. To spark immediate awareness of the need for recycling
and facilitate employee involvement, a employee suggestion program was
set up. Below'is a synopsis of the programs implemented for recycling
office, purchasing, and processing wastes.
•	Office and Break Room Waste: A "bag it" program with Garbage
Disposal Systems (GDS) to handle paper and aluminum can waste, and
color coded waste cans to ensure good separation of different paper
•	Purchasing Waste: Cardboard recycling program with GDS, plastic
cone recycling program with GDS and selling paper cones, and reuse
of most shipping pallets in-plant
•	Processing Waste: Donation of toe clippings to interested parties.
The recycling committee is seeking other recycling programs for
additional waste streams such as polybags from packaging, knitting oils,
and some plastic cones that are not accepted by GDS. The program
implemented an employee benefit program to funnel savings back to the
employees and facilitate ongoing employee involvement. The committee
meets bi-annually.
Between 1990 and 1992. Neuville reduced its solid waste disposal from
266 yd3/week to 180 yd /week.
SIC 2200-2300 Case Studies
September 1993

Case Study: Riddle Fabrics, Inc.
Location:	Kings Mountain, NC (Cleveland County)
Industry:	Textile Manufacturing (SIC 2250)
Pollution Prevention Applications: Process Modification / Chemical Reuse
Annual Savings:	$1,650
Payback Period:	2 years
Contact:	Tom Waters, General Manager, (704) 739-7731
Waste Reduction
Annual Savings
Riddle Fabrics, Inc., employes a bleaching process in the manufacture of
cotton label tape for the garment industry. Because the bleaching bath is
frequently dumped and chemicals are used in other systems, the level of
BOD exceeds compliance limits. Riddle Fabrics invited representatives of
the Pollution Prevention Program (PPP) to survey the plant's operation
and provide information on waste reduction opportunities.
After the site visit, PPP prepared a report outlining several options for
process modifications and housekeeping methods that could help reduce
the pollutant levels.
• Riddle Fabrics's use of the same vat for bleaching and rinsing allowed
reuse of the rinse bath for bleaching purposes but required frequent
discharge of the bleach bath. Following the PPP's suggestion, Riddle
Fabric installed a holding bin for the bleach bath, which is contained in
the bin during the rinsing stage and is pumped back into the vat before
the rinse bath is removed. Through titration, the bleach bath
concentration is analyzed and reconstituted as needed. This process
modification has reduced BOD levels to within compliance limits, and
water usage also has decreased.
Riddle Fabrics has been able to reduce its BOD levels from 842 mg/1 to
400 mg/1. Water usage has decreased by 5,000 gallons per year.
The plant has realize $1,650 in annual savings from reductions in
chemical and water usage and wastewater treatment surcharges. Also,
Riddle Fabrics benefits from avoided future permit fines.
SIC 2200-2300 Case Stadia
Septcmbcr 1993

Waste Reduction
Annual Savings
the wastestream. For this reason, the City of Newton granted an increase
of the limit for BOD to 340 mg/1.
Through this research Ti-Caro has been able to reduce a small amount of
chemical use as well as reduce the pollutant levels in the waste water.
Ti-Caro has experienced an increase in savings as a result of the process
modifications and chemical substitutions. However, the increase in
compliance limits, which resulted from current water saving practices,
accounted for most of the savings.
SIC 2200-2300 Case Studies
September 1993

C. EPA Pa Fact Sheets

United States
Environmental Protection
Office of Pollution Prevention
and Toxics
Washington. DC 20460
September 1993
Pollution Prevention Fact Sheet J
Pollution Prevention
Act of 1990
The Pollution Prevention Act of 1990, signed into law in November 1990,
establishes pollution prevention as a "national objective." The Act notes
of Pollution
"There are significant opportunities for industry to reduce or
prevent pollution at the source through cost-effective changes in
production, operation, and raw materials use... The opportunities
for source reduction are often not realized because existing
regulations, and the industrial resources they require for
compliance, focus upon treatment and disposal, rather than source
reduction ... Source reduction is fundamentally different and
more desirable than waste management and pollution control."
The Act establishes a hierarchy of environmental protection measures,
declaring that pollution should be prevented or reduced at the source
wherever feasible, while pollution that cannot be prevented should be
recycled in an environmentally safe manner. In the absence of feasible
prevention or recycling opportunities, pollution should be treated; disposal
or other release into the environment should be used as a last resort.
Pollution prevention is defined in the law to mean "source reduction" (as
further defined below), and other practices that reduce or eliminate the
creation of pollutants through:
• increased efficiency in the use of raw materials, energy, water, or.
other resources, or
of Source
• protection of natural resources by conservation.
Source reduction is defined in the law to mean any practice which reduces
the amount of any hazardous substance, pollutant or contaminant entering
any waste stream or otherwise released into the environment (including
fugitive emissions) prior to recycling, treatment or disposal; and which
reduces the hazards to public health and the environment associated with
the release of such substances, pollutants, or contaminants.
Printed on Recycled Paper

Provisions	The Pollution Prevention Act formalizes the establishment of an office at
EPA (the Office of Pollution Prevention and Toxics) independent of the
single medium programs to carry out the functions required by the Act
and to develop and implement a strategy to promote source reduction.
Among other provisions, the law directs EPA to:
•	facilitate the adoption of source reduction techniques by businesses
and by other federal agencies;
•	establish standard methods of measurement for source reduction;
•	review regulations to determine their effect on source reduction;
•	investigate opportunities to use federal procurement to encourage
source reduction;
•	develop improved methods for providing public access to data
collected under federal environmental statutes;
•	develop a training program on source reduction opportunities, model
source reduction auditing procedures, a source reduction
clearinghouse, and an annual award program.
TRI Reporting
Report to
The Act authorizes an $8 million state grant program to promote source
reduction by businesses, with a 50 percent state match requirement.
Under the Act, facilities required to report releases to EPA for the Toxic
Release Inventory (TRI) must also now provide information on pollution
prevention and recycling, for each facility and for each toxic chemical.
The information includes: the quantities of each toxic chemical entering
the waste stream and the percentage change from the previous year, the
quantities recycled and percentage change from the previous year, source
reduction practices, and changes in production from the previous year.
The Act requires EPA to report to Congress within 18 months (and
biennially afterwards) on actions needed to implement a strategy to
promote source reduction, and an assessment of the clearinghouse and the
grant program.
For Further
Contact the Pollution Prevention Information Clearinghouse (PPIC), U.S.
EPA (PM 3404), 401 M Street SW, Washington, D.C. 20460, Tel: 202-260-
1023, Fax: 202-260-0178.

United States
Environmental Protection
Office of Pollution Prevention
and Toxics
Washington. DC 20460
September 1993
Pollution Prevention Fact Sheet
Setting Up A
Pollution Prevention
Why Set Up
a Program ?
Where Do
I Start?
Industry, service businesses, municipalities, and other organizations are
finding that pollution prevention programs are cost-effective as well as
environmentally sound investments. Pollution prevention can improve
regulatory compliance, reduce costs for pollution control and waste
disposal, improve employee safety, and reduce the liability associated with
the management of hazardous materials and wastes.
A Pollution Prevention Program is defined as an organized,
comprehensive, and continual effort to systematically reduce or eliminate
pollution and wastes. EPA's Facility Pollution Prevention Guide is
specifically targeted to assist small and medium sized production facilities
in developing a pollution prevention program (see ordering information
below). Also, on May 18,1993, EPA issued guidance to hazardous waste
generators in putting in place a waste minimization program (a copy of the
Federal Register notice is available from the RCRA Hotline, 1-800-424-
9346). The program elements explained in that guidance are listed below.
(1) Demonstrate top management support in order to ensure that
pollution prevention becomes an organizational goal. To demonstrate
such management support, use techniques such as:
Circulating a written company policy on pollution prevention
Setting specific goals for reducing waste stream volume or toxicity
Designating program coordinators
Publicizing and rewarding successes
Providing employee training in pollution prevention.
(2) Characterize waste generation and waste management costs. Maintain
a waste accounting system to track the types and amounts of wastes and
hazardous constituents. The best type of system will vary for each
organization. Determine the true costs associated with waste management
and cleanup, including costs of regulatory oversight compliance,
paperwork, materials in the waste stream, and loss of production potential.
Printed on Recycled Paper

(3) Conduct periodic pollution prevention assessments to ensure that
pollution prevention opportunities continue to be sought at all points in
the process where materials can be prevented from becoming waste. An
assessment identifies pollution prevention options by identifying sources of
pollution and waste and by looking for clean production technologies.
(4) Develop a cost allocation system wherever practical and feasible to
allocate the true costs of waste management to the activities responsible
for generating the waste in the first place. Departments and managers
should be charged "full-loaded" pollution control and waste management
costs. Labor costs, liability, regulatory compliance, disposal, and oversight
costs should all be included.
(5)	Encourage technology transfer. Consult technical manuals or EPA's
clearinghouse (see below) for specific types of industry, processes, or
wastes, or to review case studies that have been developed. Many
successful techniques have been documented that may be applicable to
your facility. Information can be obtained from federal and state agencies,
universities, trade associations, and other firms.
(6)	Finally, review program effectiveness periodically to provide feedback
and identify potential areas for improvement. Has pollution prevention
become a significant part of the way you do business?
Where Do	A useful, ongoing source of information is EPA's Pollution Prevention
/ Go Next?	Information Clearinghouse (PPIC), which offers a reference and referral
service and a computerized network for information exchange. Contact:
PPIC, U.S. EPA (PM 3404), 401 M Street SW, Washington, D.C. 20460.
Tel: 202-260-1023. Fax: 202-260-0178.
Free	• 1993 Reference Guide to Pollution Prevention Resources (EPA/742/B-
Publieations	93/001). Lists training opportunities, technical assistance contacts,
publications, state and federal program contacts. (Available from PPIC--
see above for address.)
*	Total Cost Assessment: Accelerating Industrial Pollution Prevention
through Innovative Project Financial Analysis. (EPA/744/R-92/002, May
1992). A manual that describes the concepts and methods of a
comprehensive long-term financial analysis of pollution prevention
projects. (Available from PPIC, see above for address.)
•	Facility Pollution Prevention Guide (EPA/600/R-92/088), a manual for
identifying hazardous waste pollution prevention opportunities. Includes
worksheets, sample assessments, causes and sources of waste, pollution
prevention techniques, and economic evaluation methods. Revised 1992.
Also see: Guides to Pollution Prevention, a series of industry-specific waste
minimization guidance manuals. (Available from EPA Center for
Environmental Research Information, Publications Unit, 26 W. Martin
Luther King Drive, Cincinnati, OH 45268. Tel: 513-569-7562. Fax: 513-

V. P2 Training Materials

A. EP3 Industrial Group &
Best Industrial Practices

A Report of the
Office of Environment and Natural Resources
Bureau for Research and Development
United States Agency for International Development
Prepared for:
RCG/Hagler, Bailly, Inc.
1525 Wilson Boulevard, Suite 750
Arlington, VA 22209-2406
Prepared by:
Joel S. Hirschhorn
Hirschhom & Associates, Inc.
4221 Forbes Boulevard, Suite 240
Lanham, MD 20706
January/February 1994

Task 1. Selection of 10 priority industrial categories.	1
(1)	Evaluation Criteria and Methodology	1
(2)	Proposed Industries	3
(3)	Five Alternative Industries	9
(4)	Other Industries for Longer Term Activities	11
Task 2. Critical ratio methodology: the leather tanning and
textile industries.	12
Introduction	12
Part 1: Leather Tanning Industry	16
Part 2: Textile Dyeing Industry	26
Task 3. Collection of data from facilities.	43
1.	Benefits of the approach	43
2.	Specific stepts for collecting data	44
3.	Establishing an EP3 database for benchmark
critical ratio data	46

Task 1 Progress Report: Preliminary Selection of 10 priority industrial categories.
fll Evaluation Criteria and Methodology
In addition to leather tanning and textiles, that were specified by EP3, eight
additional industries have been selected as priority industries for EP3. Three evaluation
criteria were used in selecting each of the eight additional industries: Opportunity, Presence,
and Importance.
1.	Opportunity: There should be a significant number of commercially proven
and documented pollution prevention opportunities that address important environmental
problems. These pollution prevention actions should proven technical feasibility and net
economic benefits that are applicable for developing countries. Also, EP3 country projects
should have the potential for serving as unique sources of pollution prevention solutions and
assistance. Even though adoption of cleaner technologies may have originated in
industrialized countries, the economic benefits (paybacks) should not be dependent on
extensive, enforced environmental regulations, and capital costs should be low, actions that
have been used successfully in one or more developing countries have special importance.
2.	Presence: The industry should exist in many developing countries having the
potential of being involved in EP3, so that EP3 efforts in one country can build on previous
efforts. Also, there should be a significant number of facilities (companies) in any one
country, thereby providing greater opportunity for technology demonstration and adoption for
a given EP3 investment in a country
3.	Importance: Industries should have special significance in the context of
sustainable economic growth, rapid industrialization and urbanization, and privatization.
There should also be some balance between large industrial facilities (companies) versus
smaller enterprises; there should also be some diversity of business sectors, including
manufacturing and service sectors. In addition to economic importance, industries may also
be important because of their environmental problems, and their potential for being
effectively regulated. Government owned industries are likely to provide fewer opportunities
than private companies, because of more focus on production outputs than profitable
operations that can benefit from cost-cutting pollution prevention actions.
Each proposed industry was rated on a scale from 1 to 3 for each of the above
factors, with 3 represented the highest rating. For the most part, all the proposed industries
are likely to be found in any developing country, although the actual presence and
importance will vary from one country to another. However, the evaluations made here are
based on a general view of all developing countries.
page 1
February 28, 1994

Initially, a larger number of industries were considered, based on an assessment of
the pollution prevention literature (e.g., U.S. EPA publications, books, U.N. publications, and
journals). These were then evaluated, using the above three factors. Generally, only those
industries receiving a score of 6 or higher (out of a possible 9) have been recommended.
Leather tanning and textiles were also scored, not to determine inclusion, but to serve as a
kind of reference level. Clearly, there is some subjectivity in this evaluation process.
However, the goal is not quantitative precision, but rather to have some defensible
methodology for including or excluding industries. Thus, there is no real significance to total
score differences between 6 and 9.
(2) Proposed Industries
The numerical results are presented in the accompanying table, followed by a brief
discussion of each of the proposed eight industries, including the identification of key
subcategories when appropriate. Following that is a brief explanation of why certain other
industries have not been selected.
Leather Tanning
Metal Parts
Auto Repair
Paint ManufacL
Printed Circuit

Wet Battery Mfg.
Photo Processing
Metal Parts
There is a large literature on pollution prevention opportunities in various metal
parts manufacturing operations in the U.S. These have addressed both wastewater and
hazardous waste problems. Older, less sophisticated smaller facilities in developing countries
have the potential to use many of these technologies, methods, or products. Three
subcategories are proposed: surface finishing by electroplating, parts cleaning, and machining.
page 2
February 28, 1994

In virtually every developing country there will be many small and some larger
companies involved with the manufacture of metal parts, both ferrous and nonferrous.
Often such companies are suppliers for other manufacturing firms, which makes them
especially important for economic development This multiplier effect means that firms in
this category have an importance beyond their direct sales and employment figures.
Commercial printing companies have implemented many pollution prevention options
that have addressed solid and hazardous waste, air emissions, and sometimes wastewater.
While often ignored, printing companies are likely to be found in large numbers in
every developing country. In addition to independent printing companies, many other types
of companies have printing operations, including, for example, newspaper publishing,
packaging companies, and stationary firms.
Larger companies provide printing services for industrial, business, and government
customers; they print on paper and plastic materials. Because many industries and business
enterprises depend on local printers, this industry has an important role in developing
country economies.
Although a large scale materials processing industry with limited low cost pollution
prevention opportunities, the industry is usually a source of substantial environmental
problems. For this reason there is a significant literature to document successful actions.
Three subcategories are proposed: virgin pulp making; papermaking; and conversion of
post-consumer paper discards into recycled pulp. Unlike many other large scale processing
industries, papermaking companies in developing countries are likely to be locally owned
(Le., not owned by multinational companies, such as is the case for chemical facilities).
Many countries have papermaking companies, especially countries with timber
resources, although paper also is a significant import worldwide.
When papermaking companies are present in a developing country they usually are
deemed important to the economy, because of their large scale of investment and
employment, use of natural resources, and relationship to other domestic companies.
page 3
February 28, 1994

Auto Repair
In the U.S. significant attention has been given to auto repair shops, mainly because
of solid and hazardous waste generation, and often harmful air emissions (e.g., solvents and
In nearly all developing countries there is explosive growth of the use of automobiles,
obviously in major urban areas. Moreover, in contrast to industrialized countries, there is
greater use of older automobiles and other motor vehicles, requiring considerable use of
many small repair and service shops.
There is enormous importance of auto repair shops because of their large numbers in
rapidly expanding cities, not merely for automobiles, but also for buses and trucks which are
essential for local economies. Government owned fleets can become leaders and examples
of urban pollution prevention. Moreover, their environmental significance is unusual and
often ignored because they are a service industry with many locations, rather than
manufacturing. In Jakarta, auto repair shops have been identified as the single largest
source of waste-related problems.
Paint Manufacture
This industry has a number of proven pollution prevention approaches to use; these
address air releases of VOCs, hazardous waste, and high toxic loadings to municipal
wastewater treatment plants.
Virtually all developing countries are likely to have relatively small paint companies,
which purchase locally made and imported raw materials for processing into different types
and grades of paints.
While paint manufacturers are not likely to account for large numbers of workers or
revenues, they are needed for many local users. They also account for significant
environmental problems.
Printed Circuit Boards
This industry has received considerable attention for identifying pollution prevention
opportunities, because of the extensive use of toxic materials and the substantial potential for
causing air, water, and waste problems.
At this time, there is probably an uneven presence of printed circuit board
manufacturers in developing countries, but the potential for more presence is significant
page 4
February 28, 1994

However, when this high-tech industry is represented, it is important to growing
economies that have made a commitment to the electronics industry. It is also important
because it is a high growth, high tech industry with enormous potential for growth. Also, it
is often an important export for developing countries.
Wet Battery Mfg.
This is the one industry for which there is little available pollution prevention
information in the published literature. However, it is hoped that significant information will
be obtained from the current EP3 work in Tunisia.
This industry is likely to be present in most developing countries, because motor
vehicle batteries are needed everywhere and the technology is relatively simple.
The importance is that the product is needed for both personal and commercial use,
the industry poses significant environmental problems, and the heavy product does not lend
itself to long distance transportation.
Phntn Pmrflxsinp
Because of their large presence in the U.S. and their being a source of water
pollution, these facilities have received some significant pollution prevention attention.
This service industry is likely to undergo considerable growth in developing countries
as incomes rise. In addition to large central facilities in urban centers, it is conceivable that
smaller, convenience shops will become more important in developing countries, as they have
in industrialized countries.
However, this industry received a relatively low score for both presence and
importance, and it could be replaced by one of the industries discussed in the following
f31 Industries Not Selected
A host of food processing industries have not been selected, primarily because of few
no cost/low cost pollution prevention opportunities. Most opportunities relate to water
conservation and recycling, whose economic benefits are very dependent on local water costs
that usually are kept relatively low by government policy. Solid waste management is
unlikely to be regulated or costly in most developing countries, and thus avoidable waste
disposal costs are not likely to be significant Water pollution may be regulated, but
page 5
February 28, 1994

wastewater treatment avoidable costs cannot be completely eliminated through pollution
prevention actions. However, this is a very important industry in many developing countries.
We propose that food processing be considered a high priority for longer term EP3 efforts.
A number of large scale basic industries have not been selected, because they offer
few no cost/low cost pollution prevention opportunities. Substantial environmental problems,
usually air and water pollution, can be more effectively addressed by conventional pollution
control approaches. These industries include: cement, mining, steel and other primary metals
refining and manufacture, petroleum refining, electric power, and phosphate fertilizer, for
example. These are also industries that are often government owned and operated.
The chemical industry has not been selected, primarily because the majority of
chemical plants in developing countries are wholly or partly owned by multinational
companies that provide extensive technical support In such cases, local managers are likely
to have little interest in EP3 services. However, chemical companies could be important
clients in the longer term.
Certain manufacturing industries also have not been selected for several reasons,
including, most importantly, the fact that they are likely to be dependent on foreign
technology and technical support, because of foreign ownership, technology licensing, or
controls by foreign customers. Important examples are: pharmaceutical manufacture, motor
vehicle manufacture, and electrical/electronic commercial and consumer products.
There are several major industries related to use of the land, namely agriculture,
forestry, and rubber, that would require very special expertise for applying pollution
prevention principles. These should be seen as longer term opportunities for mature and
successful pollution prevention programs that can expand to include sustainable agriculture
Various service industries also offer longer term opportunities, often because of rising
solid waste management problems and costs. A most important example is hotels and
tourism attractions, which have energy, solid waste and water pollution problems amenable to
pollution prevention approaches. Also, dry cleaners might be a significant opportunity in the
retail sector of countries with an expanding middle class, because of their chemical usage,
which has been addressed successfully in the U.S. Similarly, hospitals and other sources of
medical waste could be longer term clients of pollution prevention services.
page 6
February 28, 1994

Task 2 Progress Report
The general approach, used in Part 1 for the leather tanning industry and in Part 2
for the textile industry, is to present the following;
1.	Industry Subcategories: define key industry subcategories or unit operations, following
the order of material flows in a facility, and describe them in simple, clear language; the
emphasis is on those operations that are material, water, and energy intensive and that are
the major sources of waste and pollution.
2.	Priority Pollution Prevention Actions: present pollution prevention priorities that are
linked to specific subcategories; describe in terms of the technical action and the economic
benefits by reference to actual industrial applications; actions have been screened so that
only actions that offer economic benefits for developing countries and do not result in
environmental media shifting have been selected.
3.	Best Industrial Practice Targets: present numerical BIPs for the same specific pollution
prevention priorities in terms of critical ratios that are technically linked to the basic
industrial activity and pollution prevention action; these ratios can be used to assess and
track pollution prevention performance and progress at a facility.
4.	Implementation Methods and Issues: discuss implementation issues for the BIPs to
elaborate on how the pollution prevention actions can be applied and what problems* will
probably have to be addressed, especially in developing countries.
5.	Comments and Discussion: present other pollution prevention actions that can also be
considered for implementation, depending on the exact configuration of a facility; these are
second order priority pollution prevention actions, which for some facilities may be important
opportunities and which may over time become first order priorities.
6.	References: identify the sources of technical information and data used.
Tables 1 and 2 present summaries of the critical ratios and BIPs for the two industries.
page 7
February 28, 1994

Table 1
Leather Tanning Industry
Critical Ratios for Best
Industrial Performance
Unit Operation
Critical Ratio
Solvent degreasing of hides
Kilograms of solvent per kilogram
of hides
Chrome fixing of hides
Parts per million of trivalent
Chrome in wastewater effluent
Chrome fixing of hides
Kilograms of purchased Chrome
sulfate per tonne of wet raw hides
Use of solvents in finishing
Kilograms of solvents per kilogram
of finished leather
Total facility water use
Cubic meters of water per tonne of
wet hides
page 8
February 28, 1994

I. INDUSTRY SUBCATEGORIES (three major unit operations)
A.	Pre-Tanninp in Beamhnuse
(A-l) Beaming: soaking of hides in water, then in strong alkali solution to remove hair and
residual flesh; mechanical trimming; possible lime splitting (produces solid waste from low
quality split layer); de-liming with weak acid; bating (an enzymatic process) to control leather
properties; and pickling of skins for reaching acidity to prevent chrome precipitation on skins
in tanning and improve chrome penetration.
(A-2) Decreasing: use of solvent (e.g., perchloroethylene, monochlorobenzene) on hides prior
to tanning to remove grease (generally necessary for sheepskins and pigskins).
B.	Tannin p
Chrome tanning with chromic sulphate, producing acidic effluent with unused chrome salts.
Alternatives to chrome are available (see discussion below).
C.	Post-Tanninp Finishing
Pressing to remove moisture (sammying); mechanical shaving and possibly mechanical
splitting; possible secondary tanning; dyeing and possibly softening; drying and final trimming;
surface coating(s); and buffing for finishing. There are companies that buy tanned hides and
do finishing only.
The focus for pollution prevention in leather tanneries should be chemical costs.
These are typically the second highest fraction of tannery manufacturing costs, about 40%,
compared to 50% for hides, without accounting for pollution control spending. Often
chemicals are imported, making them especially important targets for reduction in developing
Four high priority pollution prevention actions are presented (not in any priority
order, but following the logic of the unit operations presented above); other possible actions
are considered in the discussion section. These four priorities are designed to marimiw the
effectiveness of an initial tannery assessment or audit
page 9
February 28, 1994

Priority One. In beaming (A-2) - solvent recovery or elimination for degreasing operation
(not applicable if only cattle hides used):
A distillation unit in system takes effluent from degreasing of skins (e.g., sheep) and
recovers reusable solvent; it also produces a concentrated solid organic phase for disposal (or
for reuse because of value of grease). In one case the capital cost was $48,600 but the unit
offered a net savings from reduced solvent purchases, even with increased energy use (no
specific savings given).(2) In some plants the resulting mixture of solvent, grease and water
is pumped to tanks where some separation occurs through decanting of grease and the
solvent is reused; however, this leads to water effluent with significant solvent(8)
An alternative to solvents is to use surfactants, preferably biodegradable ones making
wastewater treatment easier. There is still a need to deal with grease and BOD in
wastewater treatment, as compared to obtaining solid residual in solvent recovery equipment
which must be disposed. (4)
Priority Two. In tanning (B) - chrome recovery and recycling:
This is a major pollution prevention action that has already been widely used. Three
specific examples are:
Method 1 (U.S.) - 99% chrome recovery by: screening of tanning effluent; caustic
soda reaction and precipitation of chrome hydroxide; pressing to concentrate; clarified water
released; chrome hydroxide sludge redissolved in sulfuric acid; and liquid reused for tanning
Capital cost was $12 million for a production capacity of 3,000 hides per day, producing
annual savings of $360,000 from reduced chrome purchases (payback for developing country
about 40 months) and $150,000 from avoided ofEsite treatment charges for wastewater.(l)
Method 2 (Greece) - 95-98% recovered by screening, magnesium oxide used for
precipitating chrome oxide at pH of at least 8; clarified water released; sludge dissolved with
sulfuric acid at pH of Z5 and liquid reused for tanning. Capital cost was $40,000 for plant
handling 2^00 tons per year (about 300 cattle hides per day or about 10% of previous
example), producing annual savings of $73,750 in chrome purchases (payback for developing
country about 6 months) and $30,200 in operating costs (probably wastewater treatment).(5)
Method 3 - (France) sodium carbonate used for precipitation. Capital cost was
$69,500 for plant handling 1,000 hides per day, producing annual savings of $147,400,
presumably from chrome savings (payback for developing country about 6 months).(2)
page 10
February 28, 1994

All of these specific examples are variations of the same basic scientific and well
demonstrated approach, which is the ability to precipitate chrome hydroxide rather easily at a
pH of &5 to 10J, then dissolving the resulting solid phase and producing a liquid that can
be used in the primary tanning operation in place of virgin material(4)
The ability to reduce chrome in effluent by using chrome recovery and reuse has
been demonstrated. A U.S. company reduced chrome from 10 ppm to less than 1 ppm, for
savings of $40,000 to $50,000 annually in avoided wastewater treatment costs.(7) Minnesota's
regulatory limit was 8 ppm total chrome content in wastewater and the facility reached
average of 2 ppm after chrome recovery from wastewater.(l) The Greek tannery mentioned
above could reach 2 ppm chrome content in wastewater.(5) The French case reduced
chrome in wastewater from 7.5 to 3 ppm.(2) Regulatory limits for chrome (trivalent) in
wastewater vary widely among countries, but rarely are below 2 ppm. Untreated effluent
from chrome tanning facility can be as high as 100 ppm.(4)
Priority Three. In post-tanning, finishing (C) - solvent recovery or elimination:
Finishing operations generally use coatings, colorants and other surface modification
products; all of these may contain solvents, such as aromatic and aliphatic hydrocarbons,
esters, and alcohols.(6) Environmental and occupational impacts are substantial (e.g., from
trichloroethylene, toluene, methylethylketone, xylene that produce air concentrations easily as
high as 25 to 100 ppm in the workplace).(4) A U.S. leather finishing company produced
over 118 tons of solvent waste yearly. (6) Solvents can either be recovered, reduced, or
eliminated altogether. However, non-solvent based coatings are not available for all types of
final coating steps that may be used to obtain certain leather products.
It is possible to use advanced mechanical techniques for contact application to
increase transfer efficiency and minimis air releases, as well using high efficiency and
automated spraying methods. Nevertheless, air losses may still be relatively high, possibly
30% or much more, especially in tanneries in developing countries. Use of modern solvent
recovery equipment is not likely to be cost-effective either, especially in developing countries,
and the use of materials with different solvents adds an additional burden. However, in a
U.S. facility an investment of $300,000 for a solvent capture system was deemed feasible,
producing annual savings of $200,000 by recovering about 90% of the solvents used.(6) As
long as solvent based materials are used, some leaking and spills are also unavoidable, even
with recovery.
page 11
February 28, 1994

Priority Four. In all operations (A, B, C) - water use reduction
Other than bad odors, which are very difficult to reduce, plant wastewater is usually
the main focus of environmental attention to a tannery. Large volumes of water are used
for three main purposes in all leather tanning companies: process waters (22%), rinse waters
(55%), and general plant washdown (23%).(3) Various water conservation methods can be
used to reduce water use. There is even some potential for reusing the effluent from
wastewater treatment Wastewater treatment may be required, even with recovery of chrome
from the original plant effluent, because of BOD and TSS considerations, for example. The
economics of water conservation are extremely dependent on the cost of water, which all too
frequently is a no cost raw material or a very low cost one that provides little incentive for
water conservation. If onsite wastewater treatment is required, or if significant charges are
levied for use of a central water treatment plant, then water conservation can cut costs.
Expert opinion is that a typical tannery consumes 50 cubic m/tonne of wet hide
processed.(3) And the generally accepted range of water use is from less than 25 to greater
than 80 cubic m/tonne of hide processed.(4) Another set of data for six plants showed a
range of 20 to 63 cubic m/tonne of raw hides.(8) Tanneries in developing countries are
likely to be at the high end of these ranges.
Corresponding to the above four pollution prevention priorities, four specific BIP
targets have been developed, as presented below. These do not address all of the many
environmental issues for leather tanneries, but they do provide a relatively quick and easy
method for people performing a facility assessment It is a strategic framework for
identifying and evaluating the major pollution prevention opportunities in a facility, especially
important immediate pollution prevention opportunities. In all cases, the objective is to
numerically reduce the parameter. When the target is to achieve a zero level, reducing
actual values of the ratio to approach zero is appropriate, which is why units are given.
BIP No. 1 - Solvent use in degreasing (not applicable if only cattle hides used):
On balance, considering both the equipment cost of solvent recovery and the need to
maintain good operating practice, the preferred practice is to eliminate the use of solvents in
favor of using biodegradable surfactants which have become increasingly available, and are
not likely to increase costs significantly.
BIP = zero kg solvent/kg of hides
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BIP No. 2 - (a) Concentration of chromic oxide in plant wastewater effluent after chrome
recovery, and (b) level of purchased chrome:
BIP = 2 ppm chrome (trivalent) in wastewater effluent achieved by chrome
precipitation and recovery
Another BP can be defined in terms of the amount of purchased chrome sulphate
necessary. The lower this value the better. It is reduced by chrome recovery and possibly
by other approaches, such as use of more expensive high fixation chrome tanning agents and
recycling of chrome liquor (see discussions below). For conventional chrome tanning the
critical ratio is:
BIP = 40 kg chrome sulphate/tonne of wet raw hides tanned
BIP No. 3 - Use of solvents in finishing operations
The best approach for developing countries is maximum conversion to aqueous dyes
and non-solvent finishing technologies to avoid the solvent problem altogether or to reduce
solvent use to the maximum degree. If alternative raw materials are available, this approach
imposes fewer challenges than purchasing and maintaining solvent recovery equipment, which
can be especially difficult if there are complex mixtures of different solvents. The amount of
solvent refers to components in finishing products and pure solvents that may be purchased
for making additions to commercial products or for cleaning purposes.
BIP = zero kg solvents/kg of finished leather
BIP No. 4 - Total facility water use
The selected BIP is deemed appropriate for an ambitious pollution prevention goal in
developing countries, considering the broad range of water use in leather tanneries and the
experience that a 50% reduction in total water use at a tannery is often feasible and
BIP = 40 cubic m/tonne of wet hides (total facility, excluding sanitary uses)
BIP No. 1 - Solvent use in degreasing
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February 28, 1994

If a person conducting a site assessment determines that the company uses sheepskins
or pigskins, then there is a need to also determine if solvent degreasing is used. If solvent
degreasing is used in a tannery, then the need is to accurately identify the total cost of using
such solvents. The next step is to identify commercial sources of alternative surfactants and
their costs, but it may be difficult to get comparable data, because of uncertainty about the
amount of surfactant needed for the job. If appropriate information is obtained on
surfactants, then the next step is to consider how a test or plant demonstration can be
conducted to show whether the surfactant has the potential to work as effectively as the
solvent(s) being used. Arranging such a plant test or demonstration may pose a challenge in
developing countries. Plant personnel should be asked whether they know of a tannery that
uses surfactant in place of solvents.
The following points can be used to persuade industry or government persons to
conduct such a test or demonstration. Replacing solvent with surfactant will have no real
impact on wastewater qualify (assuming no solvent recovery), because both methods result in
grease in the water effluent However, there is an environmental advantage in replacing
solvent in the wastewater with biodegradable surfactant Indeed, combined with other
actions, namely BIP No.2 and No. 3, replacing solvent with surfactant could help reduce the
need for wastewater treatment by removing the most toxic substances from wastewater. A
careful economic analysis will show whether use of a surfactant decreases total costs,
including raw material purchases and water related costs.
BIP No. 2 - Chrome recovery
There are two main issues or incentives for developing interest in chrome recovery:
there is a history of documented net savings by reducing purchases of chrome sulfate for
tanning; and chrome is usually the substance of highest environmental concern driving
government requirements for wastewater treatment and its significant costs for a company.
The first BIP for chrome in effluent shows the environmental need for chrome recovery,
with values of 100 ppm or more likely in untreated effluent from plants in developing
Capital cost is likely to be a major company concern. The data from the three cases
given above indicate that a rough guide for estimating capital cost is about $130 per hide
processed daily as a measure of production capacity. The BIP for chrome sulphate usage
can be used to judge the potential for cost savings. A tannery using few if any methods for
reducing chrome purchases may lose 30% of purchased chrome into effluent; recovery should
be able to save at least 95% of the wasted chrome. Payback is likely to be about six
months, based on reduced chrome purchases alone. Avoidance or downsizing of wastewater
treatment plant, or lower costs for using a municipal or industrial estate treatment plant,
adds another economic benefit If wastewater treatment is not currently required, the
probability for future regulatory requirements during the next five years should be assessed.
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The implementation challenge is to design and construct the necessary equipment
(Le., various tanks and piping) to cany out the precipitation and dissolution stages, and also
to control chemical usage (alkali and sulphuric acid) and pH to achieve a well controlled and
efficient process. One decision is what alkali to use for precipitation, with the two likely
ones being sodium hydroxide or magnesium oxide.
Chrome recovery is likely to be embraced by plant managers, but it may be resisted
by tannery owners because of capital cost, the need for trained staff, or the physical
limitations of the plant However, it should also be emphasized that the "fall-back" position
in the case of determined opposition to chrome recovery is to consider the alternatives of:
-	emphasizing high chrome fixation methods (e.g., 90% versus 70%) by using special
tanning compounds;
-	reducing purchased chrome (up to 20%) by recycling of used chrome liquors to
tannage and to pickle, also referred to sometimes as reconstitution of the chrome bath when
new chrome sulphate is added;
-	switching to alternative tanning agents (e.g., vegetable, titanium sulphate, or
While these may seem simpler, they do not yield the same benefits as chrome
recovery and reuse. See the discussion below also.
BIP No. 3 - Use of solvents in finishing operations
The chief challenge is determining how to maximize conversion to aqueous dyes and
non-solvent finishing materials. Plant managers may have already received information on
such substitutes from chemical suppliers. Any previous decision to address or ignore such
substitutions should be identified. Also, the fixing of resins with formaldehyde can be
changed to UV light fixing. Implementation of this BIP is an especially difficult task,
because it is very much linked to product quality and customer satisfaction, especially for
higher priced leather products. Alternative materials must be identified and then tested to
determine cost and product acceptability. Conducting a facility pollution prevention
assessment requires identifying all currently used finishing materials and determining the
extent to which solvents and formaldehyde are used, and also determining the costs of them
accurately in order to fairly judge the economic impacts of switching to different materials.
Testing the use of specific substitutes will probably require significant attention and
commitment by company owners and managers.
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BIP No. 4 - Total facility water use
The first implementation need is to accurately determine the total water use at a
facility, which may be difficult if the plant does not meter its water intake. Water use may
vary widely as batch production changes as a function of seasonal hide supply variations or
sales variations. Nevertheless, some representative average figures must be determined or
estimated. Any figure above about 60 cubic m/tonne (1/kg) of hides processed definitely
indicates a large potential for water conservation, perhaps as much as 50%. The current and
future costs of water and wastewater treatment must be assessed. It is probably useful to
consider a number of implementation actions in an aggregate way so that total cost savings
can be estimated relative to total implementation costs. Otherwise, only the simplest of
water conservation measures may be used.
Waste reduction or water conservation methods include: reducing water used in
beaming (un-hairing) by reducing duration of rinsing (e.g., from one 4-hour running water
rinse to two batch stages of 20-25 minutes each); using pistol-grip self-closing nozzles on
facility hoses used for equipment washdowns;(3) using batch rather than running water
washes wherever possible; reusing some wastewaters in less critical processes (e.g., second
lime wash to start a new lime liquor, used lime washes for soaking); recycling individual
process liquors; and using low float methods and water flow meters for equipment are
additional approaches.(4) Also, identifying and correcting leakages in equipment and piping
should prove useful For example, the costs of a leak of about 2 1/min from a hose will buy
a new hose every month, even in a developing country with very low water costs (Le., about
$25/cubic meter).
Chromium Alternatives
There are alternative approaches to the chrome problem, if chrome tanning is used.
High chrome fixation (absorption) is an alternative to chrome recovery. It requires use of
self-basifying chrome compounds and dicarboxylic acid. While it may achieve 90% chrome
fixation, higher cost chemicals are needed and more complex processing is required.
However, it probably cannot achieve very low chrome effluent standards. Overall it is not
especially attractive for developing countries. (4) New tanning agents may contain two-thirds
less chromic oxide than traditional tanning agent(7) Another alternative is recycling of used
chrome liquors for tanning. New plant designs can recycle 80% chrome but they probably
cannot achieve very low chrome effluent standards. (4) The conclusion, therefore, is that
although these alternatives are less costly than chrome precipitation approach, chrome
recovery and recycling through precipitation is generally cost-effective for developing
countries because of savings in purchased chrome.
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Also, there are three main alternatives to the use of chrome for tanning: use of
vegetable tanning agents; use of syntans (e.g., sulphonated products of phenol, cresol and
napthalene); and use of titanium sulphate. Many plants may be using one or more of these
in addition to chrome tanning. These other approaches, however, pose issues related to
product quality and customer acceptance as well as major process changes unlikely to be
attractive to existing companies for their major products. They also have their own
environmental impacts that may require pollution control actions.(4) The conclusion is that
the main opportunity for assisting existing tanneries in developing countries is through using
chrome precipitation and recovery as the BIP.
The more traditional end-of-pipe alternative to chrome recovery through precipitation
is wastewater treatment that can meet effluent standards for chrome. Typically, 20-40% of
chrome is discharged in wastewaters and untreated effluent can contain up to 100 ppm
chrome. A very well designed and operated wastewater treatment plant can achieve less
than 1 ppm of chrome in treated water effluent and less than 4 ppm of chrome in the
treatment sludge.(4) Overall, considering the costs of constructing and operating wastewater
treatment facilities without any offsetting payback through cost reduction, the BIP remains
chrome recovery through precipitation. Moreover, many factors may contribute to less than
optimal operation and maintenance of a wastewater treatment operation.
Solid waste
In finishing operations, mechanical buffing dust is classified in the U.S. as a
hazardous waste. (6) But this is not likely to be the case in developing countries. A U.S.
facility produced only 100 pounds yearly, and this could be sold for beneficial reuse by
another company, saving only $325 annually.(6)
Other types of solid wastes are also produced and have some potential for reuse, but
overall there is minimal economic incentives for reducing solid waste disposal through reuse.
Therefore, no BIP has been presented. If solid waste disposal incurs significant costs, which
is not the case in most developing countries, than a tannery may benefit from finding
companies that can make use of certain solid wastes. Even without significant disposal costs
it would be environmentally preferable for a tannery to facilitate free commercial access to
its solid wastes. For example, fleshings can be used by local rendering companies for
extraction of tallow and grease; untanned hide and skin trimmings can be used to make
gelatine and glue; tanned shavings and trimmings can be used to make leatherboard; and
some solid waste can also be used to recover protein for conversion into feed supplements
for animals or fish.
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No pollution prevention actions for addressing BOD and TSS in water effluent have
been presented, because the very nature of tanning means that they cannot be substantially
avoided Conventional and relatively simple wastewater treatment can remove around 70%
of BOD and up to 95% of suspended solids through physical-chemical treatment(4) The
use of screens in various effluent locations can also provide a low cost way of cutting BOD
and TSS. Even in developing countries wastewater treatment is likely to add less than 2%
to production costs, although significant capital construction costs can pose a serious barrier
to implementation and times of poor market demand and low profits can undermine proper
operation and maintenance. (4)
(1)	Institute for Local Self-Reliance, "Proven Profits From Pollution Prevention vol n,"
Case Study 57, pp. 61-64, 1989. Presentation of a project for chromium recycling at a
tannery in Minnesota.
(2)	Overcash, Michael R., "Techniques for Industrial Pollution Prevention," pp.182-185,
Lewis Publishers, 1986. A translation of an earlier French document; a brief presentation of
a new process to reduce chromium and one to recycle solvent from degreasing, probably
developed in France.
(3)	United Nations Environment Programme, "Audit and Reduction Manual for Industrial
Emissions and Wastes," Case Study 2: Leather Manufacture, pp. 56-77, 1991. A case study
of a tannery in south-east Asia processing cattle hides into finished leather, mainly for shoes,
that received a facility waste reduction assessment; however, chrome recovery was not chosen
over wastewater treatment
(4)	United Nations Environment Programme, "Tanneries and the Environment • A
Technical Guide," 1991. A very comprehensive treatment of the subject, completely different
than previous reference.
(5)	United Nations Environment Programme, "Geaner Production Worldwide," pp. 6-7,
1993. Description of a successful project for recovering and recycling chromium at a Greek
(6)	U.S. EPA, "Environmental Research Brief - Waste Reduction Activities and Options for
a Manufacturer of Finished Leather," 600/S-92/039, October 1992. Presentation of Pollution
Prevention actions at a smaller U.S. company resulting from a facility assessment; the
company no longer tans hides, but finishes tanned leather.
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(7)	U.S. EPA, "Guides to Pollution Prevention - Municipal Pretreatment Programs,"
625/R-93/006, October 1993. A very brief description of an effort at a U.S. firm to reduce
(8)	World Bank, "Environmental Guidelines," 1988. A description of various practices with
no focus on pollution prevention.
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Part Two
Companies in the textile industry vary greatly, both in terms of raw materials and
products, as well as unit operations and degree of integration. Moreover, textile plants can
be very complex in terms of material flows and handling, as well as the equipment used for
various operations. Different production lines may cany out similar operations, but in
different types of equipment The approach taken here is to focus on several main unit
operations for which there are some clear pollution prevention priorities with economic
incentives, and which are present to a considerable degree in textile plants worldwide which
may produce cotton, wool, or synthetic goods, either fabric of finished final products such as
L INDUSTRY SUBCATEGORIES fmajor unit operations^
A.	Wet raw material preparation (pre-fabric. pre-dveingl:
A-l - Wool is scoured or washed in water, and possibly organic solvents (e.g., carbon
tetrachloride, kerosene) to free it from natural grease, soluble salts, and sand and dirt A
detergent or alkali solvent is used, and rinsing is the last step.
A-2 - Yam of cotton and many cotton/synthetic mixtures is sized with starch,
polyvinyl alcohol (PVA), carboxymethyl cellulose, gelatin, glues, or gums to facilitate weaving.
A lubricant may also be applied to facilitate fiber manufacture.
B.	Fabric treatment or preparation fore-dyeingl:
B-l - Wool is carbonized with dilute acid (usually sulfuric) solution to remove
impurities, dried and baked, and mechanically treated. Then it is rinsed and neutralized with
sodium carbonate, and rinsed again. A fulling operation, either alkali (soap or detergent and
sodium carbonate) or acid (usually sulfuric), conditions the material which is then heavily
rinsed to remove all chemicals and foreign materials.
B-2 - Cotton and cotton/synthetic blends are rinsed and de-sized with enzymes or
acid, then scoured with hot alkaline detergents or soap solutions to remove wax and other
non-cellulosic materials, and final rinsed to remove residual detergents or soaps. Bleaching
whitens the material and is done with sodium hypochlorite or hydrogen peroxide; this may be
done before or after de-sizing. Mercerizing may follow to increase dye affinity and strength,
but is not likely with cotton-synthetic blends.
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facility, or the audit being overly narrow in scope, either intentionally or unintentionally, and
ignoring some important parts of a plant
-	a focus on priority pollution prevention methods, materials, or equipment that have
already been used successfully, and avoiding spending a lot of time and effort on less
important, feasible, and proven actions, or even on actions that are really end-of-pipe type
-	use of metrics or critical ratios that guide the collection and analysis of data,
including pre-audit activity by plant personnel, avoiding the frequent problem of pollution
prevention audits or assessments producing marginally useful data or little quantitative
information necessary for maximum implementation
-	having BIP or benchmark critical ratio data that allow evaluation of current plant
operations and practices against a rational standard of performance, and minrniiring
inaccurate assessments of a facility's prior accomplishments or future opportunities to use the
most effective clean technologies
-	using numerical values that establish clear technical objectives for developing and
managing economically justified plant programs based on the use of specific kinds of clean
-	having the ability to consistently track facility performance over time, even if
different people from the company or outside agencies obtain data, avoiding efforts that do
not allow accurate assessments of changes and implementation of recommended actions over
-	being able to make meaningful and accurate comparisons among companies in a
particular industry sector, either in one country or several, providing improved technology
transfer and policy assessments of country needs and progress
2. Specific steps for collecting data
The exact data to be collected at a facility depends on the industry it is in. The
Task 2 sections for leather tanning and textiles present what should be done for all 10
priority industries discussed in Task 1. Assuming that such an analysis has been done and is
made available, the basic steps in data collection for either a company employee or EP3
person, or preferably both, are:
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Step 1 - review the industry subcategories or generic unit operations to identify which ones
are present at the facility and, therefore, which BIPs are relevant; this can be done by
preparing process and materials flow diagrams to show what a facility contains in terms of
basic unit operations and equipment in different production lines
Step 2 - analyze the definitions of priority pollution prevention actions to assess whether
any have already been used completely or partially, and whether facility personnel have any
familiarity with any of them
Step 3 - examine each relevant BIP to understand what data are required; pay special
attention to the units of measurement, which may be different than ones currently used; also
pay special attention to data regarding production output or raw material inputs and how
they may vary over time
Step 4 - identify what required data exist at the facility, and what data have to be obtained;
pay special attention to obtaining accurate data to establish current facility operating
conditions that serve as the "before" or baseline figures prior to implementing a pollution
prevention action; also focus on accurate economic cost data, including direct and indirect
costs to the maximum degree
Step 5 - check the implementation discussions for each relevant BIP to identify potential
obstacles and their solutions; this should be done veiy carefully with attention to technical,
economic, and organizational issues; government policies and regulations that may pose
impediments or disincentives for pollution prevention actions should also be identified; the
focus should be on practical, real world conditions that could stand in the way of
Step 6 - develop a workplan to obtain the data required for BIPs and to verify their
accuracy, paying special attention to changes in production at certain times of the day or
year that may affect the data, the need to obtain data for different pieces of equipment, and
to instruments or devices that may have to be purchased or calibrated in order to make
necessary and accurate measurements
Step 7 - obtain the facility data for the relevant BIPs and compare them with the numerical
values presented as the benchmark figures for the industry sector
Step 8 - develop an explanation of differences between the plant critical ratio data and the
BIP benchmark data established for the industry sector; separate into two categories: worse
than and better than, but submit all data for EP3 database
Step 9 - if facility performance is worse than (numerically greater than) a relevant BIP, then
develop a pollution prevention implementation plan and make preliminary estimates of
potential implementation costs (capital and O&M) and potential savings to calculate simple
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payback periods, perhaps by assuming best case and worst case scenarios for each action so
that a range of payback periods is obtained; identify problems to address in terms of plant
implementation, such as impact on production lines, as well as locating sources of materials
or equipment, and the possible need for tests and demonstrations regarding impacts on
production, product quality and pollution prevention effectiveness (reaching the BIP value);
eventually, if there is implementation, new data for the critical ratios should be obtained and
submitted to EP3
Step 10- if facility performance is better than (numerically less than) relevant BIPs, provide
data to EP3 for establishing a new benchmark figure for that particular unit operation; also
identify any differences in applied methods, materials, or equipment that explain the
improved level of pollution prevention performance over the previous BIP numerical value
Step 11— evaluate the additional, second priority pollution prevention actions presented in
the discussion section for the industry sector and if some appear applicable develop a
pollution prevention implementation plan for them also; the establishment of new BIPs
should also be considered for inclusion in the EP3 database and industry protocol, and if one
seems appropriate a brief proposal should be prepared following the approach given for
leather tanning and textile industries
3. Establishing an EP3 database for benchmark critical ratio data
Each industry sector should contain clearly defined critical ratios and the current
benchmark BIP target values. In addition, EP3 needs to establish a system for collecting and
storing numerical values of critical ratios worse than BIP values, together with some
explanation of why a particular facility had those values. Also, some plant data may offer
values that establish new BIPs that are obtained from EP3 in-country activities, and possibly
from other sources, including information from suppliers of materials or equipment
In addition to numerical values, narrative discussions and descriptions of the specific
methods, materials, or equipment used to reach the values, as well as implementation issues,
should also be placed into the database. What has been presented above for leather tanning
and textiles serves as an example of the type of information that should be collected and
made retrievable. Someone in the field, whether in-country personnel or "experts" from the
U.S. should be able to retrieve industry-specific information for immediate use.
The database should also allow analysis and comparisons of different companies in
one or more countries with regard to critical ratio data that have been flagged to be less
than the current BIP value at the time the data were obtained, or data that have established
new benchmark BIP values. Additionally, the database can store values of critical ratios
obtained at different times for any one facility, providing a statistical tracking capability.
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The database should also permit analysis that reveals whether some EP3 projects or
personnel show some systematic tendency with regard to performance improvements in
facilities and industry sectors, either worse or better than other offices or personnel.
There is also a potential for EP3 to serve as a worldwide source of benchmark
performance data for many unit operations in a number of industries. Should a new method
or technology become the basis for a higher level of performance, then the EP3 system
could rapidly disseminate the new benchmark and the basis for it to the network of
companies that have already participated in the build-up of the database. In this sense, the
EP3 system has the potential to serve as an effective stimulus for transferring clean
technologies worldwide.
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Table 2
Textile Dyeing Industry
Critical Ratios for Best
Industrial Performance
Unit Operation
Critical Ratio
Wool scouring
Kilograms of Biological Oxygen
Demand (BOD) per kilogram of
Recovery of PVA sizing material
Chemical Oxygen Demand (COD)
after recovery compared to COD
before recovery
Reuse of caustic stream in
Kilograms of caustic for makeup
per tonne of yarn
Dyebath reconstitution
COD with reconstitution compared
to COD before reconstitution
Low liquor dyeing
Liters of water per kilogram of
Pad batch dyeing
COD of new process compared to
COD of beck process
Vacuum extraction dyeing
COD of new process compared to
COD of beck process
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C. Dveinp and finishing;
C-l - Dyeing. There are many variations, including batch and continuous dyeing,
using different types of equipment. Printing of fabric is also in this category. Rinsing is
likely to follow.
C-2 - Chemical finishing. Many textile products require the application of various
chemicals, including: resins, softeners, flame retardants, water repellents, and fluorocarbons.
Actions which reduce the use of purchased chemicals represent the highest priority,
followed by water and energy conservation, because textile plants are chemical, water, and
energy intensive.
Five high priority pollution prevention actions are presented (not in any priority
order, but following the logic of the unit operations presented above); other possible actions
are presented in the discussion section. These five priorities are designed to maximize the
effectiveness of an initial assessment or audit performed at any textile facility in a developing
Priority One. In A-l, there are two versions of recovery of materials from wool scouring
liquids. Each kilo of scoured and produced wool produces 1 to 1.5 kilos of waste impurities,
including wool oil and grease, various sheep organic substances, and dirt Consequently,
wool scouring produces a potentially large contribution to BOD from a textile plant In fact
if a mill handles wool, a high BOD in final plant effluent indicates the need for this action,
which is economically justified chiefly because of reduced or avoided wastewater treatment
costs. Thus, without required wastewater treatment or sewer charges, this option is not
likely to be pursued. However, it is also possible to recover the scouring bath by removing
the grease by, for example, ultrafiltration, which may have some market value.
Priority Two(a). In B-2, the recovery of PVA or other chemicals in the de-sizing and
rinsing of cotton and synthetic blends, offers an important method for reducing chemical
purchases and greatly reducing the pollution loading of the water effluent This assumes
that a mill does both the sizing and de-sizing, which is not the case if it is supplied with
fabric from another company. However, even in the latter case there is the potential to
recover sizing chemical for sale to the fabric provider, sufficient to justify investment in
implementing this option.
A U.S. textile mill reported that it recovered 2.5 million pounds of PVA at a net
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savings of 88 cents per pound, and reduced the COD load by 23,000 pounds per day.
Approximately 80% to 85% of the PVA is recovered from the system, including the
efficiency of the ultrafiltration (over 95% recovery) and losses during sizing. For recovering
2JS million pounds of PVA annually, capital costs were $1,275 million, and the payback was 9
months, primarily due to the reduced purchase of PVA and not considering reduced
wastewater treatment costs.(2) Thus, the economics are attractive for developing countries.
Priority Two(b). If a mercerizing process (B-2) is used, then there is major opportunity to
cut chemical and water use. In a traditional process, a strong caustic soda and wetting agent
solution is used for the mercerizing, and this is followed by two hot water rinses and then a
cold water rinse (a total of 600 liters for processing 15 kg of yarn, or 80 l/kg). The three
rinsewaters are then neutralized with hydrochloric acid prior to wastewater treatment
Forming and recycling a concentrated caustic stream provides a number of benefits.
In a French mercerizing process, water use was reduced from 80 cubic m/tonne (80
l/kg) of yarn to 12 cubic m/tonne (12 l/kg); caustic soda was reduced from 360 kg/tonne of
yarn to 100 kg/tonne of yarn; COD was reduced from 22 to 10 kgAonne. This approach
added about $100,000 to the capital cost of the mercerizing line, but annual savings exceeded
$200,000 from reduced chemical use, producing a payback of about six months, which should
be applicable to developing countries.(6)
This type of caustic soda recovery was also done in a plant in India, where feedstock
use was reduced by 35% and produced significant savings. (18)
Priority Three. In dyeing operations (C), the chief pollution prevention goal is to reduce
chemical use, followed by reduced water and energy use, and wastewater treatment demand.
A number of basic methods following two strategies can be used to implement this priority,
as presented below. The two strategies are dye bath reconstitution and alternatives to beck
A major pollution prevention opportunity is to reconstitute an exhausted dye batch
bath by analyzing it for remaining chemical/dye quantities and using new dye to obtain a
suitable bath for subsequent reuse and dyeing. This reduces purchased dye and cuts
pollution loading of the effluent and wastewater treatment capacity needs. In one case,
wastewater flow was reduced 34% and COD was reduced 33%.(4)
As to the economic costs and benefits, for a U.S. dyehouse with five 1,500 gallon
becks the capital cost was reported to be $89,000 (for instrument, computer, labware, five
2,000 gaL holding tanks, pumps, controls, piping) with yearly operating costs of $10,000. The
yearly savings were $105,000 ($75,000 from chemical savings, $22,500 from energy savings,
and the remainder from reduced water and sewer costs), yielding a payback of about a year
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February 28, 1994

(16 months with chemical savings only).
In another U.S. plant a $15,000 investment for modification of a jet dyeing machine
produced savings of $120 to $140 per cycle from reduced chemical, energy, and water costs
(a 72% reduction in water), yielding a payback of 2 months.(15) A U.S. nylon pantyhose
company saved $.02 per pound of finished goods by obtaining a 19% reduction in dyebath
usage, a 35% reduction in auxiliary chemicals, a 57% energy reduction, and a 43% water
costs.(16) Generally, the U.S. experience is that using this approach reduces auxiliary
chemical costs by 60%, dye costs by 19%, and water/sewer costs by 43%.(4)
In a French application of this approach, water use was reduced from 50 cubic
m/tonne (50 1/kg) of fabric to 35 cubic m/tonne (35 1/kg), a 30% reduction (consistent with
above example). COD was sharply reduced and operating costs were reduced by about 90%,
producing a payback of about six months.(6)
Thus, even in developing countries with no/low cost water, this approach is likely to
be justified economically because of chemical savings. This strategy is widely applicable, and
not only to repeat shade dyeing.
The second basic strategy is to use some alternative to conventional beck dyeing,
including: low liquor ratio jet dyeing; batch pad dyeing; or vacuum extraction dyeing. All of
these offer solid economic benefits while also reducing dye and water consumption. See
implementation discussion below. However, because they represent significant capital
investments and the need for new dye practices, they pose serious issues.
Priority Four. Total facility water conservation (A - C) is crucial, because virtually every
significant textile processing step involves water and, hence, an opportunity for water
conservation. Generally, water consumption is greatest for rinsing and washing operations,
rather than direct processing water needs. Although each operation in a plant should be
examined and optimized, it is useful to assess total facility use; one reason is that this helps
¦> establish the total economic incentive for taking what can be a large number of small actions
that individually may be perceived as insignificant
The use of multiple rinsing to replace overflow and soak rinsing offers benefits. In
one case for a mill in Chile, three small rinses could remove more dye than two large rinses,
requiring only 60% of the time and 60% of the water.(l)
In a U.S. example, reusing 75,000 gallons per day of bleach wastewater for scouring
had a capital cost of $23,000, with yearly operating costs of $1,300. With an annual saving
of $95,000, the payback was three months, without considering avoided wastewater treatment
costs, such as might be the case in a developing country. (5)
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February 28, 1994

A French case described the use of vacuum draining of fabric after dyeing followed
by rinsing. This reduced water use from over 400 cubic m/tonne (400 1/kg) of fabric to ISO
cubic m/tonne (150 1/kg), and it also reduced COD and BOD by about 50%. Operating
costs were reduced 22%.(6)
A U.S. review of water conservation in textile mills has stressed the important
potential of cutting water use by 30% or more.(5) In developing countries, where water has
been free or very low cost, it is probably more realistic to think of a 50% reduction being
possible, because of lack of attention to water use. For example, a plant in India cut its
fresh water consumption by 93% through a host of water conservation measures and cut
production costs significantly.(19) Thus, it should be practical to identify and act on a host
of water conservation actions in developing countries.
Priority No. Five. Total facility energy conservation (A - C) is appropriate for a pollution
prevention audit, because there is a strong link between many different types of pollution
prevention actions and energy consumption. The use of heat exchangers within the
manufacturing area has been widely successful in textile mills, because large volumes of
heated water batches are used. However, most pollution prevention audits have not focused
on boilers and their control and efficiency.
A U.S. case study described the use of a heat exchanger system by a hosiery
manufacturer. The system recovers heat from spent dye solutions and uses the heat to
preheat subsequent dyebaths from 55 degrees F to about 105 degrees F; it saved about
52,000 gallons of fuel oil yearly and reduced air pollution from the plant heating plant The
$100,000 capital investment was paid back in two years.(3) A French case described the use
of a heat exchanger that used the heat from dyebath water to heat water for rinsing. This
reduced energy consumption by 15%.(6)
Corresponding to the above pollution prevention priorities, specific BIP targets have
been developed, as presented below. These do not address all of the many environmental
issues for textile plants, but they do provide a relatively quick and easy method for people
performing a facility assessment Other actions are presented in the discussion section. The
set of BIPs offers a strategic framework for identifying and evaluating the major pollution
prevention opportunities in a facility, especially important, immediate pollution prevention
opportunities. In all cases, the objective is to numerically reduce the BIP critical ratio.
H& A-EP3/HBI-011 -94
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February 28, 1994

BIP No.l - Wool scouring
The reduction in BOD by recovery of oil and grease is the basis of the BIP:
BIP = .5 kg BOD/kg of wool
BIP No. 2(a1 - Recovery of PVA sizing material
Measuring COD change in the de-sizing effluent is probably the easiest way to
measure this action:
BIP = 0.8 COD after recovery/COD before recovery
BIP No. - Reuse of caustic stream for mercen'Tinp
A major reduction in new caustic is the key to measuring success:
BIP = 100 kg makeup caustic/tonne of yarn
BIP No. 3(al - Dvebath reconstitution
The problem in establishing a target that can be easily measured is that the amount
and type of dyes used vary enormously as do dyebath practices. The simplest solution is
probably to use COD reduction:
BIP = J COD with reconstitution /COD before
BIP No. 3fbl - Alternatives to beck dveinp
Low liquor dyeing:
Hie liquor ratio is the critical ratio of the amount of water in liters to kilograms of
fabric in the dye bath. In conventional dyeing the ratio can be in the range 10 to 20 1
water/kg fabric or even more. Hie goal is to reduce this ratio as much as possible without
reducing product quality.
BIP 3(b) = 6 1 water/kg fabric
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February 28, 1994

Pad Batch Dyeing:
The reduction in dye quantity is measured through COD reduction.
BIP = 25 COD new process/COD beck process
Vacuum Extraction Dyeing
Use of modern vacuum dyeing equipment offers considerable potential to reduce
dyes tuff and auxiliary chemicals. The reduction can be measured through COD reduction.
BIP = 25 COD new process/COD beck process
BIP No. 4 - Water conservation
Probably the most pragmatic approach is to consider the amount of water use
facility-wide. Amounts of water used in each facility operation can be optimized, but it is
useful to take a systems approach also, one that looks at the entire facility and evaluates the
total costs and benefits of many water conservation actions. Assuming that a facility is
integrated and includes raw material preparation, fabric preparation, and dyeing/finishing the
following BIP is applicable.
BIP = 200 I/kg of produced fabric (or 200 cubic m/tonne)
BIP No. 5 - F.nerj>v conservation
There are a multitude of potential energy conserving options in a typical textile mill,
including: reducing use and waste of hot water, remedying steam trap losses, and correcting
boiler inefficiencies. Use of a vacuum water removal system can reduce energy consumption
for drying. Unless a plant has already received an energy audit and acted on
recommendations, a pollution prevention assessment should be considered capable of
identifying at least a 25% energy reduction, mainly because of the actions taken related to
improvements in dyeing and various water conservation actions.
BIP = .75 amount of fuel after assessment/amount of initial fuel consumption (for
same period of time and level of production)
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February 28, 1994

BIP No. 1 - Wool scouring
There are two main options for recovery of oil and grease from wool scouring
effluent First, some type of grease recovery is practical through centrifuging. The low
density, concentrated stream on top contains about 60% of the grease for recovery (assuming
some market demand). The medium density stream is recycled upstream for reuse in
scouring, thus reducing water and chemical use. The heavy density bottom layer, with
considerable dirt and grit, can be sent to the treatment plant or sewered.(lO)
Using acid cracking, sulfuric acid breaks the grease water emulsion after initial
separation; the liquor is neutralized with lime, and 90 to 95% of the grease is recovered.(10)
Thus, this action can largely eliminate the BOD from wool scouring, which otherwise can be
several hundred mg/L Technically, the above actions are comparable in complexity to
existing textile mill operations.
Other than finding a market for the recovered grease, another possibility that has
been described is to use an evaporator and drying oven to process the recovered material
and then use the dry, oQy distillate as a fuel in the plant's boiler. This eliminates the
wastewater stream from wool scouring altogether, but produces some solid ash (about 100
kg/tonne) and is likely to be an expensive action.(6) This option only makes economic sense
if a significant wastewater treatment facility cost can be eliminated, and where fuel costs are
significant also.
BIP No. 2(a) - Recovery of PVA siring material
Accurate base level data on sizing chemical use and costs must be obtained.
Implementation of recovery options requires considerable technical and cost information for
specific, commercially available ultrafiltration or reverse osmosis equipment All the issues
for advanced technology usage in developing countries exist, including: concerns about
importing equipment; having effective technical and maintenance support; spare parts for
equipment; training facility technical staff; and feeling confident about payback and
maintaining production output and product quality.
In one case of PVA recovery, ultrafiltration was reported to cost 12 cents per pound
of recovered PVA that costs Si per pound to purchase as virgin material. Ultrafiltration
produces two recyclable streams, and the cross-flow filters are self-cleaning. The concentrate
stream contains the size material, oils, and waxes that can be reused for yarn sizing. The
permeate stream consists of hot water and detergent which is returned to the washer. This
reduces raw chemical, water, and energy costs.(6)
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February 28, 1994

PVA and other sizing compounds, such as PEG, polyaciylates, and starch, can also be
recovered, if not with ultrafiltration, then with reverse osmosis, which is more technically
complex than ultrafiltration. An Italian company has reported success with reverse osmosis
in plants producing acrylic, cotton and wool products, claiming to virtually eliminate highly
polluted effluents, from dyeing, wool washing, and de-sizing, and creating reusable water for
basic processing, because virtually all contaminants are removed and reused. Benefits cited
include: 95% waste reduction, and 95% water reduction. Payback varied from 1 to 2 years,
depending on costs of chemicals, energy, and water.(ll)
BEP No. 2fb1 - Reuse of caustic stream for lw-rcftrmnfr
Implementation requires accurate data on the current costs of mercerizing. The
pollution prevention alternative of forming a concentrated reusable caustic stream for
mercerizing is to use a series of three countercurrent rinses. Passing the first, concentrated,
rinse water through an evaporator produces a concentrated caustic stream for reuse in the
mercerizing tank and a small amount of condensate for acid neutralization prior to
wastewater treatment(6)
BIP No. 3fa1 Bath Reconstitution
As to implementation of dyebath reconstitution, there are four steps:
-	Bath retention. Saving the just exhausted dye bath by pumping to a holding tank,
while the product is rinsed in the same machine in which it was dyed; the dye bath can be
returned after the rinsed product is removed. Alternatively, the dyed product can be pulled
and moved to another tank for rinsing, depending on what equipment or plant space is
-	Analysis. Typically, only about 10% of the dye may be carried off in the product,
but certain operating conditions require an estimate of the quantity needed to replenish the
bath to ensure consistent dyeing. Some instrument, such as a spectrophotometer, must be
used together with a computer to calculate the required dyestuff additions. This should only
take a few minutes per cycle.
-	Reconstitution. This means adding back the quantities of water, auxiliary
chemicals, and dyestuffs needed for the next dyeing cycle. Even if there is some build-up of
surfactants, this can be compensated for by slightly increasing the amount of dye added. Yet
there is some finite number of maximum reuse cycles, which for many plants is in the order
of 10 to 20 reuse cycles.
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February 28, 1994

- Reuse. The major difference in reusing a dyebath is that the starting temperature
is generally higher than that of a fresh water bath. In general, however, the loss of heat
during storage and the cooling effect of the make-up water are sufficient to decrease the dye
bath temperature to a safe leveL If the stored and make-up waters do not lower the
temperature to a safe level, a heat exchanger may be cost-effective.
The key implementation need is to convince facility managers of the technical
feasibility and economic benefits of this approach. Some instruments will be necessary to
make appropriate measurements for achieving effective process control.
BIP No. 3(b) Alternatives to Beck Dveing
There are significant obstacles to implementation. Using alternatives to traditional
beck dyeing means investing in major new plant equipment This means capital investment,
training needs, and addressing concerns about production scheduling and product quality. A
lot of detailed and accurate information must be assembled to raise the level of comfort
about using different technology. Usually, senior plant managers and engineers are likely to
have had some exposure to these alternatives, through technical literature, attendance at
industry exhibits, or visits to other facilities.
Low Liquor Ratio Jet Dyeing
Hie liquor ratio is critical. It is the ratio of the amount of water (in liters) to the
amount of fabric (in kilograms) in the dye bath. For successful dyeing, modifications to the
process are generally required. Jet dyeing is probably the key, important version of this
method. It takes place in a closed system where nozzles emit a high pressure stream of dye
that penetrates the fabric and moves the fabric along a tube. The fluid moves faster than
the fabric to move the fabric through the tube without touching the walls of the tube.
Another variation consists of air transport (9)
Benefits include: shorter dyeing cycles, reduced dyestuffs and chemicals, less steam
and water, less energy consumption, and less pollutant loading in wastewater and treatment
Pad Batch Dyeing
This is a cold method of dyeing cellulosics. The fabric is saturated with the premised
dye liquor, then passed through rollers that squeeze out the excess and cause dye
penetration. This is followed by storage in containers (e.g., boxes, steamers) covered with
plastic film for 2 to 12 hours. Then the fabric is washed.(9)
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February 28, 1994

Benefits include: a simple, fast, and flexible process for woven and knitted fabrics;
use of high reactivity dyes promotes rapid fixation and stability that provide shade reliability
and repeatability; virtual elimination of a number of auxiliary chemicals (e.g., anti-migrants,
fixatives, leveling agents); less water and energy consumption; and reduced pollutant loading
and wastewater treatment (up to 80% less BOD and COD over atmospheric becks). Water
use of 17 1/kg of fabric and energy use less than 4,400 BTUs per kilogram of fabric are
possible, as compared to 170 1/kg and 20,000 BTUs for conventional use of an atmospheric
Vacuum Extraction Dyeing
Various pieces of commercial equipment are available and used worldwide; they make
use of vacuum extraction principles and a low add-on approach. A vacuum unit is used after
wet dye is applied to the fabric; the vacuum can be precisely controlled so that the amount
of dye is controlled plus or minus one percent Benefits include improved dyeing as well as
reduced dye, chemical and energy use for drying. Waste dye bath is reduced from 90 liters
per change in a high quality dye padder to 12 liters on vacuum equipment that is especially
efficient for short runs. Various chemical finishes can also be applied by low material
add-on vacuum equipment Reductions of 30% - 50% in chemical consumption and
associated raw material cost savings offer a payback of weeks or months, not years. Dyebath
and chemical finishes can be recovered, filtered, and reused. (14)
BIP No. 4 - Water conservation
A key implementation issue is obtaining accurate data on water use for the total
facility as well as individual operations and separate production lines. Even if metering is
used, it is usually necessary to verify data by measuring actual flow rates.
The economic incentive for conservation, of course, may be reduced in developing
countries, because of low water cost and in many cases no requirement for wastewater
treatment (or no sewer or municipal wastewater treatment costs). However, the cost of
water conservation actions tends to be low and there are clear indications that costs will be
rising in most developing countries, both for water inputs -and wastewater treatment In most
cases it probably is wise to package all water conservation actions together so that the best
investment cost-payback scenario is described and communicated to plant management
Otherwise, not all actions may be implemented.
Also, product quality concerns and physical plant limitations can sometimes block
some water conservation actions. But the former should be evaluated through testing for
negative impacts, rather than always assuming that any water conservation change is
detrimental to product quality. Most industrial processes err on the side of over-using water,
especially in countries where water has been essentially a no cost input
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February 28, 1994

The reconstitution of dyebaths, discussed above, is a fundamental method of water
conservation. Reuse of dirty water for less critical processing is another fundamental
method. For example, the colored wastewater from a soaping operation can be reused at a
backgrey washer, which does not require very clean water. Or the wastewater can be used
for cleaning floors and equipment in the dye or print shop. Similarly, rinsewater from
scouring can be reused for de-sizing, or for washing floors and equipment Mercerizing or
bleaching rinsewater can be reused in scouring and de-sizing, if size recovery is not practiced,
because the caustic or bleach stream will likely degrade sizing compounds. Jet weaving
wastewater can be reused in the de-sizing or scouring process, if fabric impurities and oils
are removed with in-line filters.(5)
Counter-current washing should always be considered. This means using the cleanest
water for the cleanest fabric, with the most contaminated water contacting the fabric that
first exits a process step for washing or rinsing. This method can be used for: de-size
washing, scour washing, mercerizing washing, bleach washing, and dye rinsing.
Other fundamental actions that can cumulatively produce large reductions in water
include: replacing overflow rinsing with more controlled actions; use of automatic shutoff
valves, based on time, level or temperature; use of flow control valves, especially in cleaning
areas; and general good housekeeping such as minimising leaks and spills, proper
maintenance of production equipment, and identification of unnecessary washing of
Vacuum extraction washing is a modern approach, requiring little space and relatively
low capital A major commercial U.S. equipment maker offers a stage washer using vacuum
technology and state-of-the-art computer process controls. It has counterflow and chemical
addition capabilities; it reduces water consumption, energy consumption, washing time, and
labor, and it adds considerable flexibility and effectiveness.(9)(14)
Another company makes a low wash process which offers benefits, especially for
piece dyeing of cotton fabrics with reactive dyes. Compared to conventional drop/fill or
overflow methods, this equipment reduces rinse water by about 30%, rinse cycle times by
more than 50%, and overall cycle times for complete dye procedure by about 18%, while
still achieving the equivalent level of rinsing effectiveness of conventional methods.(9)
BIP No. 5 - F.n<»rpv conservation
There are a multitude of potential energy conserving options in a typical textile mill,
including: use of heat exchangers, reducing use and waste of hot water, remedying steam trap
losses, and correcting boiler inefficiencies. Use of a vacuum water removal system can
reduce energy consumption for drying. A key implementation issue is obtaining accurate
data on energy consumption and costs relative to the implementation costs of specific
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February 28,1994

The relatively large number of actions presented below is indicative of the diversity in
textile plants. It is extremely important to have an accurate and complete characterization of
a textile plant in terms of descriptive process diagrams of different production lines and
operations in the facility.
Wnnl r-flrhnniVinp
With use of sulfuric acid and hard water containing calcium ions, calcium sulphate
may precipitate, requiring periodic dumping of the bath and a potential Ph spike in the
effluent Using an in-tank filter for the bath can remove the calcium sulphate, eliminate
contamination of the fabric, save water and wastewater treatment chemicals. A payback of 2
years has been reported^ 1)
Recovery of fiber lubricant
A U.S. fiber manufacture had a problem with high BOD caused by a costly
proprietary mineral oQ lubricant compound carried away by a continuous rinse process. A
reverse osmosis system concentrates the lubricant (to a 20% solution) and separates the
water. A feedback control system uses an automatic sensor-controlled valve to compensate
for feed concentration increases. The recovery of the lubricant reduced processing costs and
gave a payback of six months.(12)
Zinc recovery in ravon yarn manufacture
In a U.S. plant making rayon yam, zinc is used as a regeneration retardant in the
acid spinning bath of the process to slow down the formation of the yam. The zinc is not
consumed, but enters the yarn wash water and equipment wash water. A two-stage
precipitation process produces a zinc hydroxide sludge which is treated with sulfuric acid to
produce zinc sulfate that is reused in the spinning bath. This is an improved precipitation
system that saved $383,000 annually.(13)
Reconstituting bleach baths
Another pollution prevention opportunity is to reconstitute bleach baths, and use
them for many cycles. The basic approach is to establish some procedures for determining
how much fresh chemical must be added to a bath. The chief benefits are reduced chemical
purchases and reduced water use.(4)
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February 28, 1994

Dveing material change
A French case described the use of a more dilute solution of "white spirit" (Le.,
presumably solvent) in the preparation of paste for color printing (dyeing) of fabric. The
amount of white spirit was reduced from 770 g/kg of paste to 200 g/kg, and a process
controller was added to the paste preparation line. Discharge of the solvent in water was
reduced by about 85%, in air it was reduced by 70%, and the amount of waste coloring
paste was reduced by 50%. The small additional capital cost for the process controller was
paid back in about six months.(6)
Dveing auxiliary chemical substitution
A large textile company in India uses sulphur deep color dyes. The original process
required the use of sodium sulphide, which causes a major toxic sulphide loading of effluent.
The company discovered through a study that an alkaline solution of glucose could perform
as well as the sulphide. It found a low cost source, which was a by-product of the maize
starch industry, called hydrol, that had about 50% of reducing sugars. The sodium sulphide
could be replaced by a combination of hydrol and caustic soda. The dyed product quality
was improved. Sulphide concentration in effluent was reduced from 30 ppm to less than 2
ppm, with only a slight increase in BOD. No new equipment was necessary, and there was a
significant avoided cost for more wastewater treatment capacity. (7)
De-f>ilinp of fabric
Some textile plants use some type of simple fabric cleaning to remove oil The
traditional approach is to use a water-detergent washing solution that is then allowed to
settle. The decanted water is discharged or sent to the wastewater treatment plant, and the
sludge is disposed. Water use is about 45 cubic m/tonne of fabric. If wastewater treatment
is required, then the alternative of using a chemical solvent approach might be economically
attractive. However, the key need is to use an efficient solvent recovery unit. In a
description of this approach, using solvent distillation equipment, water was eliminated
altogether and annual costs were reduced by 50%.(6)
Chemical finishing
A variety of toxic chemicals may be used to achieve certain desired properties of
fabric. The pollution prevention goal should be to find less toxic alternatives, preferably
ones that are not significantly more expensive. However, because no major operation is
likely to be done after finishing, there is little potential to avoid pollution control costs,
although some water pollution is possible from equipment washing and washing after spills,
for example.
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February 28, 1994

Total Suspended Solids
If wastewater treatment is being required, then attention can be given to the use of
filters and screens throughout the facility. This can trap lint and other sources of TSS and
sharply reduce TSS in treated effluent This type of action can also reduce water and
chemical uses by removing the cause of various types of leaks in equipment
Solid waste reuse
Many types of solid waste are created in a textile mill. Material combings, cuttings,
and shavings, for example, can be used by other companies, including stuffing for toys,
furniture, and padded shipping envelopes. This kind of recycling is preferable to landfilling
and, at the very least, can reduce solid waste transportation costs for the textile plant A
plant in India, for example, dewatered solid residues were bagged and sold to board and
cellulose powder manufacturers or packing uses. (21)
Equipment cleaning solvent reuse
Many textile plants use strong chemical solvents to clean equipment In fact,
although rarely focused on, this use of synthetic chemical solvents has been found to be very
substantial in the U.S. and is likely to be important in foreign textile plants also. For
example, an analysis of legally defined hazardous waste generation in South Carolina found
that in 1988: the average plant producing yarn and fabric generated 4,415 pounds of
solvents; the average finishing mill, engaged only in bleaching, dyeing or printing fabrics
generated 20307 pounds of solvent; the average plant producing fabrics of exotic materials
or carpets generated 87,470 pounds of solvent; and the average plant producing finished
apparel only generated 7,480 pounds of solvent waste.(23) Although solvent use has been
decreasing rapidly in the U.S. because of regulatory and cost pressures, it is likely to be at
high levels in textile plants in developing countries.
This use of solvents offers an opportunity to reuse solvent or substitute with a
non-toxic, biodegradable water based solvent, because the intrinsic need for cleaning agents
cannot be avoided. Both alternatives should be seriously considered for any textile mill, and
there are significant opportunities to reduce plant costs through either buying less synthetic
solvent because of recycling, or using water based solvents that reduce the need for
wastewater treatment In most developing countries it may be easier and more cost effective
to use the onsite recycling approach, unless there are local, commercial sources of alternative
water based cleaners.
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February 28, 1994

A U.S. manufacturer of high twist filament yarn originally was using the solvent
1,1,1 -trichloroethane to remove greases, oils, dyes and chemicals from yarn cleaning
machinery parts. They installed a solvent recovery distillation unit, which recovered 90% of
the solvent The payback period was about a month. It was also reported that the company
had intentions of finding an alternative, non-toxic solvent(8)
A U.S. plant recovered 90% of isopropyl alcohol in a distillation unit purchased for
$7,500 and the still bottoms were used by the company in another product line. The annual
savings of $90,000 produced a payback of less than one month.(17) Another U.S. plant
installed a distillation unit to recover iso-propyl acetate and achieved a payback of 2
years.(20) A different U.S. plant segregated waste toluene used for cleaning printing press
equipment, and then used the materials for thinning the same type and color of ink, and a
carbon adsorption recovery system provides 90% recovery from the printing lines. (22)
(1)	Bilkovich, William W., "Pollution Prevention Diagnostic Study - Proquindus, S.A.,
Santiago, Chile," Jan. 1994. An early EP3 facility assessment performed prior to this
performance approach.
(2)	Huisingh, Donald (Ed.), "Making Pollution Prevention Pay," Pergamon Press, 1982. One
of the earliest collection of application information.
(3)	Huisingh, Donald et al, "Proven Profits from Pollution Prevention: Case Studies in
Resource Conservation and Waste Reduction," Institute for Local Self-Reliance, Wash., DC,
1986. A good, early source of case examples with varying degrees of completeness.
(4)	North Carolina Pollution Prevention Pays Program, "Dyebath and Bleach Bath
Reconstitution for Textile Mills," undated. Available through EPA's Pollution Prevention
information clearinghouse.
(5)	North Carolina Pollution Prevention Pays Program, "Water Conservation for Textile
Mills," undated. Available through EPA's Pollution Prevention information clearinghouse.
(6)	Overcash, Michael R., "Techniques for Industrial Pollution Prevention," Lewis Pub., 1986.
Mostly a translation of a French document; case examples often have very limited
(7)	United Nations Environment Programme, "Cleaner Production Worldwide," 1993. A very
useful presentation of a limited number of case examples.
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February 28, 1994

(8)	U.S. EPA, "Achievements in Source Reduction and Recycling for Ten Industries in the
United States," Sept 1991. Some recent case examples.
(9)	Univ. North Carolina, "Textile Technology Sourcebook," July 1993. A very useful
description of approaches and commercial sources for alternative technologies.
(10)	World Bank, "Environmental Guidelines," 1988. Has two sections related to textile
practices with very useful data on industrial practices.
(11)	Case study abstract from UNEP ICPIC database titled "Membrane process for water
and auxiliary chemicals recovery from effluents of textile industries;" undated.
(12)	Case study abstract from UNEP ICPIC database titled "Comparison of solvent
management on the finishing line;" Nov. 1985.
(13)	Case study abstract from UNEP ICPIC database titled "Recycling zinc in viscose rayon
plants by two-stage precipitation," undated.
(14)	Technical information, EVAC Corp., Spartanburg, S.C
(15)	Tincher, W. and F. Cook, "Reusing Dyebaths in Jet Dyeing," Textile Chemist and
Colourist, v. 13, n.12, pp 266-269.
(16)	Case study abstract from UNEP ICPIC database titled "Dye Baths are Reused in the
Textile Industry," undated.
(17)	Huisingh, D., et al, "Profits of Pollution Prevention - A Compendium of North Carolina
Case Studies," N. Carolina Dept. Natural Resources and Community Development, May
(18)	Case study abstract from UNEP ICPIC database titled "Efficient Recovery and Reuse of
Caustic Soda from Mercerizing Washwateis," undated.
(19)	Case study abstract from UNEP ICPIC database titled "Recovery and Reuse of Water
in Wet Processing in a Textile Mill, undated.
(20)	Case study abstract from UNEP ICPIC database titled "Reuse of Iso-Propyl Acetate
during Printing Equipment Cleanup in a Textile Industry," undated.
(21)	Case study abstract from UNEP ICPIC database titled "Recovery and Reuse of Solid
Waste from a Synthetic Textile Industry," undated.
(22)	Case study abstract from UNEP ICPIC database titled "Recovery of Toluene from
page 37
February 28, 1994

Printing Press Geanup in a Textile Industry," undated.
(23) Morse, John S., "Analysis of Hazardous Waste Generation in South Carolina," Univ. of
South Carolina, undated.
page 38
February 28, 1994

Task 3. Collection of data from facilities
1. Benefits of the approach
The critical ratio pollution prevention priorities methodology establishes a framework
for optimizing facility audits or assessments, and making them more consistent also. Hie
approach of using ratios rather than data for a single parameter intrinsically provides a
normalization of data that has some real meaning among very different industrial facilities.
That is, because of major differences in plant size, production outputs and material flows,
specific figures for one facility (e.g., amount of chemical used at a facility in a year) have
little meaning for a different facility. Thus, it is important to use ratios that provide a
context or basis for a quantity, such as amount of chemical not by itself, but in terms of
amount of chemical used per metric tonne of either raw material processed or final product
Although there have been many hundreds of facility pollution prevention audits or
assessments over the last decade, it is clear from examining published and unpublished
documents that the process has not been optimized. One of the most frequent problems,
other than a complete lack of data, is the presentation of data without other information
that would allow the calculation of an appropriate ratio. In the latter case, the usefulness of
a published case example is made very difficult The lack of standard approaches to
gathering information for assessing opportunities and performance has contributed to a
generally low level of post-assessment implementation by facility engineers and managers.
Widely varying facility assessment approaches have also contributed to ineffective
transfer of commercially proven and available clean technologies that could be widely
adopted by companies in developing countries. It is also reasonable to believe that the ad
hoc approaches used in collecting and presenting data have not effectively supported the
creation of in-country technical capabilities and sustainable pollution prevention programs.
The concept of identifying benchmark data as representing best industrial practice has been
shown to be extremely effective in promoting industrial improvements. While there is always
some legitimate need for experts, a standardized methodology and a set of benchmark data
will promote effective facility assessments by technically educated professionals in developing
countries who may, however, have had little field experience or formal pollution prevention
The general benefits of the BIP/critical ratio approach used in this report are
summarized as follows:
- a focus on a relatively small number of unit operations at a facility, increasing the
likelihood that audit time and effort are not wasted on relatively insignificant aspects of a
page 39
February 28, 1994

B. Leaders Guide for P2

C. Approaches to P3

by Deborah Hanlon and Jeuli Bartenstein U.S. EPA
General Information
The purpose of a Pollution Prevention Orientation Workshop is to help people
understand the concept and philosophy of pollution prevention and to adopt a
prevention approach to environmental decision making. Therefore, the fundamental
goal of this type of training is simply to help people begin to think pollution prevention.
The attached curriculum outlines one example of a framework for a course to
introduce this concept using the participatory methodology as taught by the EPA
Institute. Although there is a lot to learn and know about pollution prevention, Keep It
Simple when designing a workshop. Try to introduce no more than four or five key
topics that you feel comfortable in teaching.
The goal of a pollution prevention orientation training program is to introduce the
concept and to help people begin to think pollution prevention. Conducting creative
and interesting workshops is one way to accomplish this goal.
Duration and timing
Because the needs of the audience may vary enormously, enough material has
been provided to allow the instructor to select and tailor the information to the level of
the group. A three hour session is sufficient. A room large enough to hold the
participants in a U format with tables and additional break-out space is the best setting.
Small workshops of 15-25 are better for discussion and discovery learning
techniques. It is always important to know the audience and their level of knowledge.
Gather as much information as possible about the audience prior to the workshop and
determine their level of knowledge in introductions and through discussion during the
There are a variety of pollution prevention materials that can be used for a creative
and interesting orientation workshop. Most people will not read a lot after leaving the
workshop so it is best (in the interest of pollution prevention) to show what is available
and how to obtain materials. Once the participants are interested in the pollution
prevention topic, they will search out additional information that may be of particular
interest to them.
Be prepared and make sure your have the workshop essentials:
'Overhead projector with extra bulbs	* Name plates
*35 mm projector with extra bulbs	* Masking tape * Flip charts with paper
Prepare essential flipcharts prior to the session.

Pollution Prevention Orientation Workshop
Instructor's Guide
1. Instructors greeting and introduction:	instructor Notes
Welcome people to the course and make them feel comfortable
as they come in to the room. Introduce yourself and set a tone
of openness so that others will follow in their introductions.
2.	Purpose of Workshop:
Have a prepared fiipchart with course objectives:
The purpose of this course is:
a.	To Introduce pollution prevention concepts, philosophy and
b.	To explore problems and potential solutions/incentives for
implementing pollution prevention activities; and
c.	To provide tools and resources to implement pollution
prevention in programs and activities where appropriate;
Have a prepared fiipchart with orientation agenda:
The following issues will be discussed and discovered in this
interactive orientation workshop:
*	What is Pollution Prevention?
*	Why it is important?
*	What are some of the incentives and barriers to
implementing prevention?
*	How do we implement Pollution Prevention
*	Resources and information
Ask for additions to or clarifications of agenda.
Confirm group expectations on what will happen in workshop.
3.	Participant introductions:
Conduct an ice breaker. For example, have small groups
describe something that they do which contributes to the
generation of pollution; and name one or two things that they
can do to prevent pollution.
Examples: * I drive to work alone	I could
Carpool, metro. *l could change purchasing habits	I could
buy environmentally friendly products with less packaging.

4. What is pollution prevention? (clean instructor Notes
production?)	instructor Notes
Training objectives:
a.	To ensure participants understand what pollution prevention
is and is not and;
b.	To ensure that participants understand the difference
between prevention activities and pollution control and
management activities. End this session with a discussion
on the benefits of preventing pollution as compared to
managing or regulating pollution after it is generated or
released into the environment.
Make sure that you, as the instructor, have a clear grasp of the
concept and definition as used by EPA and/or your own
agency. Use definitions from the Pollution Prevention Act and
Agency memos etc.
Training activity to help participants understand and
identify with the concept of pollution prevention:
Flip Chart
(define each word separately in own words)
Ask participants to define prevention. Chart responses.
Ask "What other things are associated with prevention? health,
fire, crime etc. (concept is important)
Show definition of prevention;
"activity that keeps something from happening,
anticipation of outcome" source: Webster's Dictionary
Ask participants to contribute words that might be used to define
pollution	ie. waste, smog, contamination,
degradation, wastewater etc. Show overhead with definition of
pollution as defined by EPA's Science Advisory Board.
" Pollution is the undesirable change in the physical,
chemical or biological characteristics of air, water or
land that may or will harmfully effect human life or
that of other desirable species, our industrial
processes, living conditions or cultural assets, or that
may or will waste or deteriorate raw material
Ask participants to define pollution prevention in plain English
(what it means to them)

Finally show EPA's formal definition of pollution prevention:*
Instructor Notes
"Pollution Prevention is considered by EPA to mean
source reduction. Source reduction, as defined in
the Pollution Prevention Act of 1990 states that
"source reduction is any practice that reduces the
amount of any hazardous substance, pollutant or
contaminant entering a waste stream or released into
the environment prior to recycling, treatment or
disposal." Pollution Prevention applies to all forms of
pollutants; air pollution, water pollution as well as
hazardous and non-hazardous solid wastes and
applies to all sectors of society including industry,
government, agriculture, energy, transportation and
consumers, source: EPA Pollution Prevention Policy
Statement, 1990 Pollution Prevention Act 1990/
Capture words or phrases from class contributions and circle
those appropriate words that can be used in the EPA definition.
Make sure participants understand the environmental protection
hierarchy that emphasizes prevention as first choice but also
considers recycling, treatment, incineration and disposal of
wastes and pollutants as important components in the overall
strategy for environmental protection. Prevention simply will
reduce the burden of costly treatment, recycling and disposal
options in many cases. This will be illustrated in the EPA
Pollution Prevention slide show.
Show EPA's or your own Pollution Prevention slidi
with prepared script of examples of pollution prevention
techniques, technologies and programs. Take questions as they
Question audience: What are some of the reasons we are
now turning our attention to pollution prevention?
5. Barriers and Incentives Discovery Exercise:
Training Objective: To help participants think about the
challenges of implementing pollution prevention options and to
find some creative solutions to these problems. Students will
discover the barriers to implementing pollution prevention in
industry, as consumers and as EPA employees. Students then
try to find solutions or incentives to the barriers they've

identify potential programs, solutions and incentives that will
help to resolve/overcome these problems. Report Out on Instructor Notes
solutions. Allow discussion . Ask participants for additional
ideas on how each group could implement pollution prevention
programs and what activities EPA could do to promote
Pollution Prevention.
Programs/Incentives for industry
Improve public relations
Save money in long run
Protect worker and community health
Give tax incentives to upgrade
Recognition programs
Technical assistance and info dissemination
Incentives for consumers
Provide education
Make it easy
Make it inexpensive etc.
Incentives for EPA employees
Employee award program
Get top and middle management support
Provide training on what to do etc.
6. How to do Pollution Prevention.
(Hands on exercise demonstrating that you don't
need to be a Rocket Scientist to implement pollution
Depending on audience you may want to discuss specific
examples of pollution prevention accomplishments and a
conduct a descriptive short lecture on how to establish a
pollution prevention program/
Discuss the essential components as identified in EPA's Facility
Pollution Prevention Guide EPA# 600-R-92-088.
i.e. top management commitment, goals, periodic assessments,
accounting practices, technology transfer and evaluation.
These elements are applicable to all sectors and programs.

Discovery Training Activity:
Instructor Notes
Divide class into groups of 3 or 4 to work on problems and
present to class their solutions. Examples of exercises and
problems are included in the guidebook, CREATIVE
(Examples include the Play Dough Fun Factory or Blitzfn
exercises) The purpose of the case studies is to make the
participants feel that they can implement a pollution prevention
and that they have an important role to play in implementing
the program.
Report Out from each group.
Discussion among groups on lessons learned.
7. Pollution Prevention Resources
End workshop by providing the participants with resources so
that they may be able to find specific pollution prevention
information pertaining to them.
Resources, where to go for more information.
Start by discussing the Pollution Prevention Clearinghouse, *
ORD and OPTS Studies on Pollution Prevention, State activities
and resources.
The Pollution Prevention information Clearinghouse,
developed by EPA's Office of Research and
Development and the Office of Pollution Prevention
and Toxics is a multi-media clearinghouse of
technical policy legislative and financial information
dedicated to promoting pollution prevention through
efficient information transfer. The Clearinghouse is
made up of three elements... A Hard copy repository
in EPA Libraries
A computerized conduit to data bases and document
ordering and A hotline (hand out brochures and
fact sheets)
Refer to the Pollution Prevention Resources and Training
Opportunities Manual which list State resources, education and
training opportunities, case studies, videos and calendar of
Discuss further needs.

8. Closing and Evaluation:
Instructor Notes
Close workshop by asking each participant to identify
something that they learned from the workshop that they will be
able to use in their own jobs or personal lives to further promote
the concept of prevention. Open discussion, questions,
evaluation of class.
(*) Asterisk denotes that there are informational fact sheet
summaries on this topic to use as handouts and for your own
information. Available from the EPA and the EP3
Clearinghouse at (703) 351-4004.

Recommended Reading List for Pollution Prevention Instructors
1.	A Whack On the Side of the Head, Von Oech, 1985.
2.	Hazardous Waste Minimization, Harry Freeman (ed.) 1990. McGraw
3.	Serious Reduction of Hazardous Waste, US Congress Office of
Technology Assessment, 1986.
4.	The Age of Diminished Expectations, Paul Krugman, MIT Press 1987.
5.	Conceptual Blockbusting, Adams, 1986.
6.	EPA Pollution Prevention Facility Guide, 1992
7.	Prosperity Without Pollution, Oldenberg, Hirschorn, 1990
8.	Quality is Free, Philip Crosby, 1987.
9.	Instructor Training Workshop Manual, EPA Institute, 1988.
10.	UNEP Audit Manual

Creative Approaches to
Pollution Prevention Tramiia;
A Compendium of Exercises and Activities
U.S. Environmental Protection Agency

This manual provides instructors with descriptions of interactive pollution
prevention problem solving exercises for use in training and in classroom
sessions. The exercises were designed by a variety of trainers and may be used
and duplicated in any course or workshop.
These exercises can be used to train public policy staff and/or regulators about
the concepts of pollution prevention and at the same time heighten participants
awareness of the challenges of implementing prevention activities in an industrial
List of Training Exercises and Problems
1.	The Amazing Blitzfn Exercise
2.	Blitzfn Parts Exercise
3.	Fun Factory
4.	The Oily Washers Game
5.	The Green Square Game
6.	Abes' Electric Company Problem
7.	Solvent Reduction Case Study
8.	Pollution Prevention Program Planning Problem
9.	Colarama Paint Factory
10.	Bluemoon Inc. Multi-media Training Exercise
11.	4-Ways Management May Evaluate Prevention Options
12.	Reactions in Implementing Change Role Play
13.	Case Studies
Because each individual has their own unique training style, it is
recommended that the instructor "pilot" an exercise with 4 or 5 people prior to
formally conducting the exercise with larger groups.
If you have any questions on any of the problems or would like to discuss these exercises, call
Deborah Hanlon of US Environmental Protection Agency at (202) 260-2726.

Discovery Exercises for
Pollution Prevention Training

The Amazing Blitzfn Exercise Role Play
Purpose: To motivate audiences to promote pollution prevention through
enhanced communication and teamwork by taking them through a mock industrial
exercise. The exercise will demonstrate the importance of planning for
prevention and will illustrate some of the requirements of a comprehensive
facility program.
Time required: 2 hours Materials needed listed on exercise.
Instructions: Assemble participants into teams of 4,5 or 6. Assign each a role
to play in the manufacturing of the Blitzfn.
Provide each team a new factory floor (flip chart sheet) and a copy of the
attached Blitzfn Exercise.
After reading the exercise together, tell the teams they have one hour to produce
the blitzfhs.
During the exercise call the leaders to staff meetings, call the engineers to staff
meeting and tell them that EPA has passed new laws that require companies to
shut down for 5 minutes if there are any hazardous materials spills, have
employees attend Union meetings, etc
At the end of an hour visit each team and begin to inspect Blitzfn and factory.
Play role of critical customer and inspect each Blitzfn in front of entire group
for specifications. Notice spills, wastes, check hands for contamination etc.
After each plant is examined, begin discussion.
Suggested Discussion questions:
1.	What did you do to minimize waste and pollution?
2.	What roles were important in the process?
3.	Was there top management commitment?
4.	What were some of the barriers to minimizing pollution?
5.	What recommendations would you make to WHO to produce more
environmentally friendly Blitzfns?
6.	Based on the experience gained in this exercise, what do you think
are the key elements of a comprehensive pollution prevention

Th* Amarinp Blitsfn E«rrim
D. Hanlon & H. Freeman, US EPA
Congratulations! You have been chosen to be pan of a team responsible for producing the
new blitzfns. Blitzfns are devices used by the WHO to produce magic cures for diseases. These
new blitzfns are similar to other blitzfns produced in the facility, but are hew and improved and
will require the establishing of a new production line. There have been several teams of
individuals such as yours that have been given the opportunity to demonstrate the best way to
produce these new blitzfns. The team that produces the best blitzfn will open up a new factory in
the Bahamas next year. Your group is to produce	of the blitzfns.
Our CEO, Ms. Letsdottbetter has recently become enamored with the current push in the
country towards pollution prevention and has recently issued a policy statement to guide our
"There is nothing more important than preserving our environment. We will do everything
we can do to prevent pollutants to air, water and land. We shall produce no waste or pollution
before its time and we will strive to produce environmentally friendly products that contain no toxic
In addition to being an overall hard worker, you will have the duties outlined on the card
provided to you by the instructor.
The specs for a blitzfn are on the reverse side of the page. (Two sided copying, peat
pollution prevention idea.) Your production materials, processing equipment and costs are
outlined below.
Equipment	Materials Costs
scissors	blue powder paint (hazardous)	,...no cost
rulers	yellow powder paint			no cost
paintbrushes	9" x 11" paper board	$3.00
reaction vessels	wooden craft sticks	....$0.25
mix tanks	paste (voc's)	...no cost
markers (ink has hazardous	drafting tape	.....$1.00 per iRch
air emissions)	napkins	....no cost
plastic spoons	paper clips	............$1.00 each
After your group decides how its going to produce the blitzfns, you should send your Purchasing
Agent to the Central Store to get die necessary materials.
1.	Minimize wastes and reduce hazardous emissions from your factory. Spend sufficient
time in your design phase to consider options to minimize waste and reduce emissions.
2.	Your blitzfn must perform as required by the specs.
3.	Criteria for selecting the "best" blitzfn:
*	Time to produce
*	Cost
*	Specifications
*	Environmentally Friendly
*	Pollution Prevention Program
*	Customer satisfaction
*	Employee safety

Role Assignments
You-are the one responsible for making this happen. You will have to answer to Ms.
Letsdoitbetter if there is a screw up. What ever happens, you better have that blitzfn when the bell
rings or else you will be back on the midnight shift in the old blitzfn plant in Cleveland.
Now this pollution prevention stuff is OK if it does not get in the way of producing the
product Be ruthless in sticking to the main business at hand, i.e. producing a product on time
that meets the spec. Now it may very well be that the best way to get this done is to let the troops
do it there way, but you will have to make that decision.
Quality Control/Safety Officer/Regulatory Specialist
You don't really care to much about the time allotment, but if the Blitzfn does not meet the
spec, or if somebody gets hurt, you are in trouble, make real sure the workers are doing things
safely and correctly. You also must make sure the plant is in compliance with all
environmental/OSHA regs.
Plant Engineer/Pollution Prevention Advocate
You sold Ms. Letsdoitbetter on this pollution prevention stuff. If this project flies, and you
produce less waste you will be recognized. You will also be recognized if this pollution prevention
sniff gets in the way of meeting the deadline. Get really involved in coming up with creative ways
to reduce. Keep notes on how your group could have done it better. The second pan of the
exercise is to make another blitzfn incorporating all of your ideas. Do not reveal to your team
members that we are going to do it again, but be prepared to make recommendations on how it
could be improved.
Purchasing Person/Worker
You are responsible for the materials being at the plant when needed. While you want to be
sure the plant uses only what is needed, you want to be sure that they do not run out of materials,
or else Ms. Letsdoitbetter is going to be looking for you. Plan your purchases carefully before
going to the Central Store, discuss material needs with the Leader and the whole team.
You and your fellow workers have to make this thing, the pollution prevention stuff
usually just produces headaches. You just want to get it done and go home. If your team mates'
suggestions make your work easier, they are OK. Otherwise you can be difficult Incidentally,
there is a meeting tonight of the American Federation of Blitzfti makers that you want to go to.
You and your fellow workers have to make this thing. This pollution prevention stuff
usually just produces headaches. You just want to get it done and go home. If your team mates'
suggestions make your work easier, they are OK. Otherwise, you can be difficult This might be
a good project to have a work slowdown on since its a very high profile project the Leader has
been giving you a hard time.

The Amazing Blitzfn Parts Exercise
Purpose: This is shorter, simpler version of the Blitzfn exercise.
Participants will become aware of some of the conflicting demands of working in
an industrial setting and trying to minimize wastes and pollution. The exercise
demonstrates the importance of planning, communication and teamwork in
preventing pollution.
Time required: One hour Materials required are listed in exercise.
Instructions: Assemble participants into teams of 4,5 or 6. Assign each person
a role to play in the manufacturing of the Blitzfn part. Provide each team a clean
factory floor (flip chart paper). Read instructions together and give the groups
25 minutes to complete two blitzfn parts. Call staff meetings and conduct
inspections during the activity. At die end of 25 minutes inspect each factory and
examine the parts to ensure quality. Be a critical customer looking at both sides
of the blitzfn, inspect hands. Begin discussion.
Suggestions for discusssion:
1.	What did you do to minimize waste and pollution?
2.	What roles were important in the process?
3.	Did the workers contribute to or hinder pollution prevention
activites and ideas.
4.	How important was top managments' committment to pollution
5.	What were the barriers to prevention in this exercise? What are
the barriers to prevention in industrial situations?
6.	What kinds of incentives could be provided?
7.	Do you have recommendations for more environmentally friendly
blitzfn parts?
8.	What do you think are the most important considerations in
developing a pollution prevention program in an industrial setting?

The Amazing Blitzfn* Parts Exercise
*Btitzftis are imaginary devices used by the World Health Organization to cure all
diseases. New "green" blitzfn parts need to be produced to improve upon the old
uncoated blitzfn.
1.	Two uncoated blitzfn parts are provided.Your team must
coat each part by painting the part green on one side and
labeling (in black) the other side "BLITZFN".
2.	All work must be completed in 25 minutes and ready for
inspection by the World Health Organization representatives.
3.	Your goal is to coat two blitzfn parts on time, at the
least expense, with as little waste as possible.
4.	World Health Organization will want to know after the
exercise is over what you did to minimize pollution and what
recommendations you can make, based on this experience, to
produce safer, more environmentally friendly BLITZFN parts.
5.	Keep track of total costs for producing your biitzfns.
(including costs for disposal)
6.	After your group decides how its going to produce the
blitzfn parts, you should send your Purchasing Agent to the
Central Store to get the necessary materials, keeping in mind
the production requirements, (see reverse)
These materials are available from the Store:
Production Equipment
(no cost)
markers (ink has hazardous
air emissions)
paint brushes
blitzfn part (unpainted)
mix tanks
Materials	Costs
blue powder paint (toxic)... .$1 per spoon/ $.85 1/2 spoon
yellow powder paint.	$1 per spoon/ $.85 1/2 spoon
wooden craft sticks	$.25 each
water.	$.25 per spoon

Production Requirements:
1.	Green paint used for the exercise is made from one part
blue paint and two parts yellow paint. One part water per one
part paint is required for adequate coverage.
2.	Minimize wastes and reduce hazardous emissions from
your factory. Spend sufficient time in vour design phase to
consider options to minimize waste and reduce emissions.
3.	Your blitzfn parts must meet all specifications.
4.	Criteria for selecting the "best" blitzfn:
*	Time to produce
*	Cost
*	Specifications
*	Environmentally Friendly
*	Pollution Prevention Program
*	Customer satisfaction
*	Employee safety
*	Total waste generated
WILL BE A "WASTE". Therefore in closing your facility
after the exercise is over, you will be required to send all of
your hazardous wastes (materials and equipment contaminated
with blue or green paint)to an incinerator at $10.00 per item.
All non-hazardous waste (materials and equipment) will be
shipped off site for recycling or disposal at $1.00 per item.
6. All work should be carried on the "plant floor,"

Role Assignments
You are the one responsible for making this happen. You will have to answer to WHO if
there is a screw up. What ever happens, you better have the blitzfn parts when the bell rings.
Now this pollution prevention stuff is OK if it does not get in the way of producing the
product. Be ruthless in sticking to the main business at hand, i.e. producing a product on time
that meets the spec. Now it may very well be that the best way to get this done is to let the troops
do it then; way, but you will have to make that decision.
Quality Control
You don't really care to much about the time allotment, but if the Blitzfn part does not meet
the spec, or if somebody gets hurt, you are in trouble. Make real sure the workers are doing things
safely and correctly.
Plant Engineer/Pollution Prevention Advocate
You sold WHO on this pollution prevention stuff. If this project flies, and you produce
less waste you will be recognized. You will also be recognized if this pollution prevention stuff
gets in die way of meeting the deadline. Get really involved in coming up with creative ways to
reduce. Keep notes on how your group could have done it better. You will be responsible far
identifying the necessary requirements for an overall pollution prevention program and selling it to
top management
Purchasing Person
You are responsible for the materials being at the plant when needed. While you want to be
sure the plant uses only what is needed, you want to be sure that they do not run out of materials.
Plan your purchases carefully before going to the Central Store .keep track of all costs.
You and your fellow workers have to make this thing. The pollution prevention stuff
usually just produces headaches. You just want to get it done and go home. If your team mates'
suggestions make your work easier, they are OK. Otherwise you can be difficult Incidentally,
there is a meeting tonight of the American Federation of Blitzfn makers thai you want to go to. The
Union is concerned with all of the toxic materials the workers are exposed 10.

The Fun Factory
Interactive Exercise
Waste Reduction Training
Waste Reduction Institute
for Training and Applications Research, Inc.
February, 1991
by Thad Schifsky

Public Policy staff in regulatory and/or policy-making positions are in an important position.
They can influence waste generators in industry to adopt methods of environmental protection.
This training manual outlines an exercise which can heighten public policy staffs' awareness of
how waste is produced and how it can be reduced. At the same time, this exercise will provide
participants with a sense of what it's like to work in an industrial setting and to use group problem
solving techniques.
The instructions in this manual show the exercise facilitator in a step-by-step fashion how to
take a group through the Play-Doh Fun Factory exercise. The training manual also includes a
principles of operation section explaining how we developed this exercise, what our basic ideas are
behind the exercise, and how we expect participants will benefit from the exercise. We have also
included a section defining participant roles, as well as a list of equipment and materials needed.
WRITAR, 1313 5th ST SE, Ste
Ph. 612-379-5995
325, Minneapolis MN 55414-4502
FAX 612-379-5996

Principles of Operation
Nearly all training to date in waste minimization has been based on lectures and case studies, all
of which are more properly termed education. Training to date has been given a lesser priority
because the information to conduct training has not been available.
Our early training attempts at verbal role plays and small group discussions, while useful, did
not prove as powerful, successful, and flexible as the Fun Factory training exercise. It's a fun
exercise and we believe that people who have fun while learning ait more likely to retain what
they've learned. We are employing the principle that hands-on training allows trainees to become
participants rather than observers. People would rather have the actual tools to work with rather
than reflecting on concepts.
We determined that the regulatory audience who will participate in this exercise may not be
familiar with what it is like to function in an industrial setting. Because of this, we wanted to
construct an exercise to give these participants a good sense of how a business operates day-to-
day. By participating in this exercise, they will also acquire a sense of how waste is generated and
subsequendy learn to recognize processes that create waste. Finally, with their enhanced sense of
an industrial setting and knowledge of how waste is generated, we believe these participants will
be more effective in promoting waste minimization in their respective positions.
To motivate audiences to promote, persuade and encourage waste minimization by taking them
through a mock industrial process. This mock process is intended to heighten the participants'
awareness of the importance of communication in waste minimization efforts. In addition, it is
intended to help participants become mare aware of sources of waste, options for waste
minimization, and resistance to change.
WRITAR, 1313 5th ST SE, Ste 325, Minneapolis MN 55414-4502
Ph. 612-379-5995 FAX <12-379-5996

We have several objectives in mind for this exercise. One is to help participants hot familiar
with industrial processes to understand these processes. Another is to help participants understand
the challenges and frustrations of reducing waste in an industrial setting. A related objective is to
show the participants that by taking pan in this exercise, they may find their previous
understanding of waste reduction and its implementation has little in common with the reality of
waste reduction in an industrial setting. Our final objective is to help participants become aware of
the importance of communication in waste reduction efforts, and to become aware of some of the
many factors that make it difficult to actually implement waste minimization, such as labor
relations, customer demands, and competition.
WRITA.R, 1313 5th ST SE, Stc 325, Minneapolis MN 55414-4502
Ph. 612-379-5995 FAX 612-379-5996

Participant Roles
An ideal size for the group of participants is 20 people.
•	Facilitator Role.
The facilitator would be ideally filled by a person who is comfortable with taking charge and
leading a group of people through an exercise. Since the successful completion of this exercise
depends on a high level of interaction among the participants, the facilitator should also be adept at
promoting this interaction by his/her own example.
•	Customer Role.
The facilitator takes on the role of the Customer after the Play-Doh machines are handed out.
The Customer's role is to place orders, create pressure, demand quality, and generally harass the
teams with the goal of creating an atmosphere of good natured chaos. The Customer's job begins
with circulating to each team and placing the first order with each "Big Boss." After the teams
have begun working, the Customer begins requesting sample parts from each team and inspects
their quality. While inspecting each team's product, the Customer mentions how well their
competition is performing. The Customer continues to inspect each team's product, mentions the
competition's performance, and how important the job is to their company throughout the exercise.
Write the following titles and role descriptions on index cards.
•	Big Boss
Keep your back to the process at all times. Everything is always late. You only care about the
bottom line. Your links to your team are through Quality Control and the Production Manager,
communicate to your team through them.
•	Production Manager
The techs are lazy, QC is crazy, and the boss is on your case. You can look at the process
once every five minutes. Get those parts out now!
•	Quality Control (00
Everyone wants to slip something by you. Watch those techs carefully. You're the only
guardian of the company's good name. If it's no good by you, it's no good.
WRITAR, 1313 5th ST SE, Ste 325, Minneapolis MN 55414-4502
Ph. 612-379-5995 FAX 612-379-5996

•	Technician fTech^ (Two Techs per Team)
You are underpaid and overworked. Only you understand the process. If only management
could get organized! Don't let them push you around.
•	RCRA Inspector (Optional)
You know that every facility has something to hide and your job is to find it. The paper work
is never filled out right; their records are never where they're supposed to be, and all the labels are
upside down.
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Assemble attendees into teams of five and seat them around the "production floor." (see
Materials Needed, page 9, line 4)
Assign a city or country name to each team for identification, and write the team names on a
flip chart or chalkboard.
Explain to the teams that they are in competition with each other to produce a criticaTpart" for
the military, and they will produce this "pan" from play-doh using the Fun Factory machine.
Tell them that since this is work for a defense contract, the parts have to be made to exacting
Explain that Red play-doh is a toxic metal. Yellow play-doh is toxic because of volatile
organic air emissions, and Blue and White play-doh is non-toxic. Explain that if toxic play-
doh is mixed with non-toxic, the pan is contaminated and considered waste. Write these
specifications on the flip chart for the players' reference.
Explain that anything that is contaminated or isn't finished product is considered waste,
therefore it can't be recycled and should be placed in a waste pile.
Assign roles by handing out the index cards (see Materials Needed, p.9, line 5, and
Participant Roles, p.4). Roles can be assigned arbitrarily. Any extra people can be
Hand out Fun Factory machines and Play-Doh. Caution teams not to start until you tell
them. Tell teams they will have 90 minutes to complete the exercise, after which there will be
a 30 minute assessment and then a second 90 minute exercise. A half-hour break can be
inserted in die exercise.
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8.	Tell the teams that you aie the customer, and that you will order only through the Big Boss.
9.	Tell the teams to open up the machines. This may distract them for a short time, so
pause with your instructions.
10.	Give the teams the first order to make 10 blue stars with a thickness comparable to the lid of
the Play-Doh can. Explain that the parts are to be extruded with the machine, not molded by
hand. Tell teams that finished parts should be smooth on both sides, and contain no mixed
colors. Write the order and specifications on the flip chart
11.	Check on each team's progress. Begin quality control at this time, checking for parts that are
not smooth or are shaped badly.
12.	When any team is near completion of die first order, begin placing the second order of 10
white stars with the same thickness of the blue stars. Be careful not to tip off nearby teams
about the content of this and future orders.
13.	Place the third (5 blue rectangles) and fourth (3 red ropes) orders with all teams when any
one team is close to completion of the second order. Tell them the rectangles should be made
the smallest possible, with the same thickness as the stars. The ropes should be made as
long as an index card is wide.
14.	After you are certain all of the teams have begun the third aider of 5 blue rectangles,
announce to all of the teams that the customer has changed their third order to 3 red ropes,
and the fourth order to 5 blue rectangles. This will (and is intended) to cause confusion and
dismay among the teams as they will have to change their extrusion form, clean their
machines, and guard against color contamination.
15.	Continue checking for pans that are not smooth or are shaped badly, and begin inspecting
parts for streaks of color resulting from sloppy color changes.
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16.	Remind the teams that they are in competition with each other. Since teams will work at
different speeds, tell them you might have to pull the job from one team and give it to
17.	At 90 minutes, tell the teams to stop, collect and segregate their pans and waste, and clean
their machines. Determine who finished first. Inspect each team's finished parts for
conformity to the standards of smoothness and shape and inspect each teams waste piles and
note the amount of waste generated. You may wish to weigh each teams waste with a small
scale to determine which team generated the most waste.
18.	Ask the teams to appoint a group spokesman among themselves, and begin the discussion.
Write responses on flip chart Ask them what they think is wrong with the exercise as an
industrial process (process analysis). Next, ask what they would change and why (options
generation). Then ask each team what is the first thing they would modify and why
(implementation). Last, point out the insights they have gained from the exercise. Examples
of insights include:
a.	how this exercise can help participants not familiar with the process understand the
complexities of waste reduction in an industrial setting. This includes the added
complexity and additional waste order changes can cause, especially with small orders
which require die same "retooling" and cleaning as a large order.
b.	all waste reduction ideas derived from this exercise came from the participants, which is
often the case, or should be, in real industrial facilities.
c.	a sense of how waste is actually generated, which can help participants to at least promote
waste reduction ideas.
19.	begin the exercise again and have everybody implement what they've learned.
2 0. clean up.
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List of Equipment and Materials Needed
1.	Play-Doh Fun Factories
2.	supplemental supply of Play-Doh
3.	flip chart or black board
4.	24" x 36" sheets of white paper (often removed from a flip chart)
for "production floor"
5.	packet of 3" x 5" index cards
6.	felt-tip markers for flip chart
7.	chalk and erasers for blackboard
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The Oily Washers
Interactive Exercise
Waste Reduction Training
Waste Reduction Institute
for Training and Applications Research
March, 1991
by Thad Schifsky

Outline for Oily Washers Exercise
VI	Iatroduction
VII	Theory or Principles
a.	Principles of Operation
b.	Purpose
c.	Objectives
Vm Instructions Section
VlV Equipment and Materials Needed
Page 1
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Public policy staff in regulatory and/or policy making positions are in an important
position. They can influence waste generators in industry to adopt methods of environmental
protection. This training manual outlines an exercise which can heighten public policy staffs'
awareness of the challenges and problems of exchanging aqueous cleaners for solvents. At the
same time, this exercise will provide participants with a sense of what it's like to work in an
industrial setting and to use group problem solving techniques.
The instructions in this manual show the exercise facilitator in a step-by-step fashion how
to take a group through the Oily Washers exercise. The training manual also includes a principles
of operation section explaining how we developed this exercise, what our basic ideas are behind
the exercise, and how we expect participants will benefit from die exercise. We have also included
a list of equipment and materials needed for this exercise.
Page 2
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Principles of Operation
Nearly all training to date in waste reduction has been based on lectures and case studies,
all of which are more properly tamed education. Training to date has been given a lesser priority
because the information to conduct training has not been available.
Our early training attempts at verbal role plays and small group riiyrwipngs. while useful,
did not prove as effective as an exercise like the Oily Washers training exercise. Ids a fun exercise
and we believe that people who have fun while leaning are more likely to retain what they've
learned. We are employing the principle that hands-on training allows trainees to become
participants rather than observers. People would rather have die actual tools to work with than
reflecting on concepts.
We determined that the regulatory audience who will participate in this exercise may not be
familiar with what it is like to function in an industrial setting. Because of this, we wanted to
construct an exercise to give these participants a good sense of how a business operates day-to-
day. By participating in this exercise, they will also acquire a sense of the difficulties encountered
while substituting aqueous cleaners for organic solvents. With their enhanced sense of an
industrial setting and the challenges and problems of exchanging aqueous cleaners for solvents, we
believe these participants will have a clearer idea of how to promote effective solvent substitution
efforts in industry.
To motivate audiences to promote, persuade and encourage substitution of solvents in
industry by taking than through a mock industrial process. In addition, it is intended to help
participants become aware of why solvents are used, the process and difficulties of solvent
substitution, and the cause of industry's resistance to these substitution efforts. This mock process
is also intended to heighten the participants' awareness of the important role communication plays
in industry's solvent reduction efforts.
Page 3
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Objectives .
We have several objectives in mind for this exercise. One is to help participants not
familiar with industrial processes to understand these processes. Another is to help participants
understand die challenges and frustrations of substituting aqueous cleaners for organic solvents in
an industrial setting. A related objective is to show the participants that their previous
understanding of the mechanics of solvent replacement may have little in common with the reality
of replacement efforts in an industrial setting. Our final objective is to help participants become
aware of the importance of communication in efforts to exchange aqueous cleaners for solvents,
and to become aware of some of the many factors that make it difficult to actually implement
substitution, such as customer demands and timetables.
Page 4
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Ph.(612)379-5995 FAX (612) 379-5996

1.	Assemble participants into teams of five and seat each team atound a tray.
2.	Explain to the teams that they will be given oily steel washers along with three
different cleaners. Explain that they will be evaluated on how fast they clean the oil from the
washers, and afterwards, how clean and dry they are in comparison to your model of a dry
3.	Tell the teams that they too are going to evaluate the three cleaners, but during die
exercise. Tell them they will do this by deciding on criteria to evaluate the cleaners and that they
will be required to document how they evaluate each cleaner by making notes on each one.
4.	Tell the teams that they also have to decide if their washers are clean by deciding on
criteria to help determine if they are clean. Tell them they must document these criteria and their
evaluation of die washers cleanliness.
5.	Explain to the teams that in the past your industry has used organic solvents and
you've been able to clean 50 washers at a time in one minute and they came out dry. Explain that
they are expected to meet this standard of 50 washers per minute.
6.	Hand out the the piepiepaied trays containing the cleaning equipment to each team,
and tell them they will have 20 minutes to complete the exercise.
7.	Tell the teams to begin and note the time.
8.	At the 20 minute mark, tell the teams to stop.
9.	Display the piepiepared flip chart which shows the participants the cost of each
cleaner. Tell the teams to note the cost of the cleaners and to debate the merits of each cleaner
among themselves for another 15 minutes. Tell them they must decide which is the best cleaner.
10.	At the end of the 15 minute period, visit each team and ask what cleaner they've
chosen and why. While doing this, pant out the rust that will have developed on the washers as
proof that the washers are still wet, in spite of die team's efforts to dry them.
Page 5
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11.	Next, ask all the teams how they know the washers are clean. To answer this
question, ask them to refer back to their criteria and evaluation of how well they cleaned the
12.	Tell the teams you have a test to determine if the washers are/arc not clean. Test
each team's washers by dunking them in water and examining them for water beading. If water
beads form on the washer, show the washer to the team and explain that the beading is caused by
oil still present on the washer.
13.	Begin discussion by:
a)	asking die teams how they would solve the washer drying problem and asking them
for their estimate of the costs of correcting this problem.
b)	asking the teams how they would set a quality standard which will result in oil-free
End of Exercise
Page 6
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List of Equipment & Materials
Items #1 through #6 are readied and placed on each of the four trays in advance of the exercise.
Flip chart is readied in advance also (see #8).
1.	20 zinc coaled steel washers.
-	strip washers of zinc coating and immediately coat them with oil to prevent rust Place
washers in plastic baggies for transport
2.	4 six inch pieces of stainless steel wire.
-	should be stout enough to hold one washer at a time.
3.	One latex glove.
-	one for each team to keep operator's hand clean while cleaning and racking.
4.	Roll of paper towels.
-	provide at least two towels far each team.
5.	4 eight ounce paper cups.
6.	Cleaning Solutions.
a)	Ivory liquid soap mixed with water.
-	fill cup 3/4 full with water and add 1 tablespoon soap.
b)	Dawn for dishes mixed with water.
. same as above.
c)	Imodium Phosphate (TSP).
-	can be found in powdered form at a hardware store.
-	fill cup 3/4 full with water, only add 2 tablespoons powdered TSP.
7.	Rinsing Solution.
-	fill cup 3/4 full with water, add 4 tablespoons vinegar.
8.	Four trays.
-	food service trays work well, otherwise any tray with a lip.
Page 7
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9. Flip Chart or Blackboard.
- write cost of each cleaner on flip chart in advance of exercise. Use table format below.
Cost per T.
Cost per Run
Life of



10.	Felt-dp markers if flip chart, chalk and erasers if blackboard.
11.	Paper and pencils for each group.
Page 8
WRTTAR, 1313 5th St SE, Ste 325, Minneapolis MN 55414-4502
Ph. (612) 379-5995 FAX (612) 379-5996

The Green Square
Interactive Exercise
Waste Reduction Training
Waste Reduction Institute
for Training and Applications Research
February, 1991
by Thad Schifsky

Outline for Green Square Exercise
Vl Introduction
Vn Theory or Principles
a.	Principles of Operation
b.	Purpose
c Objectives
Vm Instructions Section
VlV Equipment and Materials Needed
Page 1
1313 5th St SE, Stc 325, Minneapolis MN 55414-4502
(612) 379-5995 FAX (612) 379-5996

Public Policy staff in regulatory and/or policy-making positions axe in an important position.
They can influence waste generators in industry to adopt methods of environmental protection.
This training manual outlines an exercise which can heighten public policy staffs' awareness of
how waste is produced and how it can be reduced. At the same time, this exercise will provide
participants with a sense of what it's like to work in an industrial setting and to use group problem
solving techniques.
The instructions in this manual show the exercise facilitator in a step-by-step fashion how to
take a group through the Green Square exercise. The training manual also includes a principles of
operation section explaining how we developed this exercise, what our basic ideas are behind the
exercise, and how we expect participants will benefit from the exercise. We have also included a
list of equipment and materials needed for this exercise.
Page 2
1313 5th St SE, Ste 325, Minneapolis MN 55414-4502
(612) 379-5995 FAX (612) 379-5996

Principles of Operation
Nearly all training to date in waste minimization has been based on lectures and rase studies, all
of which are more properly termed education. Training to date has been given a lesser priority
because the information to conduct training has not been available.
Our early training attempts at verbal role plays and small group discussions, while useful, were
not as effective as we'd hoped. We found that, aside from role plays and discussions, an exercise
approach such as the Green Square Game is a more effective training tool It's a fim exercise and
we believe that people who have fun while learning are more likely to retain what they've learned.
We are employing the principle that hands-on training allows trainees to become participants rather
than observers. People would rather have the actual tools to work with rather than reflecting on
We determined that the regulatory audience who will participate in this exercise may not be
familiar with what it is like to function in an industrial setting. Because of this, we wanted to
construct an exercise to give these participants a good sense of how a business operates day-to-
day. By participating in this exercise, they will also acquire a sense of how waste is generated and
subsequently leam to recognize processes that create waste. In addition, participants will
understand how hazardous waste, even when properly disposed of, can re-enter the environment,
and that landfills and incinerators don't reduce hazardous waste's threat to the environment
Finally, with their enhanced sense of an industrial setting and knowledge of how waste is
generated, we believe these participants will be more effective in promoting waste minimization in
their respective positions.
To motivate audiences to promote, persuade and encourage waste minimization by taking them
through a mock industrial process. This mock process is intended to heighten the participants'
awareness of the importance of communication in waste minimization efforts. In addition, it is
Page 3
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(612) 379-5995 FAX (612) 379-5996

intended to help participants become more aware of sources of waste, options for waste
minimization, and resistance to change.
We have several objectives in mind far this exercise. One is to help participants not familiar
with industrial processes to understand these processes. Another is to help participants understand
the challenges and frustrations of reducing waste in an industrial setting. A related objective is to
show the participants that by taking part in this exercise, they may find their previous
understanding of waste reduction and its implementation has little in common with the reality of
waste reduction in an industrial setting. Our final objective is to help participants become aware of
the importance of communication in waste reduction efforts, and to become aware of some of the
many factors that make it difficult to actually implement waste minimization, such as labor
relations, customer demands, and competition.
Page 4
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MN 55414-4502

Instructions Organization
•	Form teams
•	Explain exercise
•	Hand out materials
•	Inform players of your role
•	Place order
•	Check on teams progress
•	Begin discussion
-ask the students to discuss techniques they used to minimize waste generation.
-solicit ideas on how to dispose of waste generated by each company.
-If incineration is recommended, solicit ideas on how to dispose of the toxic ash and air
-If placing ash in a landfill is recommended, ask how die rainwater might become
contaminated and enter drinking water supplies.
-solicit ideas on how to clean up the contaminated water and what should be done with
the toxics we remove from the water.
-ask what would happen if these toxics were incinerated.
-point out that, while the volume of waste was reduced, the hazardous portion was not and
is simply being moved around without being completely eliminated.
-solicit ways to overcome this problem, i.e. how should we deal with hazardous waste
generated in in industrial processes? Is source reduction the answer?
-discuss the relative merits of buying and using products from industries that cannot
entirely remove hazardous waste. Participants may be interested in researching industries
in their own communities that generate air, water, and land pollution and where that waste
is disposed.
•	Clean up
P&EG 5
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1.	Assemble- participants into teams of five and seat them around the "production floor."
2.	Ask the groups to invent their own company name, and write the team names on a flip chart or
3.	Explain to the teams that they will mix blue and yellow tempera paints to color a square-shaped
piece of paper green for an unspecified "customer." Tell teams that their "product" should
match the model representing die customer's desired color.
4.	Explain that any surface or object which becomes contaminated with paint, whether blue, green
or yellow, becomes "hazardous/This includes all materials, hands, clothing, table surface, and
the floor. Explain that teams will be evaluated on their ability to paint the square the correct
color while generating the least amount of this "hazardous waste."
5.	Hand out painting materials to each team. Caution teams not to start until you tell them, and tell
them they will have 20 minutes to complete the exercise. You may wish to pause with your
instructions until the teams are ready.
6.	Tell die teams to begin the exercise and note the time.
7.	At the 20 minute mark, tell the teams to stop.
8.	Begin inspection of each team's product and evaluate their efforts with the following criteria:
color match with the customer modeL
production floor cleanliness.
number of contaminated brushes.
number of contaminated cups.
number of contaminated spoons.
cleanliness of back of green square.
left over green paint
contaminated hands, clothing, etc.
9. Begin discussion
a.	ask the students to discuss techniques they used to minimize waste generation.
b.	solicit ideas on how to dispose of waste generated by each company.
c.	If incineration is recommended, solicit ideas on how to dispose of the toxic ash and air
Page 6
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(612) 379-5995 FAX (612) 379-5996

d.	If placing ash in a landfill is recommended, ask how the rainwater might become
contaminated and enter drinking water supplies.
e.	solicit ideas on how to clean up the contaminated water and what should be done with
the toxics we remove from the water.
f.	ask what would happen if these toxics were incinerated.
g.	point out that, while the volume of waste was reduced, the hazardous portion was not and
is simply being moved around without being completely eliminated.
h.	solicit ways to overcome this problem, Le. how should we deal with hazardous waste
generated in in industrial processes? Is source reduction the answer?
i.	discuss the relative merits of buying and using products from industries that cannot
entirely remove hazardous waste. Participants may be interested in researching industries
in their own communities that generate air, water, and land pollution and where that waste
is disposed.
Instruct teams to clean up.
Page 7
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List of Equipment & Materials
I.	Blue tempera paint
Yellow tempera paint
-use 1 teaspoon powder per team as a guideline
3.	4 8oz. paper cups
4.	2 water color brushes
5.	2 spoons
6.	24" X 36" sheets of white paper for production "floor"
-can be removed from flip chart
7.	1 8x12 piece of heavy grade paper
-cut into 4 squares
8.	1 half-full cup of water
9.	flip chart or blackboard
10.	felt-tip markers for flip chart
II.	chalk and erasers for blackboard
Page 8
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Problem #1
ABE's Electric Company
Abe's Electric Company produces ceramic filaments by mixing two powders into a slurry which
is then placed in molds.. A pan of the process involves wet mixing of the two powders using a
vibaratory grinder. Powder A Consists of inert ceramic material and Powder B contains lead
oxide, a required ingredient for ceramic fusion. The two powders are delivered in SO lb. sacks to
die weighing station. Six pounds of A and three pounds of B are weighed and manualy trans-
ferred to a wet grind process to adequately mix the powders. The slurry is then transferred to
shallow trays which are placed manually into a drying oven. The ceramic "cake"which has been
oven dried is then manually put into a dry grinding mixer to delump the compund for the calci-
nation process. The ceramic powder goes dry into this process.
Abe is facing a number of problems including:
1) OSHA has issued a citation to the company for violating TTLV for lead, (worker expo
2) EPA's land disposal restrictions will prevent Abe from disposing of the hazardous waste
Chemical substitution is not a viable Waste Minimization option, so Abe has hired you to modi-
fy the process in which the filament mixture is formulated in order to address the described prob-
* Emission of Powders into workplace
* Powders settle on floor
* Area is washed down daily
* Waste goes to settling pit and hazardous sludge is disposed of offsite
* Reduce hazardous sludge
* Reduce worker exposure to lead dust









~r «-*-


Examples: Dyes, Inorganic Pigments, Paint, Agricultural Chemicals
Formulation, Phenolic Resins, Wood Preserving
Material Handling:
Filtration and
Baghouse Fines
Off-Spec Product
Equipment Cleaning
Leaks and Spills
1.	Segregate containers by prior contents
2.	Use rinseable/recyclable drums
3.	Purchase materials in bulk or in larger containers
4.	Purchase materials in preweighed packages
5.	Use pipeline for intermediate transfer
1.	Optimize the reaction variables/receptor design
2.	Optimize the reactant addition method
3.	Eliminate the use of toxic catalysts
1.	Employ efficient washing/rinsing methods
2.	Eliminate the use of filter aids
3.	Use countercurrent washing
4.	Recycle spent washwater
5.	Maximize sludge dewatering
1.	Increase use of dust suppression methods
2.	Use wet instead of dry grinding
3.	Schedule baghouse emptying
1.	Tighter control of reaction temperatures
2.	Reformulation of off-spec product
1.	Install high pressure spray wash system
2.	Alter production schedule
3.	Use mechanical wipers on mix tanks
4.	Clean mix tanks immediately after use
5.	Use a countercurrent rinse sequence
6.	Recycle spent rinse water
7.	Increase spent rinse settling time
8.	Re-examine need for chemical cleaning
9.	Dewater spent rinse sludge
1.	Use bellow-sealed valves
2.	Install spill basins
3.	Use canned (sealless) pumps
4.	Maximize use of welded vs. flanged pipe joints

Mechanical Specialties Inc. produces servo-mechanical components for use in the
aerospace industry. The parts are manufactured by a milling process which uses
conventional oil-water emulsified coolant Grease is then applied to the parts to
protect them against oxidation during prolonged storage.
Prior to assembly, the alloy steel parts are thoroughly cleaned in a vapor degreaser
with perchloroethylene (PCE) to remove the protective grease. The wastes
associated with this process include air emissions, decanted water, and grease-rich
bottoms which are periodically removed and sent off site for destructive
The degreaser has a freeboard-to-width ratio of 0.75 and is equipped with
refrigerator coils and a hinged cover.
Identify candidate WM options.

FIGURE 1 - Vapor Degreaser
FIGURE 2 - Vapor Degreaser with Spray Attachment

Freon Cleaning Agents
Qeaning System Design
Properly designed and maintained equipment is a prerequisite for minimizing solvent emissions. For over 30 vears
Du Pont has worked closely with cleaning equipment manufacturers to develop the following basic equipment
design guidelines that permit Du Pont FREON® fluorocarbon cleaning agents to be used effectively with minimal
solvent loss.
FREON cleaning agents are used in degreasing/defluxing equipment that is configured in a variety of ways.
However, all of the configurations are based on the fundamental cencepts of the simple two-sump, open-top
degreaser, shown in Figure 1 on the back fold-out of the brochure, and contain the same basic elements:
•	A tank containing one or more heated sumps 0
that generate solvent vapors, along with one or
more sumps 0 arranged in an overflowing cas-
cade to clean parts by liquid immersion and/or
spray washing.
•	A condenser (heat exchanger) © to turn solvent
vapors back into liquid form. A trough @ under
the exchanger collects condensate.
•	A water separator (or desiccant dryer) ® to
remove water from the condensate before it is
returned to the cleaning sump cascade.
•	A vapor zone (vapor-filled space) 0 between the
surface of the liquid in the various sumps and the
vertical midpoint of the condenser.
•	A freeboard zone, 0 which is the space lying
between the vertical midpoint of the condenser
(top of the vapor zone) and the top edge of the
•	Safety controls © © to shut off heat to the boil
Sumps if the condenser system fails, liquid level
in the boil sumps becomes low, or the boil sump
temperatures are elevated because of contami-
Equipment design affects three principal mechanisms
of solvent loss from degreasers and defluxers. The
mechanisms are DIFFUSION, DRAGOUT, and
Diffusion losses result from the contact of liquid or
vapor with air. The following design parameters con-
trol diffusion losses:
Freeboard Height—Diffusional losses are inversely
proportional to the freeboard height. To minimize
losses, the freeboard should be as deep as possible and
at least 75 percent of the smallest horizontal tank
dimension, which is usually the width of the machine.
Small open-top units should have a freeboard'width
ratio of 1.0 or greater. (See Figure 2.)
5 2
? I -
JCZ *1
Oq. I
— CC £ .
0 ££ 1
^00 «
a >
* ;<
8 is *
** O „
Ratio > 0 46
Ratio ¦ l 0
Figure 2
Condenser Temperature—Diffusional losses are
directly related to condenser temperature; therefore,
the condenser should be designed to operate at the
lowest practical temperature. In state-of-the-art
design using either mechanical refrigeration, recir-
culating chilled water, or brine, the condensers oper-
ate at temperatures of 40 to 50°F. (See Figure 2.)

Freon Cleaning Agents
Recommended Work Practices
Good work practices play an important role in any emission control program. Failure to recognize this can reduce
many of the benefits that would be expected from the use of state-of-the-art equipment, solvent recovery and
recycle measures. Listed below are the work practices that play a major role in Du Pont FREON® fluorocarbon
cleaning agents emission control.
Cleaning System Location
A degreaser/defluxer should be placed in as draft-free
an environment as possible. Vapor/air interfacial tur-
bulence caused by drafts (velocity >40 ft/min) blow-
ing into or, in the case of open-top units, over the
cleaning equipment from adjacent windows, doors,
fans, unit heaters, ventilators or spray booths will
greatly increase the rate at which solvent vapor is
emitted to the atmosphere. •
When excessive air movement is a problem with exist-
ing equipment, consider the installation of baffles or
partitions on the windward side to divert the draft
away from the cleaning unit.
In the case of open-top equipment, problems with
drafts can be avoided or corrected by using hooded
enclosures in conjunction with automated work-han-
dling facilities (see Robotics Section of "Cleaning Sys-
tem Design").
A workload that is too large in physical size can dis-
place vapor from the cleaning unit by the "piston
effect." (See Figure 1.) To avoid losses by this mecha-
nism, the area of the workload should not be greater
than 50 percent of the horizontal cross-sectional area
of the sump into which it is being introduced.
Introduction of a workload that is too heavy will result
in a collapse of the vapor blanket ("work shock," see
Figure 2), and the infiltration of air into the cleaning •
unit. During reestablishment of the vapor blanket, the
infiltrated air saturated with solvent vapors will be
expelled from the cleaning unit. If this condition is
encountered on a regular basis, the equipment manu-
facturer should be consulted to determine if additional
heating and condensing facilities can be incorporated
into the cleaning unit. If not, purchase of a new
machine with adequate work-handling capabilities
should be considered.
Piston Effect
Work Shock
Figure 1
Workload Size
The processing of workloads that exceed the cleaning
system's design capabilities will expel solvent vapors
from a degreaser/defluxer.
* Condensation on
6	Vfepor blanket
7	vapor-laden
air expelled
Figure 2

An accountant for Ace Manufacturing, an employer of 2,000
people, reported that the company spent $250,000 for off-site
treatment and disposal of hazardous wastes last year. Based
on the manifest information, the only source of available in-
formation on wastes, the company and its eight divisions gen-
erated the following waste streams:
50 tons acidic waste
10 tons paint waste
5 tons used oil
10 tons various solvents; MEK.TCE, Naptha, Perc.
1 ton adhesives
15 tons contaminated soil
30 tons clarifier sludge
The General Manager, alarmed by the 200% increase in disposal
costs assigns you to develop a waste minimization program.
You have no budget to do this but can devote all of your time to
the project.
1.	Outline what steps you would take to begin to develop a
waste minimization program.
2.	How would you prioritize wastes for reduction?
3.	What resources would you use?

The Waste Minimization Assessment Procedure
The recognized need to minimize waste
Get management commitment
Set overall assessment program goals
Organize assessment program task force
Assessment organization
and commitment to proceed
1 Collect process and facility data
' Prioritize and select assessment targets
' Select people for assessment teams
' Review data and inspect site
' Generate options
• Screen and select options for further study
Assessment report of
selected options
Select new
assessment targets
and reevaluate
previous options
•	Technical evaluation
•	Economic evaluation
•	Select options for implementation
Final report, induting
recommended options
*	Justify projects and obtain funding
*	Installation (equipment)
*	Implementation (procedure)
*	Evaluate performance
Repeat the process
Successfully implemented
waste minimization projects

Problem 1
Colorama Paint Factory
You are a production superintendent in a large paint formulating plant. A customer has ordered
5000 gallons of red paint and 2000 gallons of green paint. Three tank sizes are available for final
mixing: 5000 gallons, 2000 gallons and 1000 gallons. All tanks are clean and ready to use. At the
end of the production campaign, all tanks must be cleaned for the next order.
1.	Which tank utilization strategy would result in
(a)	least number of production batches
(b)	least amount of cleaning waste generated
2.	List considerations other than waste minimization that enter into strategy development.
Hint: Assume that the amount of cleaning waste is proportional to the tank internal surface area
wetted by the paint at the time when the tank is ready for cleaning. These areas arc as follows:
350 ft2 for the 5000 gallon tank
190 ft2 for the 2000 gallon tank
120 ft2 for the 1000 gallon tank

'Colorama Paint Factoiy" Solutions
a. The least number of tank batches required to produce 5000 gallons of red
paint and 2000 gallons of green paint is simply:
One 5000 gallon batch of red
One 2000 gallon batch of green
A total of two batches
All other combinations (e.g., 5000 and 2 x 1000,2 x 2000 + 1000 and 2000, etc..) will
result in more than two batches.
b. The least amount of waste would be generated by using the 1000 gallon tank
only. Use the 1000 gallon tank five times to produce the red paint order,
clean the tank, and tnen use the tank two times to produce the 2000 gallon
green paint order.
Note that only two tank cleanings are involved; one after the red paint
production, and one after the green paint production. Because the 1000
gallon tank has the least amount of wetted surface area, the amount of waste
generated will be minimal (proportional to 2 x 120 ft2). All other tank
utilization combinations result in either a larger number of tank cleanings
and/or larger wetted surface areas.
In a formal comparison, one would have to perform a cost benefit analysis between
strategies a ana b, weighing such factors as labor costs, waste generation, and
product quality. Most production planners would intuitively choose the strategy
resulting in the least number of batches (strategy a) due to the reduced labor
requirements and product quality considerations. Alternatively using the 1000
gallon tank (strategy b) will generate the least amount of waste but will require
more labor to produce the total paint order and could possibly compromise product
ouality and consistency when compared to a single batch. Another factor which
snoula be considered is the potential for product spillage, which is higher for
strategy b.

Problem 2
Mechanical Specialties Inc.
Mechanical Specialties Inc. produce mechanical components for use in the
automotive industry. Steel parts are manufactured by a milling process which uses
conventional oil-water emulsltbn coolant Grease is then applied to the parts to
protect them against oxidation during prolonged storage outdoors.
Prior to assembly, the steel parts are cleaned in cold naptha solvent to remove the
protective grease. After cleaning in solvent, the parts are alkaline cleaned and
painted. The wastes associated with this process include air emissions and grease-
rich solvent which is periodically removed and sent off site for recycling. Recovered
solvent is returned to the facility.
You have been hired to provide the facility with viable waste minimization options
for their degreasing operation.
Make a list of operating sequences, or flow diagram, to assist you in determining
wastestreams, sources, and potential areas for waste minimization options.

"Mechanical Specialties Inc." Solutions
Avoid the need to clean by implementing Just-In-Time (JIT) manufacturing schedules. JIT
schedules eliminate the need for storage and hence the need for applying protective grease.
This reduces the loading of grease into the solvent bath. If the alkaline cleaner effectively
removes the oil-water coolant, then the solvent cleaning step can be eliminated.
Move storage of parts indoors to reduce contamination and oxidation. Parts stored outdoors
quickly become contaminated with dirt and moisture (morning condensation and rain). Both
dirt and moisture increase the loading on the solvent bath which leads to more frequent
replacement of the solvent. Another problem with outdoor storage is that parts to be cleaned
are cold, which slows the cleaning process. The use of oil-water coolant leaves a slight oil film
on parts which typically provides adequate protection during short-term indoor storage.
Maintain the quality of the solvent by the following methods:
Pre-clean parts by wiping off dust, dirt and excessive grease before soaking in solvent.
Cloths should be lint free so a new source of contamination is not created. Dirty cloths
must be handled in an appropriate manner.
Store parts indoors to avoid moisture and condensation. Keep parts away from dust or
fume generating operations.
Maintain racks and barrels in a corrosion free condition. Rust and scale in the solvent
bath leads to increased loading. Cracks in hooks can increase loss of solvent by means
of "drag-out."
Routinely remove fines and sludges. Metal fines can lead to the break down of
chlorinated solvents. Some sludges dissolve slowly over time and absorb solvent. Also,
excessive sludge in the solvent tank can lead to the contamination of parts with sludge.
Hard paint chips will soften and swell as they absorb solvent which can then no longer
be used for cleaning. With continuous or frequent filtering, these chips can be removed
before dissolving.
Monitor solvent composition to ensure that solvent is dirty before recycling. Quite
often, solvent is prematurely discarded or change-out because someone "feels" that the
solvent is not cleaning fast enough. With chlorinated solvents, monitoring "goes acid"
Reduce air emission from the tank by employing the following methods:
"Rack" parts to ensure good drainage of solvent from the parts back into the bath. Cup
shaped parts should be racked upside-down. In addition to proper racking, allow
enough dwell time over the tank to ensure good drainage.
Install lids on all tanks and be sure to use them to prevent solvent loss and
contamination. Tanks should only be open when placing a part into the tank, manually
scrubbing a part, or when removing a part. Slide covers are preferred over removable or
hinged covers.
Locate cleaning tanks away from open doors or any place where there may be drafts.
Ropes or cloth bags should never be used to hold parts. The materials used for holding
parts should be non-porous and non-reactive. Baskets should be designed to avoid drag-
out of solvent.

Problem 3
Hot Block Refractory Corporation
The Hot Block Refractory Corporation produces ceramic bricks used as refractory in boilers and
heaters. The process involves the wet mixing of two powders followed by drying and firing of the
mixture in bulk form. You have been asked to study the weighing and mixing operation as shown in
the attached figure. The following information is available:
o Powder A consists of an inert ceramic/binder mixture. Powder B consists of chrome
o The two powders are delivered in 50 pound sacks to the weighing station. 120 pounds
of A and 60 pounds of B are weighed and manually transferred to the wet vibratory
o Water is added to the grinder and after mixing, the slurry is gravity fed into brick form.
The forms rest on the floor and when one becomes full, the operator uses an empty
form to push the filled form out from under the spigot.
o The grinder is flushed with water after each batch. The area is washed down after each
shift. All wastewater goes to the area sump.
Your job is to identity all possible wastestreams and propose viable waste minimization options for

Hot Block Refractory



"Hot Block Refractory Corp." Solutions
Improve operator training - Does the operator wear proper protective gear? A sloppy
operator can destroy the effectiveness of any WM measure. Mistakes due to ignorance can be
corrected by training, mistakes due to carelessness are inexcusable.
Provide closer supervision.
Tighten equipment inspection and maintenance.
Purchase materials (especially the most hazardous) in pre-weighed containers (eliminates
weighing) or in recyclable containers (eliminates bags). Powders in paste form may also be an
Use dust reducing metered hoppers for both powders A and B. Use a collection berm or bin
around the hopper to collect dusts and spilled powders. This material can then be reused.
Locale equipment as close as possible to each other. This would limit the amount of wastes
generated by the transfer processes.
Use a vacuum system to collect spilled powder instead of washing to the sump. If possible,
scoop up bulk of spilled powder for re-use before vacuuming. A vacuum system would require
dust control and collection systems and a scheduled filter maintenance plan.
Dedicate grinding units so that the need for cleaning is minimized or eliminated. Don't over
Install a slurry pump unit on the wet grind to fill the brick forms. A collection tray or bin
should be placed under the transfer point of the slurry to the forms to collect any spilled slurry.
To reduce spillage, install a positive cut-off valve on the wet grind unit.
Install dedicated baghouse dust collection system for equipment so as not to contaminate all
collected shop dust with chrome.
Investigate ways to recover chrome compound from sludge and dusts for possible re-use on-
Investigate off-site usage of sludge and dust as raw material (possibly sell to a smelter or
pigment manufacturer).
Segregate empty packages.
Store raw materials properly.

Training Exercise Background
BlueMoon Inc., a manufacturing firm, produces thousands of widgets annually at their
facility in Industrial Town. Associated with the production of their widgets, is the
generation of 18,000 tons of a waste by-product annually. Workers at the factory have
taken to calling this waste bluegoo. At various times in the past. BlueMoon has dumped
bluegoo into the water, released it into the air, and shipped it to hazardous waste sites.
Like most businesses, their goal is to legally dispose of the bluegoo at the lowest cost.
BlueMoon is a major employer in the economically depressed area of Industrial Town.
They currently have permits to discharge 6,000 tons of bluegoo into the sewer and
6,000 tons of bluegoo into the air. The remaining 6,000 tons is disposed of in a
hazardous waste landfill.
The Industrial Town Consolidated Sanitary District has been notified by state authorities
that the discharge from their treatment facility is not meeting new federal standards. The
local air district is now regulating the treatment facility as a major emitter of ozone
precursors. In addition, the treatment facility's sludge has contaminants in excess of
proposed EPA levels. To address these constraints facing their operations, the Sanitary
District is considering reducing the discharge limits of all permittees, including
BlueMoon's. If the District doesnt respond to state and federal laws, they may be fined
The Industrial Town Air Pollution Control District is receiving pressure from the State Air
Resources Board to clean up Industrial Town's air, which does not meet standards
established by the Clean Air Act. In addition, local environmental groups have
successfully sued the District and obtained a court order mandating that the District clean
up the air. BlueMoon is a major source of air contaminants in the air basin. If the District
fails to clean up the air, the EPA may take over air pollution control in Industrial Town.
The Industrial Town Environmental Health Agency has been informed by the operator of
the nearby hazardous waste disposal facility that they can no longer accept untreated
hazardous waste due to land disposal bans established by State and Federal laws. The
Environmental Health Agency has informed BlueMoon of this development and has also
informed them that a new state law has been passed which requires major hazardous
waste generators to conduct source evaluation and review plans analyzing waste
generation and disposal patterns in their operation. In addition, a waste management
firm is proposing to site a hazardous waste management facility near Industrial Town to
handle bluegoo. Town leaders are opposing the proposed facility.
The trade association that BlueMoon is involved in has recently completed a report
describing how injection wells can be used for bluegoo disposal. Their analysis is that
injection wells can be a legal, cost-effective waste disposal technology.

Multimedia Pollution Prevention Training Exercise Design
10 min. Air, Land, and Water get into groups to answer: What would be your
agency's possible response(s) to this situation with BlueMoon? They list on
flipchart paper.
20 min. Agencies report back to full group what is on flipchart.
20 min. Facilitator: What would BlueMoon's likely response be to each of these?
(Done separately) Recorder lists. What would BlueMoon's likely response be
to all of these combined? Are these responses best for the environment? For
each agency? Rhetorical question: What would happen if interagency
communication and cooperation occurred?
20 min. New groups form including agencies and industry reps, to answer: What
kinds of approaches could be pursued by the regulatory agencies working
together? How could they affect the outcome?
30 min. Groups report to full group on answers to both questions.
10 min. Facilitators: Discussion centering on group's responses and on this being the
goal of the rest of the day's program. They will hear big picture perspective
from the keynote speaker, will hear local agencies' issues, perspectives, and
programs, and will hear about a successful pilot project that used an
innovative multimedia approach to waste minimization.

Exercise design by:
Jane Straus, Bare Bones Training & Consulting
Tony Eulo, Local Government Commission
Dave Hartley, California Department of Health Services
What would be your agency's possible response(s) to the situation with Blue Moon?
Small Group Answers:
•	Evaluate the facility:
Review current practices at Blue Moon.
Review Blue Moon's SB 14 plans.
Determine the impact of bluegoo.
•	Regulate and cut Blue Moon's allowable discharges.
•	Provide instruction regarding pretreatment and alternative disposal methods; advise
on proper disposal sites.
•	Reduce emissions of bluegoo via control technologies:
Scrubbers wet/dry
Catalytic converters
•	Increase monitoring of Blue Moon:
Develop compliance schedule.
Require immediate compliance when possible.
•	Consider Bluegoo for use as a raw material in another manufacturing process.
•	Reduce the volumeAoxicity of bluegoo at the source via process modification or
safer substitutes.
•	Recycle bluegoo at Blue Moon or at a recycling facility.
•	Encourage commitment from management.
•	Consider a local tax incentive for capital improvements.
•	Injection wells are not recommended; would like to see EIR for wells.
What would Blue Moon's likely response be to each of those?
Group Answers:
•	Ask "Why start now?"
•	Ask for more time.
•	Go to Mexico.
•	Ship bluegoo to third world & label "recyclable".
•	Threaten to take jobs away.
•	"Job out1 to subcontractors making parts for widgets.
•	Request a special waiver.
•	Ask "How much cost is involved?'
•	Request a meeting with regulators regarding compliance issues.
•	Ask 'Which laws have precedence in cases of conflicting laws?1

•	Ask "what resources are available, i.e., consultants, industry associates, public
•	Ask for financial assistance, tax incentives.
•	Implement proactive top management.
•	Propose a time line & plan to change process.
•	Begin treatment to keep regulators off of their back.
•	Temporarily shutdown plant to correct problem.
•	Utilize a transportable treatment unit.
•	Implement a waste exchange program.
•	Encourage industry-wide research and development.
•	Recycle bluegoo.
•	Eliminate bluegoo from production process via substitution.
What kinds of approaches could be pursued by the regulatory agencies working
•	Perform multimedia/comprehensive waste audits.
•	Hold interagency scoping meeting:
Determine lead agency for coordination.
Discuss roles and responsibilities of each agency.
Come to agreement on information needed from the facility.
Agree on permits needed.
•	Review regulations and needs from agencies; eliminate contradictions.
•	Coordinate overlapping functions.
•	Identify individual agency concerns.
•	Have each agency identify its problems and its tolerance (what each agency can do
without violating its own requirements).
•	Set priorities among agencies.
•	Coordinate the collection of information.
•	Develop a comprehensive regulatory package for industrial firms.
•	Meet with facility top management to:
Seek cooperation.
Obtain input from facility. Define issues/problems.
Discuss available alternatives.
Explain plan of action.
•	Utilize BACT (best available control technology)
•	Seek most efficient way to treat waste in air, water, and land. Determine which of
these three processes is most effective - and treat all waste this way.
•	Form a compliance schedule.
•	Long-term: Lobby the legislature to require interagency coordination.
How could these approaches affect the outcome?

•	Encourage cooperation, resulting in fewer inter-agency disputes and better
utilization of personnel and information.
•	Establish cross-training programs.
•	Establish regional goals.
•	Coordinate compliance incentives of all agencies.
•	Consolidate consulting work for one plan instead of one for each agency.
•	Allow agencies to pool technical and financial resources.
•	Synchronize inspections.
•	Assure that all environmental media are addressed.
•	Result in greater leverage in getting industry compliance.
•	Provide enhanced communication between and among industry and regulators.
•	Reduce confusion and conflict regarding industry requirements by coming up with a
compliance plan.
•	Encourage information and technology transfer among industries.
•	Potential cost savings to industry from reduced controls, fines, consulting fees.
•	Having one permit will reduce cross media waste.
•	Management will be provided with all available information and technology.
•	Management will be provided with contacts at lead agencies that can answer
regulatory questions in a comprehensive manner.
•	Potential for turf battles and/or negative political impacts.
•	Laws are not set up for interagency work.
•	Legislators lack awareness of the impacts of single-media regulation.
•	Coordination between different levels, i.e., local, regional, and state agencies would
be necessary.
•	Agency commitment could vary depending on their perception of the problem.
•	Many battles have been fought separately; agencies may be reluctant to give up
ground gained.
•	There are potential problems of accountability and liability.
•	Fear from administration.
•	Difficulty in formulating a one-format permit application.
•	Mediators would be necessary to close the gap between availability and
implementation of alternatives.
•	It is necessary to strike a balance of economic and environmental and political

Role Play #1
4 ways that management may evaluate pollution preventions
-as a labor/management issue
-as a business strategy issue
-as a philosophical issue
-as a technical issue
Situation description
ABC Co. is a small shop using a solvent (1,1,1-trichloroethane) for degreasing parts.
Waste solvent is generated at the rate of one drum per month, and disposed at a cost of
$1,500+/year. One drum per month is lost as air emissions. Material costs at 2 drums
per month x $300 per drum = $7,200 per year. After a walkthrough of the shop to
evaluate solvent use, the following pollution prevention options are indicated:
•	Replace open buckets with plunger cans
•	Install automatic lid on vapor degreaser and automatic removal system
•	Distill waste solvent on-site and re-use
•	Replace solvent with alkaline cleaner
Description of pollution preventer
After situation was evaluated, suggestions were pulled from basic resources. Further
evaluation as to payback and practicality is up to the company. The job of the pollution
preventer is to promote, persuade, and encourage in favor of further exploration and
Description of management
Founder and owner. Profitable company. In compliance with all current regulations.
Minor violations in the past. Friendly but conservative.

PP = Pollution Preventer
M = Management
M: So, what good ideas do you have for us?
PP: Well, there are a lot of open buckets of solvent out there. I've seen some
containers called plunger cans that might cut down some evaporation loss.
M: Oh, great. If I tell them to lose those buckets, they'll just hide 'em under their
benches. They can be stubborn, you know, about how they like to do things.
PP: Dont they mind the solvent smell?
M: Some do, some don't. But I could mention that. Lord knows they complain
enough about other things. Any other ideas?
PP: You might consider an automatic and a hoist above the degreaser. Then it would
be closed more often, and parts wouldn't get yanked out so fast.
M: Well, I think a lid would be disabled in a week. There's no way they'd put up with
that. But a hoist might fly. They don't like pulling baskets out. It's hard on the
back, I know it is.
PP: Maybe you could go a step further and recycle that dirty solvent yourself. You'd
save some money, and I've seen other shops like yours do it.
M: Sounds like another can of worms. I can hear it now. "That recycled stuff dont
clean right. Why do we have to mess around like this1? They'd blame the solvent
everytime they had a reject.
PP: I know, I've seen that happen too. If you're going to get them riled up anyway, I
think you should stop using that solvent entirely. A different cleaner might do the
trick. It would probably take some testing, but...
M: Right, and who's going to do all that? I've got a shop to run here. Show me
something that works for sure and I'll think about It. I cant afford to rock the boat.
Things are tight enough.

PP = Pollution Preventer
M = Management
M: Well, what did you find in your little walkaround?
PP: There are a few things that could be changed...
M: Well, now, that always the case, isn't it? Just wait til those guys hear something
might be changed. I'll have questions thick as black flies. What exactly do you
have in mind?
PP: For one thing, all those open buckets are evaporating quite a lot of solvent into the
M: Great, that's great. If I tell them to lose those buckets, they'll just hide them under
the benches. We can't even switch to another solvent, that's how stubborn they
PP: It also might be possible to cut some evaporation by modifying the degreaser.
M: What do you mean?
PP: I was thinking about a lid that would close automatically and some sort of hoist to
control how fast parts are pulled out of the degreaser.
M: We might get somewhere with the hoist. They complain a lot about having to yank
baskets out of there. The lid would be disabled in a week, I guarantee you. In the
PP: Dont they complain about the solvent smell?
M: Come to think of it, they do. That kind of argument could help.
PP: Now I've got a couple of bigger changes on my list. First you could be doing some
distillation and reusing...
M: Oh, boy, now there's a can of worms. I can hear it now. This used solvent's no
good. This just dont clean right Remember what I said about trying to change
solvents? This would be a lot worse, let me tell ya.
PP: Maybe the way around a lot of this is to switch out of solvents altogether, clean with
something else. You have fairly simple requirements, it seems.
M: Still the same problem. They just don't want to change. Everything is too much
work for them. I have to watch all the time to get out of them what I do.

Pollution Preventer position description
Your job is to convince a somewhat resistant business person to try something. The
manager is not too concerned about air emissions, since regulations still seem to be
coming, but are not yet here. This shop is a "follower" in the sense of not being very
innovative. While not necessarily a long-range thinker, an appeal to consider elimination
of solvent use might sway this manager. Again, the options are:
•	Plunger cans in place of open buckets
•	Lid and hoist for the degreaser
•	On-site distillation and re-use
•	Replace solvent with another cleaner
Things you might mention:
If you're able to distill your used solvent yourself and re-use it, you could save up
to 3000 per year at your waste volume.
If you're concerned about quality, you might just do a trial run with a substitute to
see how it works.
Have you heard anything about what other shops are trying?
If you did away with this sort of solvent, you could improve working conditions,
reduce your liability, and reduce your cost, all at once.
What do you workers think about the solvent smell out there?
Is there anything you'd like to look at more, or maybe try?
To get you started:
M: So, what good ideas do you have for us?
PP: Have you considered doing this cleaning without this solvent?

Management position description
You are very concerned about future liability and your regulatory status. You are nervous
about the operation of distillation units from the standpoint of safety. You also worry
about the effect on product quality of not using virgin solvent. You don't really feel that
you have the time to bother with another process, which you see on site distillation to be.
Regulations are getting in the way, when it's hard enough to make money.
Things you might ask about:
Is distilled solvent as good as the new stuff?
How hard are these distillation units to run?
How can I find a substitute cleaner?
Do you know what other shops are doing to reduce solvent waste?
How will changes be regarded under the regulations?
How can I do something to protect myself from future liability?
To get started:
M: So, what good ideas do you have for us?
PP: Have you considered doing this cleaning without this solvent?

Pollution preventer position description
When confronted with management which is philosophically negative, your sell job is
probably the hardest one of all. You still want this manager to at least try one of the
options you've come up with, but you'll probably be caught up in a battle of words.
Every assumption which underlies environmental protection will be open to question, and
cynicism and criticism will run rampant. The only good persuasive hook is cost savings
($2,000-3,000 per year), and even this will probably be questioned. Don't bother to
argue, just try to explain as best you can. Again, the options are:
•	Plunger cans in place of open buckets
•	Lid and hoist for the degreaser
•	On-site distillation and re-use
•	Replace solvent with another cleaner
Things you might defend yourself with:
You might have fewer annoying regulations to deal with if you reduce the waste
you generate.
There are no guarantees; all you can do is try something out in your shop.
You probably will save some money by reducing your solvent waste.
The regulations change slowly; we might be able to reduce your waste right away.
To get you started:
M: See anything interesting?
PP: Well, I do think there are some changes you might want to look at.
M: You know, I wouldn't have to look at anything if it wasn't for these crazy rules.

Management position description
Regulators don't understand your business, and these regulations are a giant pain.
There's no way things can be accurately measured at such low concentrations. It's
impossible to comply with all these regulations and stay in business. Waste reduction
tries to show cost savings-but it's mostly a bunch of projections. You dont want to
change perfectly good processes; what if something goes wrong? No one else complies,
why should you? The regulators wont catch you anyway; they don't even know what
they're seeing.
Things to ask about;
Why should I change my processes?
Why do the regulations keep changing?
How do I know what to do first?
My people have worked with this solvent for a long time, and they're all healthy.
I cant stay in business with all this paperwork getting in the way.
What about all those other guys?
To get you started:
M; See anything interesting?
PP: Well, I do think there are some changes you might want to look at
M: You know, I wouldnt have to look at anything if it wasnt for these crazy rules.

Pollution Preventer description
Quality and reliability are big issues here, so it might be best to suggest a gradual
approach, but aiming at distillation or replacement of the solvent. You won't be able to
answer all the questions this manager has. The first two options might get ignored
entirety, just because they're not "sex/1. Again, the options are:
•	Plunger cans in place of open buckets
•	Lid and hoist for the degreaser
•	On-site distillation and re-use
•	Replace solvent with another cleaner
Things to mention:
Since there are quite a few distillation units in the field, technical back-up is good.
Many questions can't be answered without some testing on specific applications.
These units are built to be operated safely in a shop environment.
To get you started:
M: So, what good ideas do you have for us?
PP: Have you ever considered recycling your solvent here in the shop?

Management position description
You don't mind trying new things, especially if they might help you get ahead. In fact you
don't even mind tinkering a little to make something fit. You do want things to go well,
however, and you run a tight ship as far as quality and maintenance go.
Things to ask about:
How hard is it to run the distillation unit well enough to get usable solvent?
Can quality be affected by poorly distilled solvent?
How safe are these units?
Arent the still bottoms considered a hazardous waste?
Are these units easier to maintain than a degreaser?
Will I get more control over solvent quality?
Am I to be ahead of the pack if I do this?
To get you started:
M: So, what good ideas do you have for us?
PP: Have you ever considered recycling your solvent here in the shop?

Role Play #2
4 groups who have a stake in implementing change
-line management
Situation description
ABC Co. has decided after careful evaluation to eliminate solvent use from the shop by
switching to an aqueous alkaline cleaner. Capital costs ($7500) will cover replacing the
degreaser with appropriate tanks and disposal and purchase of chemicals. Disposal of
waste cleaner will be simpler and cheaper, but care must be taken lest it build up in
heavy metals and be judged a hazardous waste. Effects on quality are still not fully
known, although bench-scale testing gave favorable results. Material costs will drop
substantially. Parts will take nearly twice as long to clean, but this time extension should
affect the profitability of the process.
Description of pollution preventer
After much evaluation, ABC has finally gone with a solution which holds excellent long-
term promise. However, implementation is still to come. The job here is not only to
persuade, promote, and encourage, but also to coordinate the inevitable rumblings so
that they are answered appropriately, before derailing the project.

Management reaction
PP = Pollution preventer
M = Management
PP: Are you having any afterthoughts about the changes being made?
M: Not much. Seems like it could be expensive.
PP: How so?
M: Well, I have chemicals to dispose of, and equipment which isn't fully depreciated
which no one wants, and if we have QC problems I could lose customers.
PP: But you knew all that, and still decided to go ahead.
M: I pretty much had to. Between worker exposures and the neighborhood knowing
more about what's what in here and all these laws about plans and such, I just had
to do it.
PP: Any feedback yet?
M: I'm sure they're all just waiting out in the shop for their first reject so they can blame
it on the cleaner. But when it comes right down to it, they have to like it. They
have no choice.

Line management reaction
PP = Pollution preventer
LM = Una management
LM: This sure is getting to be a lot of work.
PP: How so?
LM: Moving all this equipment around, drumming stuff up. I'm having a heck of a time
keeping a production schedule.
PP: But the end's in sight, isnt it? You look pretty well done with the hook-up.
LM: I wish it were so, but I've got to get all my guys squared away on this cleaning
process, and I'm not even quite sure how it goes.
PP: Has the supplier been working with you?
LM: Yeah, right. "Call me if you run into any trouble," he said. Just what I need.
PP: It sure does smell better back here now, though. It must be great to be rid of that
LM: That's one good thing. It's a whole lot easier to work a whole day back here now.

Production reaction
PP = Pollution preventer
WP = Working person
PP: What do you think about getting rid of the solvent?
WP: It's all right, I guess. It sure did smell back here at times.
PP: Do you think the alkaline cleaner will work as well?
WP: I expect it will, after we all get used to it. The solvent was easy, and fast, but sure
could tear up your skin. I'll tell you one thing, though. The guy who gets in trouble
when parts don't turn out won't be the supplier, or the boss. It'll be old me. And I
don't like that.
PP: What can you do?
WP: I don't know, really. I wish I knew more about this cleaner they're bringing in here.
We get some stuff sometimes that's real hard to clean. I dont know how they
expect to get that kind of thing ciean with a little soap.
PP: How do you usually start up a new process?
WP: The boss says, "Do it" and we do it until something goes wrong, then we stop up,
and try her again. And it sure can be wasteful. I wish they'd ask us once in a while
what's going on. They get the screwiest ideas sometimes about what might work.

Customer reaction
PP = Pollution preventer
C = Customer
PP: Do you have any particular concerns to the switch to a new cleaner?
C: As long as I get my parts and they're good, I don't care. That's it basically. I will
be looking harder for a while, though
PP: You'll do more inspections, things like that?
C: Right.
PP: Will you hold these parts to a higher standard for a while?
C: I suppose that's about the gist of it. We have had good parts, and we have to be
PP: Were you consulted about the change?
C: Not in advance. In fact, we only found out by chance through one of our buyers.
That doesn't help matters.
PP: Have you ever been consulted on a manufacturing change in advance?
C: Oh, sometimes. Not commonly. There's not much we have to offer. Meet the
specs, don't charge too much.

A large tobacco products company generates approximately
7,000 kg/month of spent 1,1,1-trichloroethane (RCRA P001 spent
halogenated degreaser) used to cle*n engraved printing cylinders,
cylinder pans, splatter guards and other machinery used for
printing cartons and labels for cigarette packages. The
contaminated solvents, after solids settling, are discharged to a
5,000-gallon underground storage tank. Every five or six months
the solvents are shipped to a recycler for solvent reclamation or
incineration. Sludge is accumulated on site in 55-gallon drums
before shipment to an incinerator facility.
In compliance with the 1984 HSWA amendments, as a permit
condition and requirement of the manifest, the generator
certified that it "has a program in place to reduce the volume
and toxicity of the waste to the degree economically
The facility has submitted a RCRA Part B permit application
as a storage facility. A RCRA Facility Assessment (RFA) has been
performed to determine if there is any evidence of a release.
The findings of the RFA indicated a release had occurred and a
subsequent RCRA Facility Investigation (RFI) performed by the
generator confirmed the release. A corrective measure study vas
performed to determine the appropriate steps to mitigate the
problem. The facility operator recommended three actions:
(1)	replacement of the leaking tank;
(2)	ground-water stripping to clean up the contaminated
media; and
(3)	installation of a batch-distillation unit for solvent
The Problem . . .
You must review the proposed corrective action as part of
the Part B permitting process. The recently-proposed RCRA
Corrective Action Rule (£B 30798, July 27, 1990) specifies
general factors to be considered as appropriate by EPA in
selecting a remedy. These factors include:
•	long-term reliability and effectiveness, and
•	reduction of toxicity, mobility or volume of waste
* * * September 21, 1990 * * *

Techniques which may offer short term solutions to
contamination problems could potentially lead to the creation of
new risks if cross-media transfer is not taken into account.
Cross-media transfer of contaminants could potentially be
considered when evaluating these decision factors. Air stripping
alone may create a new risk (transferring the contaminants from
ground water to air). The permit writer may consider requiring a
treatment technology prior to or in place of air stripping.
The new corrective action process will place greater
emphasis on source controls to minimize further releases.
Keeping within the spirit of this policy, waste reduction
solutions will help to prevent future releases to the
Although specific authority to require waste reduction as
part of the corrective action remedy may not exist, this forum
presents a good opportunity to suggest to the facility operator
the virtues of pollution prevention.
By installing a batch-distillation unit the facility can
recover over 90 percent of the solvent for reuse. This procedure
would reduce the generation of hazardous waste by 95 percent and
allow the facility to become a small quantity generator storing
the remaining contaminated solvent and sludge in 55-gallon drums
before shipment to an incinerator facility.
* * * September 21, 1990 * * *

A.	Pursuant to 40 C.F.R. 264.73 (b) (9), and Section 3005(h) of RCRA, 42 U.S.C. 6925(h). the
Permittee must submit to the Regional Administrator, at least annually, a waste minimization
certification. This certification and all accompanying documentation shall be submitted
annually on each anniversary date of the effective date of this permit.
B.	The Permittee must certify that:
(1)	A program is in place to reduce the volume and toxicity of hazardous waste generated to
the degree determined by the Permittee to be economically practicable; and
(2)	The proposed method of treatment, storage or disposal is that practicable method
currently available to the Permittee which minimizes the present and future threat to
human health and the environment.
C.	The Permittee shall submit a Waste Reduction Impact Statement within one hundred and fifty
(150) days of the effective date of this Permit. The Permittee shall include the following
information in the Waste Reduction Impact Statement:
(1)	An identification of the annual amount and types of hazardous waste that are generated;
(2)	For each waste stream, an identification of the source of generation of these hazardous
(3)	an analysis of technically and economically feasible hazardous waste reduction techniques
for the facility, including a description of any techniques that were implemented since
I9K4, at a minimum; and
(4)	a program and schedule for implementing the feasible hazardous waste reduction
D.	In conjunction with the annual certification required by conditions A and B above, the
permittee must submit an annual report to EPA on the status of waste reduction techniques,
including those which have been implemented during the previous year and those specified in
the Waste Reduction Impact Statement required by condition C above.

Description of Pacillty
A hypothetical company, BORCO (Big Oil Refining Company),
wishes to obtain all necessary permits to modify their crude oil
refinery in a large industrial district in the southeastern
United States. BORCO's air permit application specifies the use
of a wet-based nonregenerable flue gas desulfurization (FGD)
technology that is guaranteed by the design firm to meet the
applicable air emissions regulations for exhaust gases. The new
gas stream may contain less than 5,000 ppm of S02.
The proposed technology is a well known approach that has a
proven record in applications such as the one at hand. The
approach, however, results in the generation of an aqueous waste
stream requiring disposal. Simultaneous with applying for the
air permit, BORCO is also applying for a NPDES permit to allow
direct discharge of this aqueous waste stream into a local
While BORCO's permit application is well done and suggests
that BORCO will be able to comply with all applicable numerical
CAA requirements, you realize that the combination of approaches,
that they are proposing will result in cross-media transfer of
wastes. On one hand, you consider approving the air permit
application and assuming that the NPDES permit writer will be
responsible for invoicing CWA authority to ensure proper
management of the waste water resulting from the FGD. On the
other hand, however, you are reminded of a section in an air
permit writer's training manual you read recently about the
importance of considering the cross-media impacts of any air
permit application.
Since it occurs to you that there should be a better way to
control the S02 in air emissions than by putting it in the water,
you decide to check with a few other engineers. By so doing, you
realize the potential of regenerable dry-scrubbing technologies.
In general, these technologies result in the generation of
elemental sulfur, liquid S02, or liquid S03 as a saleable
endproduct; and a byproduct that is recycled back into the
desulfurization process. The so2 removal efficiencies of these
techniques is typically in excess of 90 percent. Regenerable
processes, however, have higher capital and operating costs than
nonregenerable processes. You know that there is at least one
phosphate fertilizer plant in the vicinity of BORCO's proposed
refinery, and perhaps other facilities as well that might
represent potential markets for BORCO's saleable sulfur-
containing endproduct.
* * * DRATTj September 21, 1990 • * *

- 3 -
Lessons Learned — petroleum Refinery
1.	Permit writers nay be able to influence applicants to adopt
pollution prevention techniques even though they say not
have the specific statutory authority to require applicants
to do so.
2.	The choice of a particular pollution control technology nay
have a significant inpact on the overall net effect of a
process (or a facility) on the environnent — permit writers
should be prepared to affect the selection of such
3.	Movement of process residuals from one environmental medium
to another (or from one permit writer's area of
responsibility to another's) can occur easily, but should be
avoided whenever possible.
* • * DRMPT: September 21, 1990 * * •

U.S. Electroplating is a large midwest electroplating firm
which specializes in kitchen appliances, utensils, tools, and
cabinet hardware. The firm commonly uses a variety of metal-
cyanide electroplating baths to process its products. The firm
generates seven primary waste steams.
Generally, the firm combines concentrated cyanide wastes
from the plating and cleaning solutions with filter sludge before
treatment and disposal. Also, acidic wastes and dilute cyanide
solutions are segregated and treated separately. You are part of
a special team of permitting staff looking at the facility as it
impacts all media.
U.S. Electroplating recently hired an independent contractor
to perform a facility assessment consisting of a review of the
plant's operations and waste streams, development of options with
the potential to minimize waste, and the technical and economical
feasibility evaluation of the controls. The firm has presented
you with a summary of the facility assessment that highlights the
scope of pollution prevention opportunities they have identified.
oeod House Keeping Practices Applying to All waste Streams
¦	Employee Training
signs and methods of detecting the release of toxic
materials into the work environment
a review of good operating practices for
storing and transporting toxic materials
proper equipment use
¦	Procedural Measures
tracking and inventory control of material/waste's
location, quality, age, and use
¦	Spill Prevention
monthly inspection of tanks for leak or potential
spent Plating solution and Pilter Sludge
¦	Increase longevity of plating solution
clean the workpiece to reduce drag-in contamination
from one bath to the next
* * * September 21, 1990 * * *

¦	By replacing cyanide plating solutions with cyanide-free
solutions, and thus requiring upgrading of the
degreasing/cleaning techniques, you nay be reducing one
waste stream (toxicity of spent plating solutions) but at
the same time increasing another (work cleaning wastes).
Additional assessment would be required to determine whether
or not there was a net gain.
¦	Reducing the amount of rinse water without reducing drag-out
may result in a smaller, but more highly toxic, volume of
treatment sludge.
¦	Volume reduction through surface impoundment evaporation
is lowest on the pollution prevention hierarchy (land-
based treatment)
must include measures to control air and surface
without reducing contaminant concentration in the rinse
water, a larger volume of sludge will be exchanged for
a smaller volume of wastewater
¦	Burning used cleaning rags and spent binder waste
is low on the pollution prevention hierarchy
will shift waste management from the land to air medium
* * * September 21, 1990 * * *

Description of Facility
This hypothetical facility, owned and managed by AquaVanp,
Ltd., is a snail privately-owned boat restoration and renovation
facility. The facility is located on a snail bay off a major
inland waterway and primarily services privately-owned motor-
powered vessels of 65 feet or less. The facility services 150 to
175 vessels per year. The staffing of the facility varies with
the seasons and workload. Minimum staffing averages seven
Typical services performed at AquaVanp include washing and
cleaning of vessels, stripping (using chemicals and abrasives)
and painting of hulls, and servicing and rebuilding of vessel
superstructures and mechanical systems. Average vessel residency
is two to three days.
The facility consists of docks, drydocks, marine elevators
and railways, mechanical and engine shops, and a parking lot.
The facility has all support services, including machine shops
and painting stations, on site. Solvents, fuels, lubricants,
paints, chemicals, and abrasives are kept on site. They are
frequently handled and transferred in the open and/or in large
quantities. When these materials are wastes, they are handled in
accordance with RCRA hazardous waste regulations (including
manifest, storage, and waste minimization certification/planning
Most of Aquavamp's infrastructure, including the buildings,
vessel handling systems, and pump/drainage systems are 35 to 45
years old. As the facility ages, maintenance burdens grow
greater. According to Mr. C. Leggs, the facility manager, a
chronic maintenance problem is the accumulation of used
sandblasting media in the sumps and pumps of the drydocks. Mr.
Leggs has noted, however, that a decline in the prevalence of
algae and snails on the superstructure of the vessel handling
systems has had an overall positive impact by reducing required
maintenance in that particular area.
The Problem . . .
As a permit writer, you are going to use your authority
under CWA Section 402(a)(1) to require facility-specific best
management practices (BMPs) in AquaVamp's NPDES permit. The
objective for including the BMPs in their permit is to prevent
pollution as much as possible. Therefore, you would like their
plan to resemble a waste minimization/pollution prevention plan.
• • * September 21, 1990 * * *

- 3 -
Lessons Learned — small Boatyard
1.	In general, BMP plans nay be most applicable to ancillary
activities at a particular facility. The general activities
for which BMPs may be most applicable include:
•	material storage;
•	loading and unloading operations;
•	facility runoff control;
•	process, materials transfer, and handling operations;
•	sludge and hazardous waste disposal.
2.	A BMP plan generally has specific elements (requirements).
These elements may include:
•	a plant-based BMP "committee,"
•	risk identification and assessment,
e	reporting of BMP incidents,
•	materials compatibility
•	good housekeeping,
•	preventative maintenance,
•	inspections and recordkeeping,
•	security, and
•	employee training.
3.	BMPs may include some of the very same elements as those
presently used in other programs, for example:
•	safety,
•	loss control,
•	fire protection,
•	insurance qualification,
•	waste minimization planning.
•	public relations/image management, and
•	spill prevention, control, and countermeasures (SPCC).
4.	Permit writers £2 have the authority to incorporate
requirements for BMP plans in permits as a means of
preventing pollution. This authority is described in
Section 402(a)(1) of the Clean Water Act.
* * * September 21, 1990 * * *

Slide Show

E. UNEP Audit Manual

Environmental Pollution
Prtveitton Project
Distributed liv the
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Suite 900
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United Nations Industrial
Development Organization
PO BOX 300
TR: 431 211 310
FAX: 431 232 156
United Nations Environment
TEL: 33(1)40 58 8850
TLX: 204997F
FAX: 33(1)40 58 88 74

This is the seventh publication in a new Technical Series that regroups the
Guidelines, Overviews, Technical Reviews and Workshop Proceedings previ-
ously published by UNEP/IEO. The regrouping into a single series will ensure a
greater cohesion among future publications, and allows a single document to
include the various elements of IEO work that had earlier been presented
As before, the Technical Series aims to meet the needs of a wide range of
governmentofficials, industry managers and environment protection associa-
tions, by providing information on the issues and methods of environmental
management relevant to various industrial sections.
Copyright © 1991 UNEP
All rights Reserved. No part of this publication may be reproduced, stored in a
retrieval system or transmitted in any form or by any means: electronic, electro-
static, magnetic tape, mechanical, photocopying, recording or otherwise, without
permission in writing from copyright holders.
First edition 1991
The designation employed and the presentation of the material in this publica-
tion do not imply the expression of any opinion whatsoever on the part of the
United Nations Environment Programme concerning the legal status of any
country, territory, city or area or of its authorities, or concerning delimitation of
its frontiers or boundaries. Moreover, the views expressed do not necessarily
represent the decision or the stated policy of the United Nations Environment
Programme, nor does citing of trade names or commercial processes constitute
SaltaN0 91-ID-D6
ISBN 92-807-1303-5
[Reproduction authorized by the United Nations Environment Programme Industry and
Environment Office (UNEP/IEO), Paris, and the United Nations Industrial Development
Organization (UNIDO), Vienna.]

Table of Contents
Acknowledgements	iii
Foreword	v
Chapter 1	Introduction to Waste Auditing	1
Flow Diagram:	Quick Reference Audit Guide	5
Chapter 2	The Audit Procedure	i
Phase 1	Preassessment	9
Step 1:	Audit Focus and Preparation	9
Step 2:	Listing Unit Operations	11
Step 3:	Constructing Process Flow Diagrams	12
Phase 2	Material Balance: Process Inputs and Outputs	15
Step 4:	Determining Inputs	15
Step 5:	Recording Water Usage	18
Step 6:	Measuring Current Levels of Waste Reuse/Recycling	19
Step 7:	Quantifying Process Outputs	20
Step 8:	Accounting for Wastewater	21
Step 9:	Accounting for Gaseous Emissions	23
Step 10:	Accounting for Off-Site Wastes	24
Step 11:	Assembling Input and Output Information for Unit Operations	25
Step 12:	Deriving a Preliminary Material Balance for Unit Operations	26
Step 13:	Evaluating the Material Balance	26
Step 14:	Refining the Material Balance	27
Phase 3	Synthesis	28
Step 15:	Examining Obvious Waste Reduction Measures	29
Step 16:	Targetting and Characterizing Problem Wastes	30
Step 17:	Segregation	31
Step 18:	Developing Long-Term Waste Reduction Options	31
Step 19:	Environmental and Economic Evaluation of Waste Reduction Options	32
Step 20:	Developing and Implementing an Action Plan: Reducing Wastes and	35
Increasing Production Efficiency
Chapter 3	Case Studies	37
Case Study 1:	Beer Production	39
Case Study 2:	Leather Manufacture	56
Case Study 3:	Printed Circuit Board Manufacture	78

Tabla of Contents continued
Chapter 4	Resource Section	101
Appendix 1	Wastewater and Gas Flow Measurement Methods	103
Appendix 2	Glossary	111
Appendix 3	References	115
Appendix 4	UNEP/IEO Cleaner Production Programme	119
Pull-Out Quick Reference Audit Guide

This technical guide has been prepared on behalf of the United Nations Environment Programme
- Industry and Environment Office (UNEP/IEO) and the United Nations Industrial Development
Organization (UNIDO), using the input and guidance of an international group of experts:
Mr M Belliappa, Environmental Research Foundation, India
Mr K Bradley, Wastart Ltd, Environmental Consultancy, Canada
Ms L Brown, Environmental Protection Agency, USA and Netherlands Organization for
Technology Assessment, The Netherlands
Ms T Hartcn, Environmental Protection Agency, USA and Netherlands Organization for
Technology Assessment, The Netherlands
Prof E Kempa, Institute of Sanitary Engineering, Poland
Mr D Mebratu, Sintec pic, Industrial and Waste Management Consultancy, Ethiopia
Mr A Somani, The World Bank, Washington DC, USA
Dr P Modak, CESE, Bombay, India.
UNEP/IEO and UNIDO would also like to acknowledge the assistance of the Ontario Waste
Management Corporation (OWMC) whose expertise and publications provided much valuable
guidance. The present technical guide has been adapted from an dieting waste audit and reduc-
tion manual published by the OWMC.
This guide has been prepared by ASHACT Ltd, Process and Environmental Management
Consultants (UK), under contract to UNEP/IEO.
UNEP/IEO staff participating in this project were:
Mme J Aloisi de Larderel, Director
Mr F Balkau, Senior Programme Officer
Mr J Kryger, Senior Consultant
Ms K Oldenburg, Senior Consultant.
Within UNIDO the project was coordinated by Dr R A Luken, Senior Environmental Advisor,
Environment Coordination Unit
The Government of Norway, acting through UNIDO, contributed financially to the preparation of
this manual

Sustainable development will only become a reality if we adopt methods of production that
generate less waste and fewer emissions than traditional industrial processes. Sometimes the
change involves the adoption of new, cleaner technologies of production. Even without new
technologies however, improvements in operation can often dramatically reduce the level of
release. A reduced level of emissions and wastes frequently means savings in costs of production,
as less valuable raw material is squandered.
Accurate information about the origins and sources of environmental releases is a prerequisite for
effective reduction of industrial emissions and wastes. Once the sources are identified, the most
cost-effective options for avoiding, reducing and recovering wastes can be evaluated.
In order to assist in the diagnosis of emission and waste sources UNEP/IEO and UNIDO have
joined forces to produce this audit manual. The manual is based on an earlier publication by the
Ontario Waste Management Corporation in 1987. In order to adapt it to as wide an international
audience as possible, UNEP/IEO and UNIDO obtained the advice of an international group of
experts who met in Paris for the two days of 1,2 August 1991.
The manual is a practical working document intended for use within industry. It can be used by:
•	factory personnel at all levels interested in upgrading their own processes;
•	consultants reporting to an industrial client;
•	government personnel reviewing existing factory operations.
Depending on the outcome of the audit procedure, information on reduction options can come
from a number of technical sources. In particular the International Cleaner Production Informa-
tion Clearinghouse (ICPIC), established by UNEP/IEO under its Cleaner Production Programme
with the support of the US EPA, allows rapid worldwide access to information on technologies,
programmes and experts in a number of key industry sectors. UNEP/IEO and UNIDO arc also
able to provide direct advice and follow-up technical assistance in many cases. Further informa-
tion about these programmes can be found in the appendices of this
It is hoped that decision-makers in industry and government will find in this document the ele-
ments to develop waste audits as one of the new management tools that lead to cleaner industrial
production becoming a reality in the future.


In the context of this manual, waste is taken as a broad term to include any non-product discharge
from a process. Thus, it describes discharges in the gaseous, liquid and solid phases.
In the past, waste management has concentrated on end-of-pipe waste treatment; designing
waste treatment plants and installing pollution control equipment to prevent contamination of the
A different philosophy has emerged in recent times, that of waste prevention and reduction.
Now we ask how can we prevent the generation of this waste? How can we reduce this waste?
Can we reuse or recover this waste?
This progressive shift from waste treatment towards waste prevention has the following benefits:
•	waste quantities are reduced;
•	raw material consumption and therefore costs are reduced;
•	waste treatment costs are reduced;
•	the pollution potential is reduced;
•	working conditions are improved;
•	process efficiency is improved.
In order to prevent or reduce waste generation you need to examine your process to identify the
origins of wastes, the operational problems associated with your process and those areas where
improvements can be made.
A waste audit is the first step in an on-going programme designed to achieve maximum resource
optimisation and improved process performance. It is a common sense approach to problem
identification and problem solving.
A waste audit enables you to take a comprehensive look at your site or process to facilitate your
understanding of material flows and to focus your attention on areas where waste reduction and
therefore cost saving is possible.
Undertaking a waste audit involves observing, measuring, recording data and collecting and
analysing waste samples. To be effective it must be done methodically and thoroughly together
will full management and operator support.
A good waste audit:
•	defines sources, quantities and types of waste being generated;
•	collates information on unit operations, raw materials, products, water usage and wastes;

Chapter 1: Introduction to Waste Auditing
•	highlight* process inefficiencies and areas of poor management;
•	helps set targets for waste reduction;
•	permits the development of cost-effective waste management strategies;
•	raises awareness in the workforce regarding the benefits of waste reduction;
•	increases your knowledge of the process;
•	helps to improve process efficiency.
The waste audit procedure can be applied on various scales. A waste audit of a region can
indicate problem industries. At the plant level, wastes can be traced to particular processes
allowing allocation of treatment charges where necessary, and at the process level the exact
origins of wastes can be identified enabling waste reduction measures to be established.
This manual is designed to be used by staff at all levels; technical as well as non-technical It is a
practical guide to help you understand your processes.
How To Use the Manual
A waste audit approach leading to the implementation of a waste reduction action plan is illus-
trated in the form of a flow diagram overleaf (see also the pull-out Quick Reference Audit Guide
at the back of the manual).
To undertake this approach use the Quick Reference Audit Guide and refer to the Audit Proce-
dure in Chapter 2 for instructions for each step.
As a starting point reproduce tables along the lines of Tables 1 • 9 to give you a basis for your
data collection and organisation.
Three case studies are included to illustrate the wide application of this waste audit and reduction

Step I prepare and organise audit team and resources
Step 2 divide process into unit operations
Step 3 construct process flow diagrams linking unit operations


This Chapter describes a step-by-step approach for carrying out a waste audit. It is designed to
be generic to apply to a broad spectrum of industry. The approach comprises three phases; a
preassessment phase for audit preparation; a data collection phase to derive a material balance;
and a synthesis phase where the findings from the material balance are translated into a waste
reduction action plan.
It is possible that not all of the audit steps will be relevant to every situation. Similarly, in some
situations additional steps may be required. However, the following approach should form the
basis of your investigations.
Use the Quick Reference Audit Guide at the back of the manual in conjunction with the follow-
ing explanatory notes to carry out your audit.
Step 1: Audit Focus and Preparation
A thorough preparation for a waste audit is a prerequisite for an efficient and cost-effective study.
Of particular importance is to gain support for the audit from top-level management, and for the
implementation of results; otherwise there will be no real action.
The waste audit team should be identified. The number of people required on an audit team will
depend on the size and complexity of the processes to be investigated. A waste audit of a small
factory may be undertaken by one person with contributions from the employees. A more compli-
cated process may require at least 3 or 4 people: technical staff, production employees and an
environmental specialist. Involving personnel from each stage of the manufacturing operations
will increase employee awareness of waste reduction and promote input and support for the
A waste audit wiO probably require external resources, such as laboratory analytical facilities and
possibly equipment for sampling and flow measurements. You should attempt to identify external
resource requirements at the outset of the project.
Analytical services and equipment may not be available to a small factory. If this is the case,
investigate the possibility of forming a waste auditing association with other factories or indus-
tries; under this umbrella the external resource costs can be shared.

Phase 1: Preassessment
It is important to select the focus of your audit at the preparation stage. You may wish the waste
audit to cover a complete process or you may want to concentrate on a selection of unit opera-
tions within a process. The focus will depend on the objectives of the waste audit. You
may wish to look at waste minimisation as a whole or you may wish to concentrate on particular
wastes, for example:
•	raw material losses;
•	wastes that cause processing problems;
•	wastes considered to be hazardous or for which regulations exist;
•	wastes for which disposal costs are high.
A good starting point for designing a waste audit is to determine the major problems/wastes
associated with your particular process or industrial sector. The Rapid Assessment of Sources of
Air, Water and Land Pollution published by the World Health Organisation (WHO, 1982) is
a useful reference for identifying the type and typical quantities of wastes associated with particu-
lar industries. For example, Table 1 describes the likely waste quantities for the tanning industry.
Table 1: Manufacture of Leather and Products of Leather, Leather Substitutes and Fur,
except Footwear and Wearing Apparel

Pulp hair/
Save hair/
Save hair/

chrome tanning/
chrome tanning/
vegetable tanning

Waste volume
(m3^ of hides)
(kgA of hides)
(kgA of hides)
Suspended Solids
(kgA of hides)
Total Solids
(kgA of hides)
Total Chromium
(kgA of hides)
(kgA of hides)
Oil and Grease
(kgA of hides)
Total N
(kgA of hides)

(Source: WHO. 1982)
All existing documentation and information regarding the process, the plant or the regional
industrial sector should be collated and reviewed as a preliminary step. Regional or plant surveys
may have been undertaken; these could yield useful information indicating the areas for concern
and will also show gaps where no data are available. The following prompts give some guidelines
on useful documentation.
•	Is a site plan available?
•	Are any process flow diagrams available?
•	Have the process wastes ever been monitored - do you have access to the records?
•	Do you have a map of the surrounding area indicating watercourses, hydrology and human
•	Are there any other factories/plants in the area which may have similar processes?

Phase 1: Praassassmant
Other general data which can be collated quickly and which are useful orientation material are
described below.
•	What are the obvious wastes associated with your process?
•	Where is water used in greatest volume?
•	Do you use chemicals that have special instructions for their use and handling?
•	Do you have waste treatment and disposal costs • what are they?
•	Where are your discharge points for liquid, solid and gaseous emissions?
The plant employees should be informed that the audit will be taking place, and they should be
encouraged to take part. The support of the staff is imperative for this type of interactive study.
It is important to undertake the audit during normal working hours so that the employees and
operators can be consulted, the equipment can be observed in operation and, most importantly,
wastes can be quantified.
Step 2: Listing Unit Operations
Your process will comprise a number of unit operations. A unit operation may be defined as an
area of the process or a piece of equipment where materials are input, a function occurs and
materials are output, possibly in a different form, state or composition. For example, a process
may comprise the following unit operations: raw material storage, surface treatment of compo-
nents, rinsing, painting, drying, product storage and waste treatment.
An initial site survey should include a walk around the entire manufacturing plant in order to gain
a sound understanding of all the processing operations and their interrelationships. This will help
the audit team decide how to describe a process in terms of unit operations. During this initial
overview, it is useful to record visual observations and discussions and to make sketches of pro-
cess layout, drainage systems, vents, plumbing and other material transfer areas. These help to
ensure that important factors are not overlooked.
The audit team should consult the production staff regarding normal operating conditions. The
production or plant staff are likely to know about waste discharge points, unplanned waste
generating operations such as spills and washouts, and can give the auditors a good indication of
actual operating procedures. Investigations may reveal that night-shift procedures are different
from day-shift procedures; also, a plant tour may disclose that actual material handling practices
are different from those set out in written procedures.
A long-standing employee could give some insight into recurring process problems. In the
absence of any historical monitoring this information can be very useful. Such employee partici-
pation must however be a non-blaming process; otherwise it will not be as useful as it could be.

Phase 1: PreuMSsment
During the initial survey, note imminent problems that need to be addressed before the audit is
The waste audit team needs to understand the function and process variables associated with
each unit operation. Similarly, all the available information on the unit operations and the
process in general should be collated, possibly in separate files. It is useful to tabulate this
information, as~shown in Table 2.
Table 2: Identification of Unit Operations
Unit Operation
file Number
(A) Surface Treatment
Surface treatment of metal products
10 m3 spray chamber, 6 lets, 100 l/min pump

(B) Rinsing
Washing metal products before painting
Identification of materials handling operations (manual, automatic, bulk, drums etc) covering raw
materials, transfer practices and products is also an important aspect which could usefully be
included in the above tabulation as a prelude to development of a materials balance (Phase 2).
Step 3: Constructing Process How Diagrams
By connecting the individual unit operations in the form of a block H«»gra«n you can prepare a
process flow diagram. Intermittent operations such as cleaning, make-up or tank dumping may
be distinguished by using broken lines to Hnk the boxes. Figure 1 is an example of a simplified
process flow diagram for a metal finishing process.

Phase 1: Preassaasment
Figure 1: A Process Row Disgram for a Metal Finishing Process
C Waning Fluid
Wait* Palnt/Claanlng
Fluid Dlfposal
Cham leal
For complex processes prepare a general flow diagram illustrating the main process areas and, on
separate sheets of paper, prepare detailed flow diagrams for each main processing area. The
printed circuit board manufacture case study in Chapter 3 shows how this can be done (Case
Study 3).
Now you must decide on the level of detail that you require to achieve your objectives.
It is important to realise that the less detailed or larger scale the audit becomes, the more infor-
mation is likely to be lost or masked by oversimplification. Establishing the correct level of
and homing in on specific areas is very important at an early stage.
Pay particular attention to correcting any obvious waste arisings which can be reduced or pre-
vented easily, before proceeding to the development of a material balance (Phase 2). By making
simple changes at this early stage, the resultant benefits will help enlist the participation and
stimulate the enthusiasm of employees for the total waste audit/reduction programme.

Phase 1: Praassassment
Phase 1 Summary
At the end of the waste audit preassessment stage the audit team should be organised and
be aware of the objectives of the waste audit.
Plant personnel should have been informed of the audit purpose in order to maximise co-
operation between all parties concerned.
Any required Financial resources should have been secured and external facilities checked
out for availability and capability.
The team should be aware of the overall history and local surroundings of the plant.
The scope and focus of the waste audit should have been established, and a rough
timetable worked out to fit in with production patterns.
The audit team should be familiar with the layout of the processes within the plant and
should have listed the unit operations associated with each process. Sources of wastes and
their causes should also have been identified.
It should be possible to draw process flow diagrams highlighting those areas to be covered
in the waste audit.
Any very obvious waste saving measures which can be introduced easily should be imple-
mented immediately.
The findings of the Phase 1 investigations could usefully be presented to the management
in the form of a brief.preassessment report in order to reaffirm their commitment into the
next phase.

A material balance may be defined as a precise account of the inputs and outputs of an opera-
This phase describes a procedure for the collection and arrangement of input and output data.
The procedure can be applied to derive the material balance of a plant, a process or a unit
operation. Figure 2 is an example of a set of components that need to be quantified to derive a
material balance. Note that infrequent outputs (eg the occasional dumping of an electroplating
bath) may be as significant as continous daily discharges.
Figure 2: Typical Components of a Material Balance
The manual uses unit operations to illustrate the waste audit procedure.
Although the procedure is laid down in a step-by-step fashion it should be emphasised that the
output information can be collected at the same time or before the input data; it is up to you to
organise your time efficiently.
Step 4: Determining Inputs
Inputs to a process or a unit operation may include raw materials, chemicals, water, air and
power (Figure 2). The inputs to the process and to each unit operation need to be quantified.
As a first step towards quantifying raw material usage, examine purchasing records; this rapidly
gives you an idea of the sort of quantities involved.

Phase 2: Materia! Balance: Process Inputs and Outputs
In many situations the unit operations where raw material losses are greatest are raw material
storage and transfer. You should look at these operations in conjunction with the purchasing
records to determine the actual net input to the process.
Make notes regarding raw material storage and handling practices. Consider evaporation losses,
spillages, leaks from underground storage tanks, vapour losses through storage tank pressure-
relief vents and contamination of raw materials. Often these can be rectified very simply.
Record raw material purchases and storage and handling losses in a table in order to derive the
net input to the process (Table 3).
Table 3: Raw Material Storage and Handling Losses
Raw Material
Raw Material
(per annum)
Type of
Used in
(per annum)
of Storage
Annual Raw
Material Losses
Material 1	100kg	95kg	Dosed 1 month	5kg
Material 2
Material 3
Once the net input of raw materials to your process has been determined you should proceed
with quantifying the raw material input to each unit operation.
If accurate information about raw material consumption rates for individual unit operations is not
available then you will need to take measurements to determine average figures. Measurements
should be taken for an appropriate length of time. For example, if a batch takes one week to run,
then measurements should be taken over a period of at least three weeks; these figures can be
extrapolated for monthly or annual figures.
Some quantification is possible by observation and some simple accounting procedures.
•	For solid raw materials, ask the warehouse operator how many sacks are stored at the
beginning of the week or prior to a unit operation; then ask him again at the end of the week
or unit operation. Weigh a selection of sacks to check compliance with specifications.
•	For liquid raw materials such as water or solvents, check storage tank capacities and ask
operators when a tank was last filled. Tank volumes can be estimated from the tank diameter
and tank depth. Monitor the tank levels and the number of tankers arriving on site.

Phass 2: Material Balanoa: Process Inputs and Outputs
While investigating the inputs, talking to staff and observing the unit operations in action, the
waste audit team should be thinking about how to improve the efficiency of unit operations.
Consider the following questions.
•	Is the size of the raw material inventory appropriate to ensure that material-handling losses
can be minimised?
•	Transfer Hictancp* between storage and process or between unit operations - could these be
reduced to minimise potential wastage?
•	Do the same store different raw materials depending on the batch product? Is there a
risk of cross-contamination?
•	Are sacks of materials fully emptied or is some material wasted?
•	Are viscous raw materials used on site - is it possible to reduce residual wastage in drums?
•	Is the raw material storage area secure? Could a buOding be locked at night, or could an area
be fenced off to restrict access?
•	How could the raw materials be protected from direct sunlight or from heavy downpours?
•	Is dust from stockpiles a problem?
•	Is the equipment used to pump or transfer materials working efficiently? Is it maintained
•	Could spillages be avoided?
•	Is the process adequately manned?
•	How could the input of raw materials be monitored?
•	Are there any obvious equipment items in need of repair?
•	Are pipelines self-draining?
•	Is vacuum pump water recirculated?
The energy input to a unit operation should be considered at this stage; however, energy use
deserves a full audit in its own right. For waste auditing purposes make a note of the energy
source and whether waste reduction could reduce energy costs. If energy usage is a particularly
prominent factor maybe you should recommend that an energy audit be undertaken.
Input data should be recorded on your process flow diagram or in tabular form as shown in
Table 4.
Water is frequently used in the production process, for cooling, gas scrubbing, washouts, product
rinsing and steam cleaning. This water usage needs to be quantified as an input.
Some unit operations may receive recycled wastes from other unit operations. These also repre-
sent an input
Steps 5 and 6 describe how these two factors should be included in your waste audit.

Phase 2: Material Balance: Process Inputs and Outputs
Table 4: Input Data
Unit Operation
Raw Material 1
Raw Material 2
Energy Source


Treatment (A)

Rinse (B)
Painting (C)
Total Raw Material

Used in All Unit


Step 5: Recording Water Usage
The use of water, other than for a process reaction, is a factor that should be covered in ail waste
audits. The use of water to wash, rinse and cool is often overlooked, although it represents an
area where waste reductions can frequently be achieved simply and cheaply.
Consider these general points about the site water supply before assessing the water usage for
individual unite.
•	Identify water sources? Is water abstracted directly from a borehole, river or reservoir; is
water stored on site in tanks or in a lagoon?
•	What is the storage capacity for water on site?
•	How is water transferred - by pump, by gravity, manually?
•	Is rainfall a significant factor on site?
For each unit operation consider the following.
•	What is water used for in each operation? Cooling, gas scrubbing, washing, product rinsing,
dampening stockpiles, general maintenance, safety quench etc.
•	How often does each action take place?
•	How much water is used for each action?
It is unlikely that the answers to these questions will be readily available • you will need to under-
take a monitoring programme to assess the use of water in each unit operation. Again, the
measurements must cover a sufficient period of time to ensure that all actions are monitored. Pay
particular attention to intermittent actions such as steam cleaning and tank washouts; water use is
often indiscriminate during these operations. Find out when these actions will be undertaken so
that detailed measurements can be made.

Phase 2: Material Balance: Process Inputs and Outputs
Record water usage information in a tabular form • ensure that the units used to describe inter-
mittent actions indicate a time period (Table 5).
Table 5: Water Usage
Cleaning	Steam	Cooling	Other
Unit Operation A
Unit Operation B
Unit Operation C
All measurements in standard units, for example nrrtyannum or m3/day.
I king less water can be a cost-saving exercise. Consider the following points while investigating
water use:
•	tighter control of water use can reduce the volume of wastewater requiring treatment and
result in cost savings - in the extreme, it can sometimes reduce volumes and increase concen-
trations to the point of providing economic material recovery in place of costly wastewater
•	attention to good house-keeping practices often reduces water usage and, in turn, the
amount of wastewater passing to drain;
•	the cost of storing wastewater for subsequent reuse may be far less than the treatment and
disposal costs;
•	counter-current rinsing and rinsewater reuse are highlighted in the case studies as useful tips
for reducing water usage.
Step 6: Measuring Current Levels of Waste Reuse/Recycling
Some wastes lend themselves to direct reuse in production and may be transferred from one unit
to another (eg reuse of the final rinse in a soft-drink bottle washing plant as the initial rinse);
others require some modification before they are suitable for reuse in a process. These reused
waste streams should be quantified.
If reused wastes are not properly documented double-counting may occur in the material balance
particularly at the process or complete plant level; that is, a waste will be quantified as an output
from one process and as an input to another.
The reuse or recycling of wastes can reduce the amount of fresh water and raw materials required
for a process. While looking at the inputs to unit operations think about the opportunities for
reusing and recycling outputs from other operations.

Phase 2: Material Balanoa: Process Inputs and Outputs
Steps 4,5 and 6 Summary
By the end of Step 6 you should have quantified all your process inputs.
The net input of raw materials and water to the process should be established having
taken into account any losses incurred at the storage and transfer stages.
Any reused or recycled inputs should be documented.
All notes regarding raw material handling, process layout, water losses, obvious areas
where problems exist should all be documented for consideration in Phase 3.
Step 7: Quantifying Process Outputs
To calculate the second half of the material balance the outputs from unit operations and the
process as a whole need to be quantified.
Outputs include primary product, by-products, wastewater, gaseous wastes (emissions to atmos-
phere), liquid and solid wastes which need to be stored and/or sent off-site for disposal and
reusable or recyclable wastes (Figure 2). You may find that a table along the lines of Table 6 will
help you organise the output information. It is important to identify units of measurement
Table 6: Process Outputs
UnK Operation Product By-Product Waste
to be
Wastewater Gaseous Stored Liquid/
Emission* Wastes Solid
Untt Operation A
Unit Operation B
Unit Operation C
The assessment of the amount of primary product or useful product is a key factor in process or
unit operation efficiency.
If the product is sent off-site for sale, then the amount produced is likely to be documented in
company records. However, if the product is an intermediate to be input to another process or
unit operation then the output may not be so easy to quantify. Production rates will have to be
measured over a period of time. Similarly, the quantification of any by-products may require

Phase 2: Malarial Balance: Prooosa Inputs and Outputs
Hints on how to approach the quantification of wastewater, gaseous emissions and wastes for off-
site removal are described in Steps 8,9 and 10.
Step 8: Accounting for Wastewater
On many sites significant quantities of both clean and contaminated water are discharged to
sewer or to a watercourse. In many cases, this wastewater has environmental implications and
incurs treatment costs. In addition, wastewater may wash out valuable unused raw materials from
the process areas.
Therefore, it is extremely important to know how much wastewater is going down the drain and
what the wastewater contains. The wastewater flows, from each unit operation as well as from the
process as a whole, need to be quantified, sampled and analysed.
Here are some suggestions on how to carry out a thorough survey of wastewater flows on your
•	Identify the effluent discharge points; that is, where does wastewater leave the site? Waste-
water may go to an effluent treatment plant or directly to a public sewer or watercourse. One
factor that is often overlooked is the use of several discharge points - it is important to identify
the location, type and size of all discharge flows.
•	Identify where flows from different unit operations or process areas contribute to the overall
flow. In this way, it is possible to piece together the drainage network for your site. This can
lead to startling discoveries of what goes where!
•	Once the drainage system is understood it is possible to design an appropriate sampling and
flow measurement programme to monitor the wastewater flows and strengths from each unit
•	Plan your monitoring programme thoroughly and try to take samples over a range of operating
conditions such as full production, start up, shut down and washing out. In the case of com-
bined storm water and wastewater drainage systems, ensure that sampling and flow measure-
ments are carried out in dry weather.
•	For small or batch wastewater flows it may be physically possible to collect all the flow for
measurement using a pail and wristwatch. Larger or continuous wastewater flows can be
assessed using flow measurement techniques. A method using a simple triangular notch (V-
notch) or rectangular weir arrangement is outlined in Appendix 1.
The sum of the wastewater generated from each unit operation should be approximately the same
as that input to the process. As indicated in Step 6, note that double-counting can occur where

Phase 2: Material Balance: Process Inputs and Outputs
wastewater is reused. This emphasises the importance of understanding your unit operations and
their interrelationships.
The wastewater should be analysed to determine the concentration of contaminants.
e You should include wastewater analyses such as pH, chemical oxygen demand (COD),
biochemical oxygen demand (BODs), suspended solids and grease and oil.
e Other parameters that should be measured depend on the raw material inputs. For example,
an electroplating process is likely to use nickel and chromium. The metal concentrations of the
wastewater should be measured to ensure that the concentrations do not exceed discharge
regulations, but also to ensure that raw materials are not being lost to drain. Any toxic sub-
stances used in the process should be measured.
e Take samples for laboratory analysis. Composite samples should be taken for continuously-
running wastewater. For example, a small volume, 100 ml, may be collected every hour
through a production period of ten hours to gain a 1 litre composite sample. The composite
sample represents the average wastewater conditions over that time. Where significant flow
variations occur during the discharge period, consideration should be given to varying the size
of individual samples in proportion to flow rate in order to ensure that a representative
composite sample is obtained. For batch tanks and periodic draindown, a single spot sample
may be adequate (check for variations between batches before deciding on the appropriate
sampling method).
Wastewater flows and concentrations should be tabulated (Table 7).
Table 7: Wastewater Flows

Discharge to

Total Waste-
water Output
Source of
Row Conc'n
Row Conc'n
Row Conc'n
Row Conc'n
Row Conc'n
Unit Operation A
Unit Operation B
Unit Operation C
Rows in m3/d; concentrations of contaminants of concern in mg/l

Phase 2: Material Balance: Process Inputs and Outputs
Step 9: Accounting for Gaseous Emissions
To arrive at an accurate material balance some quantification of gaseous emissions associated
with your process is necessary.
It is important to consider the actual and potential gaseous emissions associated with each unit
operation from raw material storage through to product storage.
Gaseous emissions are not always obvious and can be difficult to measure. Appendix 1 outlines a
possible method of measuring gaseous emissions through vents using a bag orifice. Where
quantification is impossible, estimations can be made using stoichiometric information. The
following example illustrates the use of indirect estimation.
Consider coal burning in a boiler house. The auditor may not be able to measure the mass of
sulphur dioxide leaving the boiler stack due to problems of access and lack of suitable sampling
ports on the stack. The only information available is that the coal is of soft quality containing 3%
sulphur by weight and, on average, 1000 kg of coal is burnt each day.
First calculate the amount of sulphur burned:
1000 kg coal x 0.03 kg sulphur/kg coal = 30 kg sulphur/day.
The combustion reaction is approximately:
S + o2 = so2
The number of moles of sulphur burned equals the number of moles of sulphur dioxide produced.
The atomic weight of sulphur is 32 and the molecular weight of sulphur dioxide is 64. Therefore:
kg-moles S = 30 kg/32 kg per kg-molc = kg-mole of S02 formed
kg S02 formed = (64 kg S02/kg-mole) x kg-moles SOz = 64 x 30/32 = 60 kg
Thus, it may be estimated that an emission of 60 kg sulphur dioxide will take place each day from
the boiler stack.
Record the quantified emission data in tabular form and indicate which figures are estimates and
which are actual measurements.
The waste auditor should consider qualitative characteristics at the same time as quantifying
gaseous wastes.
• Are odours associated with a unit operation?

Phase 2: Material Balance: Process Inputs and Outputs
•	Are there certain times when gaseous emissions are more prominent • are they linked to
•	Is any pollution control equipment in place?
•	Are gaseous emissions from confined spaces (including fugitive emissions) vented to the
•	If gas scrubbing is practised, what is done with the spent scrubber solution? Could it be
converted to a useful product?
•	Do employees wear protective clothing, such as masks?
Step 10: Accounting for Off-Site Wastes
Your process may produce wastes which cannot be treated on-site. These need to be transported
off-site for treatment and disposal Wastes of this type are usually non-aqueous liquids, sludges
or solids.
Often, wastes for off-site disposal are costly to transport and to treat. Therefore, minimisation of
these wastes yields a direct cost benefit.
Measure the quantity and note the composition of any wastes associated with your process which
need to be sent for off-site disposal. Record your results in a tabic (see Table 8).
Table 8: Wattes for Off-site Disposal
Liquid	Sludge	Solid
Unit Operation	Qty Composition	Qty Composition	Qty Composition
Unit Operation A
Unit Operation B
Unit Operation C
Quantities in m3/anmim or t/annum
You should ask several questions during the data collection stage.
•	Where does the waste originate?
•	Could the manufacturing operations be optimised to produce less waste?
•	Could alternative raw materials be used which would produce less waste?
•	Is there a particular component that renders the whole waste hazardous - could this compo-
nent be isolated?
•	Does the waste contain valuable materials?
Wastes for off-site disposal need to be stored on-site prior to dispatch. Does storage of these
wastes cause additional emission problems? For example, are solvent wastes stored in closed
tanks? How long are wastes stored on-site? Are stockpiles of solid waste secure or are dust
storms a regular occurrence?

Phase 2: Material Balance: Prooess Inputs and Outputs
Steps 7,8,9 and 10 Summary
At the end of Step 10 the waste audit team should have collated all the information re-
quired for evaluating a material balance for each unit operation and for a whole process.
All actual and potential wastes should be quantified. Where direct measurement is impos-
sible, estimates based on stoichiometric information should be made.
The data should be arranged in clear tables with standardised units. Throughout the data
collection phase the auditors should make notes regarding actions, procedures and
operations that could be improved.
Step 11: Assembling Input and Output Information for Unit Operations
One of the basic laws applied to chemical engineering is that of the material balance which states
that the total of what goes into a process must equal the total of what comes out. Prepare a
material balance at a scale appropriate for the level of detail required in your study. For example,
you may require a material balance for each unit operation or one for a whole process may be
sufficient. In this manual the preparation of a material balance for the unit operation scale is
Preparing a material balance is designed to gain a better understanding of the inputs and outputs,
especially waste, of a unit operation such that areas where information is inaccurate or lacking
can be identified. Imbalances require further investigation. Do not expect a perfect balance •
your initial balance should be considered as a rough assessment to be refined and improved.
Assemble the input and output information for each unit operation and then decide whether all
the inputs and outputs need to be included in the material balance. For example, this is not
essential where the cooling water input to a unit operation equals the cooling water output.
Standardise units of measurement (litres, tonnes or kilogrammes) on a per day, per year or per
batch basis.
Summarise the measured values in standard units by reference to your process flow Hiagram it
may have been necessary to modify your process flow diagram following the in-depth study of the

Phase 2: Material Balance: Process Inputs and Outputs
Step 12: Deriving a Preliminary Material Balance for Unit Operations
Now it is possible to complete a preliminary material balance. For each unit operation utilise the
data developed in Steps 1 • 10 and construct your material balance. Display your information
clearly. Figure 3 is one way of presenting the material balance information.
Figure 3: Preliminary Material Balance lor Each Unit Operation
Inputs (amounts in atari
dard units per annum)
Raw Materia] 1

Raw Material 2

Raw Material 3

Waste Reuse



Outputs (amounts in standard units per annum)
Raw MatartaJ Storage and Handling Losaes
^ 		-* lif- —|
nBUMQ warns
Gaseous Emissions
Stored Wastes
Hazardous Liquid Waste Transported Off-Site
Hazardous Solid Waste Transported OH-Site
Non-Hazardous liquid Waste Transported Off-SHa
Non-Hazardous Solid Waste Transported Off-Site
Note that a material balance wQl often need to be carried out in weight units since volumes are
not always conserved. Where volume measurements have to be converted to weight units, take
account of the density of the Squid, gas or solid concerned.
Once the material balance for each unit operation has been completed for raw material inputs
and waste outputs it might be worthwhile repeating the procedure with respect to each contami-
nant of concern. It is highly desirable to carry out a water balance for all water inputs and
outputs to and from unit operations because water imbalances may indicate serious underlying
process problems such as leaks or spills. The individual material balances may be summed to give
a balance for the whole process, a production area or factory.
Step 13: Evaluating the Material Balance
The individual and sum totals	up the material balance should be reviewed to determine
information gaps and inaccuracies. If you do have a significant material imbalance then further
investigation is needed. For example, if outputs are less than inputs look for potential losses or

Phase 2: Material Balance: Prooess Inputs and Outputs
waste discharges (such as evaporation). Outputs may appear to be greater than inputs if large
measurement or estimating errors are made or some inputs have been overlooked.
At this stage you should take time to re-examine the unit operations to attempt to identify where
unnoticed losses may be occurring. It may be necessary to repeat some data collection activities.
Remember that you need to be thorough and consistent to obtain a satisfactory material balance.
The material balance not only reflects the adequacy of your data collection, but by its very nature,
ensures that you have a sound understanding of the processes involved.
Step 14: Refining the Material Balance
Now you can reconsider the material balance equation by adding those additional factors identic
fied in the previous step. If necessary, estimates of unaccountable losses will have to be calcu-
Note that, in the case of relatively simple manufacturing plants, preparation of a preliminary
material balance and its refinement (Steps 13 and 14) can usefully be combined. For more
complex waste audits however, two separate steps are likely to be more appropriate.
Remember, the inputs should ideally equal the outputs but in practice this will rarely be the case
and some judgement will be required to determine what level of accuracy is acceptable.
In the case of high-strength or hazardous wastes, accurate measurements are needed to design
waste reduction options.
It is possible that the material balance for a number of unit operations will need to be repeated.
Again, continue to review, refine and, where necessary, expand your database. The compilation
of accurate and comprehensive data is essential for a successful waste audit and subsequent waste
reduction action plan. You cannot reduce what you do not know is there.
Steps 11,12,13 and 14 Summary
By the end of Step 14, you should have assembled information covering process inputs and
process outputs. These data should be organised and presented clearly in the form of
material balances for each unit operation.
These data form the basis for the development of an action plan for waste minimisation.

Phases 1 and 2 have covered planning and undertaking a waste audit, resulting in the preparation
of a material balance for each unit operation.
Phase 3 represents the interpretation of the material balance to identify process areas or compo-
nents of concern.
The material balance focuses the attention of the auditor. The arrangement of the input and
output data in the form of a material balance facilitates your understanding of how materials flow
through a production process.
To interpret a material balance it is necessary to have an understanding of normal operating
performance. How can you assess whether a unit operation is working efficiently if you do not
know what is normal? A member of your team must have a good working knowledge of the
process. This knowledge can be supported by texts such as the Rapid Assessment of Sources of
Air, Land and Water Pollution (WHO, 1982).
To a trained eye the material balance will indicate areas for concern and help to prioritise
problem wastes.
You should use the material balance to identify the major sources of waste, to look for deviations
from the norm in terms of waste production, to identify areas of unexplained losses and to pin-
point operations which contribute to flows that exceed national or site discharge regulations.
Process efficiency is synonymous with waste minimisation.
Different waste reduction measures require varying degrees of effort, time and financial re-
sources. They can be categorised as two groups.
•	Obvious waste reduction measures, including improvements in management techniques and
house-keeping procedures that can be implemented cheaply and quickly.
•	Long-term reduction measures involving process modifications or process substitutions to
eliminate problem wastes.
Increased reuse/recycling to reduce waste falls between the immediate and the more substantial
waste reduction measures.
Steps 15,16 and 17 describe how to identify waste reduction measures.

Phase 3: Synthesis
Step 15: Examining Obvious Waste Reduction Measures
It may have been possible to implement very obvious waste reduction measures already, before
embarking on obtaining a material balance (ref Step 3). Now consider the material balance
information in conjunction with visual observations made during the whole of the data collection
period in order to pinpoint areas or operations where simple adjustments in procedure could
greatly improve the efficiency of the process by reducing unnecessary losses.
Use the information gathered for each unit operation to develop better operating practices for all
Significant waste reductions can often be achieved by improved operation, better handling and
generally taking more care. The following list of waste reduction hints can be implemented
immediately with no or only small extra costs.
Specifying and Ordering Materials
•	Do not over-order materials especially if the raw materials or components can spoil or are
difficult to store.
•	Try to purchase raw materials in a form which is easy to handle, for example, pellets instead of
•	It is often more efficient and certainly cheaper to buy in bulk.
Receiving Materials
•	Demand quality control from suppliers by refusing damaged, leaking or unlabelled containers.
Undertake a visual inspection of all materials coming on to the site.
•	Check that a sack weighs what it should weigh and that the volume ordered is the volume
•	Check that composition and quality are correct
Material Storage
•	Install high-level control on bulk tanks to avoid overflows.
•	Bund tanks to contain spillages.
•	Use tanks that can be pitched and elevated, with rounded edges for ease of draining and
•	Dedicated tanks, receiving only one type of material, do not need to be washed out as often
as tanks receiving a range of materials.
•	Make sure that drums are stored in a stable arrangement to avoid H«n»ging drums while in
•	Implement a tank checking procedure • dip tanks regularly and document to avoid discharging
a material into the wrong tank.
•	Evaporation losses are reduced by using covered or closed tanks.

Phase 3: Synthesis
Material and Water Transfer and Handling
•	Minimise the number of times materials are moved on site.
•	Check transfer lines for spills and leaks.
•	Is flexible pipework too long?
-• Catch drainings from transfer hoses.
•	Plug leaks and fit flow restrictors to reduce excess water consumption.
Process Control
•	Feedback on how waste reduction is improving the process motivates the operators - it is vital
that the employees are informed of why actions are taken and what it is hoped they will
•	Design a monitoring programme to check the emissions and wastes from each unit operation.
•	Regular maintenance of all equipment will help to reduce fugitive process losses.
Cleaning Procedures
•	Minimise the amount of water used to wash out and rinse vessels • on many sites indis-
criminate water use contributes a large amount to wastewater flows. Ensure that hoses are
not left running by fitting self-sealing valves.
•	Investigate how washing water can be contained and used again before discharge to drain.
The same applies to solvents used to clean; these can often be used more than once.
Tightening up house-keeping procedures can reduce waste considerably. Simple, quick adjust-
ments should be made to your process to achieve a rapid improvement in process efficiency.
Where such obvious reduction measures do not however solve the entire waste disposal problem,
more detailed consideration of waste reduction options will needed (Steps 16 • 18).
Step 16: Targettlng and Characterizing Problem Wastes
Use the material balance for each unit operation to pinpoint the problem areas associated with
your process.
The material balance exercise may have brought to light the origin of wastes with high treatment
costs or may indicate which wastes are causing process problems in which operations. The
material balance should be used to focus your priorities for long-term waste reduction.
At this stage, it may be worthwhile considering the underlying causes as to why wastes are gener-
ated and the factors which lead to these; for example, poor technology, lack of maintenance and
non-compliance with company procedures.

Phase 3: Synthesis
Additional sampling and characterization of your wastes might be necessary involving more in-
depth analysis to ascertain the exact concentrations of contaminants.
List the wastes in order of priority for reduction actions.
Step 17: Segregation
Segregation per se is arguably not properly part of a waste audit's step-by-step sequence, being
but one of numerous measures which can lead to waste reduction activities. It is however the
most central of such options and is a universal issue which needs to be addressed.
Segregation of wastes can offer enhanced opportunities for recycling and reuse with resultant
savings in raw material costs. Concentrated simple wastes are more likely to be of value than
dilute or complex wastes.
Mixing wastes can enhance pollution problems. If a highly-concentrated waste is mixed with a
large quantity of weak, relatively uncontaminated effluent the result is a larger volume of waste
requiring treatment. Isolating the concentrated waste from the weaker waste can reduce
treatment costs. The concentrated waste could be recycled/reused or may require physical,
chemical and biological treatment to comply with discharge consent levels whereas the weaker
effluent could be reused or may only require settlement before discharge.
Therefore, waste segregation can provide more scope for recycling and reuse while at the same
time reducing treatment costs.
Review your waste collection and storage facilities to determine if waste segregation is possible.
Adjust your list of priority wastes accordingly.
Step 18: Developing Long-Term Waste Reduction Options
Waste problems that cannot be solved by simple procedural adjustments or improvements in
house-keeping practices will require more substantial long-term changes.
It is necessary to develop possible prevention options for the waste problems.
Process or production changes which may increase production efficiency and reduce waste
generation include:
•	changes in the production process • continuous versus batch;
•	equipment and installation changes;
•	changes in process control - automation;

Phase 3: Synthesis
•	changes in process conditions such as retention times, temperatures, agitation, pressure,
•	use of dispersants in place of organic solvents where appropriate;
•	reduction in the quantity or type of raw materials used in production;
•	raw material substitution through the use of wastes as raw materials or the use of different
raw materials that produce less waste or less hazardous waste;
•	process substitution with cleaner technology.
Waste reuse can often be implemented if materials of sufficient purity can be concentrated or
purified. Technologies such as reverse osmosis, ultrafiltration, electrodialysis, distillation, electro-
lysis and ion exchange may enable materials to be reused and reduce or eliminate the need for
waste treatment.
Where waste treatment is necessary, a variety of technologies should be considered. These
include physical, chemical and biological treatment processes. In some cases the treatment
method can also recover valuable materials for reuse. Another industry or factory may be able to
use or treat a waste that you cannot treat on-site. It may be worth investigating the possibility of
setting up a waste exchange bureau as a structure for sharing waste treatment and reuse facilities.
The Resource Section (Chapter 4) cites sources of technical information relating to recovery,
reuse, waste treatment and associated technologies.
Consider also the possibilities for product improvements or changes yielding cleaner, more
environmentally-friendly products, both for existing products and in the development of new
Steps 15,16,17 and 18 Summary
At the end of Step 18 you should have identified all the waste reduction options which
could be implemented.
Step 19: Environmental and Economic Evaluation of Waste Reduction
In order to decide which options should be developed to formulate a waste reduction action plan
each option should be considered in terms of environmental and economic benefits.
a) Envrionmental Evaluation
It is often taken for granted that reduction of a waste will have environmental benefits. This is
generally true; however, there are exceptions to the rule. For example, reducing one waste

Phase 3: Synthesis
may give rise to pH imbalances or may produce another which is more difficult to treat,
resulting in a net environmental disadvantage.
In many cases, the benefits may be obvious such as the removal of a toxic element from an
aqueous effluent by segregating the polluted waste or by changing the process in such a way
that the waste is prevented.
In other cases the environmental benefits may be less tangible. Creating a cleaner, healthier
workplace will increase production efficiency but this may be difficult to quantify.
For each option a series of questions should be asked.
•	Consider the effect of each option on the volume and degree of contamination of process
•	Does a waste reduction option have cross-media effects? For example, does the reduction
of a gaseous waste produce a liquid waste?
•	Does the option change the toxicity, degradability or treatability of the wastes?
•	Does the option use more or less non-renewable resources?
•	Does the option use less energy?
b) Economic Evaluation
A comparative economic analysis of the waste reduction options and the existing situation
should be undertaken. Where benefits or changes cannot be quantified (eg reduction in
future liability, worker health and safety costs) some form of qualitative assessment should be
made; it may be necessary to consult an expert for advice on how to judge a change.
Economic evaluations of waste reduction options should involve a comparison of operating
costs to illustrate where cost savings would be made. For example, a waste reduction measure
that reduces the amount of raw material lost to drain during the process results in reduced
material costs. Raw material substitution or process changes may reduce the amount of solid
waste that has to be transported off-site. Therefore, the transport costs for waste disposal
would be reduced.
In many cases, it is appropriate to compare the waste treatment costs under existing condi-
tions with those associated with the waste reduction option.
The size of treatment plant and the treatment processes required may be altered significantly
by the implementation of waste reduction options. This should be considered in an economic
Calculate the annual operating costs for the existing process including waste treatment and
estimate how these would be altered with the introduction of waste reduction options. Tabu-

Phase 3: Synthesis
late and compare the process and waste treatment operating costs for both the existing and
proposed future waste management options. Table 9 shows the typical cost components. In
addition, if there are any monetary benefits (eg recycled or reused materials or wastes), then
these should be subtracted from the total process or waste treatment costs as appropriate.
Now that you have determined the likely savings in terms of annual process and waste treat-
ment operating costs associated with each option, consider the necessary investment required
to implement each option.
Investment can be assessed by looking at the payback period for each option. Payback period
is the time taken for a project to recover its financial outlay. A more detailed investment
analysis may involve an assessment of the internal rate of return (IRR) and net present value
(NPV) of the investment based on discounted cash flows.
Analysis of investment risk allows you to rank options.
Consider the environmental benefits and the savings in process and waste treatment operating
costs along with the payback period for an investment, to decide which options are viable.
Table 9: Annual Process ami Waste Treatment Operating Costs
Process Operating Costs	Annua] Cost
Raw Material 1
Raw Material 2
Waste Treatment Operating Costs	Annual Cost
Raw Material eg Ume
Raw Material eg Rooculant
«»-»- -
Trade Effluent Discharge Coats
Off-Site Disposal
Other, eg violation, fires

Phase 3: Synthesis
Step 19 Summary
At the end of Step 19 you should be able to list those waste reduction options that are
environmentally and economically viable.
Step 20: Developing and Implementing An Action Plan: Reducing
Wastes and Increasing Production Efficiency
Consider the immediate reduction measures identified in Step 15 along with the long-term waste
reduction measures that have been evaluated in Steps 18 and 19. These measures should form the
basis of the waste reduction action plan. Discuss your findings with members of staff and develop
a workable action plan.
Prepare the ground for the waste reduction action plan. Its implementation should be preceded
by an explanation of the ethos behind undertaking a waste audit: Waste Prevention Makes Sense.
It is necessary to convince those who must work to new procedures that the change in philosophy
from end-of-pipe treatment to waste prevention makes sense and serves to improve efficiency.
Use posters around the site to emphasise the importance of waste reduction to minimi** produc-
tion and waste treatment/disposal costs and, where appropriate, for improving the health and
safety of company personnel
Set out the intended action plan within an appropriate schedule. Remember it may take time for
the staff to feel comfortable with a new way of thinking Therefore, it is a good idea to imple-
ment waste reduction measures slowly but consistently to allow everyone time to adapt to these
Set up a monitoring programme to run alongside the waste reduction action plan so that actual
improvements in process efficiency can be measured. Relay these results back to the workforce
as evidence of the benefits of waste reduction. Adopt an internal record-keeping system for
maintaining and managing data to support material balances and waste reduction assessments.
It is likely that you will have highlighted significant information gaps or inconsistencies during the
waste audit investigations. You should concentrate on these gaps and explore ways of developing
the additional data. Is outside help required?
A good way of providing waste reduction incentives is to set up an internal waste charging system,
those processes that create wastes in great volume or that are difficult and expensive to handle
having to contribute to the treatment costs on a proportional basis. Another method of motivat-

Phase 3: Synthesis
ing staff is to offer financial reward for individual waste-saving efforts, drawing on the savings
gained from implementing waste reduction measures.
Waste auditing should be a regular event - attempt to develop a specific waste audit approach for
your own situation, keeping abreast of technological advances that could lead to waste reduction
and the development of 'cleaner' products. Train process employees to undertake material
balance exercises.
Training people who work on the process to undertake a waste audit will help to raise awareness
in the workforce. Without the support of the operators waste reduction actions will be ineffectual
- these are the people who can really make a difference to process performance.
Step 20 Summary
Prepare the ground for the waste reduction action plan, ensuring that support for the audit,
and implementation of the results, is gained from senior management. Implement the plan
slowly to allow the workforce to adjust.
Monitor process efficiency.
Relay results back to the workforce to show them the direct benefits.
Train personnel to undertake your own waste audit for waste reduction.


Company A operates a modern brewery in western Europe, producing beer in bottles, kegs and
bulk tankers! The essence of beer production is the processing and fermentation of malt and
hops in the presence of added sugar. Considerable volumes of wastewater containing high BOD/
COD and suspended solids (SS) concentrations are produced as a result of washing of vessels and
associated equipment between production batches.
Company A has been in operation some four years. During this time wastewater flows and
pollution loads have increased significantly with production increases, resulting in consent limits
for discharge to the public sewer (pH 6-10 and 500 mg/1 SS) being exceeded on a regular basis.
The regional water authority recently indicated however that the brewery flows could continue to
be accepted into the public sewer without pretreatment other than possibly pH control and flow/
load balancing at some future date, primary settlement and biological treatment being
undertaken at an extended local municipal sewage treatment works.
The water authority also informed Company A that a capital cost contribution towards the
planned sewage works' extensions would not be necessary and that the normal trade effluent
charging system would be applied whereby charges varied according to variations in flow and
pollution loads (COD and SS).
The current trade effluent charges amount to US$332,000 per annum and are expected to
increase by 10% shortly. After considering the likely implications of the increase in effluent
charges, the company decided to appoint a firm of consultants to cany out a waste audit and
waste reduction study to investigate the possible ways of minimising waste disposal costs.
The following case study describes the waste audit/waste reduction procedures carried out
Step 1: Audit Focus and Preparation
Two chemists from the consulting firm's staff were allocated to carry out the required investiga-
tions, assisted as necessary by one of Company A's brewing technologists.
With the support of senior management, the audit team first organised an in-house seminar. This
enabled the study procedures and objectives to be outlined and helped to ensure the full co-
operation of production staff.
With the help of the brewery's engineering staff, a V-notch weir was then installed in a manhole
where all the various effluents combined so that the flow could be monitored continuously using
an available ultrasonic level/flow meter and associated chart recorder.

Case Study 1: Beer Production
Since an automatic sampler was not readily available, it was decided that composite samples
would be taken daily by combining manually-taken samples in proportion to flow. It was also
established that the brewery's laboratory was well-equipped to carry out the required wastewater
In view of the scale of the brewery operations and the time and budget constraints imposed on the
project, it was decided that the study should concentrate on:
•	water usage aspects (rather than attempt to obtain a complete materials balance);
•	investigate methods of reducing COD and SS loads discharging to drain.
In order to put the brewery operations in perspective from a waste management viewpoint, a
preliminary check on wastewater and pollution loads discharged per cubic metre of beer pro-
duced was carried out based on past records of water usage and product data together with some
limited information on combined wastewater strength.
It was concluded that, in general, the brewery operated with a very low degree of water wastage
with most of the useful by-products or wastes already being recycled or recovered for off-site
disposal. These aspects had been considered at an early stage in the design of the brewery and
had clearly paid dividends in reducing waste volumes and pollution loads discharged. Neverthe-
less, it was considered that there was still scope for further waste saving measures to be imple-
The success of the measures already practised can be illustrated as follows:
Table 1: Waste Contributions from Beer Production

Company A


Wastewater Flow (m3/m3 beer)
BOD Load (kg/m3 beer)
(a)	Based on the consulting firm's project experience elsewhere
(b)	Based on data published by WHO, 1982
Another factor in favour of Company A is that most of the beer is transported from the brewery
in road tankers rather than bottles or kegs, both of which give rise to more waste being produced.
This simplifies the brewery operations and makes for more efficient and economical operation
in terms of water consumption.

Case Study 1: Beer Production
Step 2: Listing Unit Operations
The study team started off the waste audit/waste reduction programme by becoming familiar with
all the various production stages. This was done by walking around the plant with the brewery
technologist and collecting relevant information from departmental records. It was found that so
much data were being collected that a file was opened for each key area within the brewery.
The various unit operations were listed as in Table 2.
Table 2: Major Unit Operations and Brief Functional Description
Unit Operation Brief Functional Description	File No.
Brewhouse Processing of matt, hops and sugar to	1
produce 'wort'
Fermentation Fermentation of chilled "wort'	2
Product Treatment Centrttugation, filtration, carbonation,	3
colouring and final polishing and pasteurising
Dispatch Bottling, kegging and bulk tanker filling	4
Step 3: Constructing Process Row Diagrams
A schematic flow diagram was then compiled to illustrate the various unit operations within the
brewery (Figure 1).
Once all the unit operations had been identified and described, the audit team proceeded to
gather data on water usage, wastewater output and waste recovery.

Acomvcs ¦
j WA8H I#.
1 [
X ~

¦*—-r ,
BBB	j[
| WA8H |

Step 4: Determining Inputs
The audit team first proceeded to gather data on material inputs, concentrating on water usage,
both for the brewery process as a whole and for individual unit operations. These activities are
described further in Step 5.
Step 5: Recording Water Usage
The total water consumption from water meter readings for the previous three month period was
found to be 247,500 m3, equivalent to an average 2,750 m3/d.
This included a small domestic water allowance, evaporation make-up and water entering the
beer products as well as general washdown water for equipment for cleaning operations.
The audit team then proceeded to examine how water usage was split between the various unit
Step 6: Measuring Current Levels of Waste Reuse/Recycling
No attempt to quantify the extent of current waste reuse/recycling was made during the waste
audit programme since it was feh that this would have involved a considerable time input dispro-
portionate to the likely benefits obtained.
However, it was noted that reuse of caustic and sterilant rinses following discharge to drain of
initial water rinses generally formed an integral part of the automatic deaning-in-place (CIP)
system employed for equipment washing.
Step 7: Quantifying Process Outputs
The principal process outputs of concern were the wastewater discharges arising from production
operations and also the beer products themselves.
It was also noted that minor domestic sewage contributions discharged to the same drainage
network as the brewery process wastewaters.
The audit team then proceeded to quantify these outputs.

Case Study 1: Beef Production
Step 8: Accounting for Wastewater
The total wastewater flow recorded during a two-week monitoring period averaged 1,730 m3/d. It
was noted, however, from the flow patterns during each day that wastewater discharges were
extremely variable with a peak flow rate of up to 100 m3/h occurring when a hot water tank
overflow was discharged. On the basis of this and a number of other assumptions, the audit team
estimated that the maximum flow on any one day could reach 2,600 m3/d.
The corresponding combined wastewater pollution loads averaged 5,980 kg COD/d and 1,500 kg
SS/d. These figures equated to waste quantities per cubic metre of beer produced of 2.1 m3, 7.1
kg COD and 1.8 kg SS. Assuming an average COD:BOD ratio of 1.7, the corresponding BOD
waste load was 42 kg/m3 beer produced. These unit wastewater flow and BOD load contribu-
tions proved to be similar to the approximate estimates calculated in Step 1.
An estimate of domestic water usage and hence domestic sewage discharges to the trade effluent
drainage system were also made, together with an assessment of the quantity of water entering
the beer products. Calculations indicated that these additional outputs averaged a total of 850
m3/d, of which only 10 m3/d (140 employees at 70 litres per head per day) related to domestic
Studies were then carried out to develop a breakdown of the main process outputs (wastewater
and product) for each key unit operation. This involved sampling and flow measurement of
individual discharges around the brewery. Since the volume and composition of some of these
discharges varied considerably with the type of beer produced, the survey was undertaken over
several weeks to allow a realistic assessment of the situation to be made.
Step 9: Accounting for Gaseous Emissions
Gaseous emissions were not of particular concern in the context of the terms of reference drawn
up by Company A for the study. However, it was noted that the breweiy boilers were gas-fired
and that boiler flue-gas emissions were discharged via a tall stack such that they were not likely
to give rise to any concern.
It was noted that if control of alkaline wastewater discharges associated with use of caustic soda
in the CEP systems proved to be necessary in the future (a possibility if alkaline waste discharges
could not be controlled at source), then use of acidic flue-gas (a source of carbon dioxide) could
be considered for this purpose.
The audit team also observed that pockets of carbon dioxide in the fermentation areas could
cause problems of drowsiness amongst the brewing staff and that improved ventilation would help
to ensure their general health and safety.

Case Study 1: Be«r Production
Step 10: Accounting for Off-Site Wastes
At the time of the survey, wastes produced for transportation and disposal off-site were limited
to spent grain and hops generated in the brewhouse as by-products. These were disposed of off-
site by a local fanner, for cattle food and as a soil conditioner respectively, at no cost to the
brewery. Total quantities were estimated at some 25,000 tonnes (wet weight) per annum.
Step 11: Assembling Input and Output Information for Unit Operations
As previously indicated, the prime interest in this waste audit and reduction programme was to
concentrate on the potential for reducing wastewater and associated pollution loads.
Hence, for the purposes of the project in question, the material balance was confined to consid-
eration of water issues only.
Step 12: Deriving a Preliminary Material Balance for Unit Operations
It was decided to conduct a preliminary material balance for the brewery as a whole, based on
water usage, before embarking on the more complicated step of obtaining a balance for each key
unit operation. This was then constructed as set out in below.

Oman Brewery Operations

Domestic Sewage
'** - 4.11 .1.

Case Study 1: Beer Production
Step 13: Evaluating the Material Balance
The material balance with respect to overall water usage showed a remarkably good agreement,
the average daily water input amounting to 6.6% above the daily water output assessed.
Although raw materials in the form of malt, hops, sugar, additives and other process chemicals •
and also wastes disposed of off-site • had not been included in the balance, it was noted that
these items are relatively small in the case of breweries where water is the dominant raw material
Step 14: Refining the Material Balance
On studying the data collated, it was observed that no allowance for evaporation had been
included in the material balance and that, from the consultant's previous experience of brewery
operations, evaporation alone could account for up to 5% of total water usage. This allowance
therefore effectively closed the small difference between water input and output indicated in
Step 13.
The waste audit team then proceeded to build up material balances for all the major unit opera-
tions within the brewery. When this work had been completed, they fek that they had gained
considerable knowledge about the various production activities, their inputs, outputs, wastes
and operational problems.

Step 15: Examining Obvious Waste Reduction Measures
The audit considered that the cost of wastewater disposal at the brewery could be minimised
in two ways:
•	reduction in volume, BOD* and/or SS load of the wastewater produced in the brewery,
•	reduction in the BOD* and/or SS load of the wastewater discharged to sewer by pretreatment.
(* or rather COD, as used in the water authority's charging formula)
In the light of a comprehensive examination of the waste producing areas, it was possible to study
both these alternatives. To assist the investigations into waste saving possibilities, reference was
made to available information (including database) sources, as well as the consultant's own
experience of undertaking similar projects.
The various sections of the brewhouse were studied in turn as follows.
a) Brewhouse
The two principal discharges in the brewhouse were the drain from the Lautertuns and a 75°C
hot water tank overflow. Together these contributed 12% of the total wastewater flow from
the brewery.
Study of the flow and analytical data obtained indicated that the Lautertun drain contributed
35% of the flow, 23% of the COD and 4% of the SS load. Discussions with the company
indicated that it should be possible to store this waste flow for use as make-up water for the
subsequent brew and that this should be possible without detriment to brewing standards. A
15 m3 stainless-steel storage tank with associated pumps, valves and pipework would need to
be installed with the advantage that the system would:
*	reduce raw water costs;
•	eliminate effluent charges previously incurred by this discharge;
*	reduce energy requirements since the liquor returned as make-up water would not need
•	eliminate existing shock load discharges from this source which should remove any need
for flow/load balancing of the total site wastewater flow.
The hot water tank overflow accounted for nearly 9% of the total wastewater flow. Since this
water was clean and hot, continual reuse was the obvious possibility. Unfortunately this
proved to be impossible owing to the spasmotic production of this water.

Case Study 1: Beer Production
proved to be impossible owing to the spasmotic production of this water.
As the 75°C tank was very large however, it was considered that its inherent balancing capac-
ity could be utilised if the supply for reuse was taken part way down the tank rather than from
the overflow when it occurred.
Reuse of this water would be preferable in a process that consumed hot water at approxi-
mately the same rate as the 75°C hot water production, that is 150 m3/d. The only process in
the brewery which utilised this quantity of hot water was the pasteurising machine which had a
water consumption of some 170 m3/d. However, all of this flow was not hot water since a
temperature gradient had to be maintained within the pasteuriser to ensure that bottles were
not wanned up or cooled down too rapidly.
It was considered that the 75°C hot water should be injected directly into the pasteuriser to
replace the heating of cold water to 60°C. In addition, the hot water could be blended with
the supply of cold water that already existed to give the required temperature profile
thoughout the pasteuriser. It was estimated that such a system would enable at least 75 m3 of
the excess hot-water to be reused each day.
b) Fermentation Cellar
The majority of waste produced in this area of the brewery originated from the CIP systems,
the discharges from which contained a high COD load due principally to the high yeast
content. With the exception of the initial rinse from pre-fermentation stage gauging vessels,
the initial rinses from other tanks • fermentation tanks, storage vessels and yeast recovery
vessels - all exceeded 6,000 mg/1 COD and together accounted for over 90% of the COD load
produced in the fermentation cellar.
Proposals for reducing/treating these discharges were developed as follows.
Gauging Vessels
Possibilities for reducing the pollution load from this source of CIP effluent were limited as no
yeast was present which could be filtered out. However, reuse of the relatively-clean final
rinse as the initial rinse for the next CIP wash would reduce the effluent flow to drain by a
total of 26 m3/d from 8 vessels.
It was also noted that the caustic wash from the brewhouse which occurred usually every week
was discharged to drain from these gauging vessels every weekend and that this, together with
the acid wash from Wort Kettle No2 discharged via a fermentation (balancing) tank, had a
major effect on the combined wastewater pH giving values frequently outside the allowable
pH range for discharge to the public sewer of 6-10.
Tests showed that if the acid and caustic discharges were run to drain together, the neutralis-
ing effect of the acid on the caustic was neglible owing to the different volumes, strengths and

Case Study 1: Beer Production
neutralise the predominant caustic load, it was envisaged that closing up the system by
providing additional holding tank capacity would be suitable. This could be achieved using a
similar arrangement to the existing closed.CIP units in order to standardise on equipment; it
would reduce effluent flows to drain, raw water costs and also chemical-cleaning costs.
Fermentation Tanks
The load produced by the initial rinse was found to be 210 kg COD/d and 150 kg SS/d which
could be reduced by at least 75% by passing the rinse through a yeast press. It was considered
that the final CIP rinse could also be reused as the initial rinse, reducing effluent flow by 25
m3/d from 8 tanks.
As referred to above, acid washes from the brewhouse were being discharged from the
fermentation tanks; on occasions, these depressed the pH to 2.4. Containment and
recirculation via a new CIP unit was considered to be the most suitable and practicable
control measure.
Storage Tanks
The initial rinse in the CIP sequence was found to contain 75 kg COD/d and 10 kg SS/d. It
was estimated that passing these rinses through a yeast press would reduce overall loads from
this source to 22 kg COD/d and 3 kg SS/d. Also, reuse of the final rinse as the initial rinse of
the next sequence would reduce effluent flows by 5 m3/d.
Yeast Recovery Plant
Discharges from centrifuge cleaning were difficult to arrange at the time of the waste audit
and reduction investigations. However, from visual observations the initial rinse clearly
contained a significant quantity of yeast and so it was recommended that such wastes should
also be passed to a yeast filter press. Similarly, recovery of the final rinse and reuse as a
subsequent initial rinse was proposed It was also suggested that the initial rinses from yeast
storage vessels should be filtered through a yeast press.
Company A had already purchased a new yeast press to filter yeast liquors which at the time
were stored until press capacity became available. This proposal was expected to reduce
storage requirements, allowing a small amount of beer recovery (press filtrate) and elimina-
tion of the frequent storage tank overflow.
Therefore, instead of treating each of the fermentation cellar discharges separately which
would be uneconomic, the audit team considered that the proposed filter-press installation
for the yeast recovery area should be arranged to filter the initial rinses from fermentation
tanks, storage vessels and yeast recovery equipment. This would not only prevent the majority
of yeast from flowing to drain but would enable its recovery for resale to a food manufacturer.

Case Study 1: Beer Production
In addition, any other liquor containing yeast that had to be dumped to drain, such as the
initial drop from the storage tanks when the yeast storage vessels were full, could be Altered
and the yeast and beer recovered. The expected increase in flow to the proposed filter press
was estimated at 50 m3/d containing 100 kg SS/d, well within the unit's design capacity.
c) Treatment Cellar
A number of waste saving options were recommended for this area. The principal measures
proposed related to the bottling and kegging areas. The possibilities of utilising the 7S°C hot
water tank overflow for the pasteuriser supply have already been highlighted in the brewhouse
section above. The audit team felt that the water flowing out of the pasteuriser could be used
as an initial rinse in the bottle washer.
The existing bottle washer system used 9 m3/h fresh deionised water. It was proposed that the
final sparge pipes should continue to be supplied with deionised water but that the pasteuriser
water be used to supply the remainder and also for continual replenishment of the water in the
final rinse tank. Mains water would be provided as a standby supply in the event for any
reason that the pasteuriser water ceased.
In the kegging area, dumping of returned beer to drain was occurring periodically giving a
very significant rise in BOD and COD load during the dumping periods. It was indicated to
the company that separate disposal, possibility directly to land, should be seriously considered
as often adopted by other breweries. It was noted, however, that this would require the
permission of Customs and Excise officials and be subject to the beer being destroyed in an
approved manner such as by dyeing.
Step 16: Targetting and Characterizing Problem Wastes
Following completion of Step 15, the audit team realised that significant reductions in wastewater
flows and pollution loads could be achieved by carrying out all the improvement measures high-
lighted, all of which were relatively straightforward to implement
It was decided it would be useful to obtain an overall picture of the waste savings which could be
achieved Thus, a summary of the existing and proposed reduced waste contributions for the unit
operations highlighted in Step 15 was drawn up as presented in Table 3. At this stage, no allow-
ance was made for the benefits of avoiding returned beer being discharged to drain since this was
dependent on future discussions with Customs and Excise personnel.

Case Study 1: Be«r Production
Table 3: Summary of Existing and Proposed Reduced Waste Contributions
- Predicted

m1 kg

kg kg
Final run to
60 1392
0 0
75°C Hot Water
50% reuse as make-up
for pasteuriser
0 0
Caustic and
acidic wash at
36 152
Installation of OP unit
0 0
OP wash
Reuse rtnsewater
0 0
OP wash
65 248
Reuse and yeast
62 44 -
Storage Tanks
17 89
Reuse of rinsewaters and
pressing of initial rinse
22 3
Yeast Storage
and recovery
OP wash
2 17
yeast recovery
4 0.2
Process water
Reuse In botUewasher
0 0

456 1898

88 47.2
For flow, COD and SS load savings of 327 m3/d, 1,810 kg COD/d and 230 kg SS/d (ref. Table 3),
the predicted reductions on the total wastewater discharges assessed in Step 8 were approxi-
mately 19%, 30% and 15% respectively.
Step 17: Segregation
In formulating a series of recommendations for waste reuse and recovery which could be imple-
mented relatively quickly (ref. Step 16), the waste audit team had recognised at an early stage
that waste segregation would form an integral part of the waste reduction strategy.
The proposals were discussed with the management who, in principle, were in agreement that
the various measures put forward were sensible and practicable, subject to the audit team being
able to demonstrate that the likely long-term cost savings to be achieved would be appreciable.

Case Study V. Beer Production
Step 18: Developing Long-Term Waste Reduction Options
Prior to the water authority stating that the increase in local sewage treatment works capacity
would not require a capital contribution from Company A, the brewery's waste management
consultants had prepared preliminary plans for an on-site pretreatment plant based on pH
control, balancing and oxygen activated sludge treatment.
This compact treatment option had been selected in view of the limited spare land area available
on site. An additional attraction was the reduced risk of developing filamentous, poorly-settling
sludges compared with conventional air activated sludge systems treating brewery, or similar
wastes, having a high soluble carbohydrate content.
However, in the light of the water authority's subsequent proposals and a comparative economic
assessment of the two alternatives - discharge of untreated combined wastewaters (or, at worst,
following preliminary treatment only) plus payment of trade effluent charges, or partial biological
pretreatment plus payment of reduced trade effluent charges - plans for pretreatment facilities
on-site were shelved pending the outcome of the waste audit and reduction investigations.
The audit team considered that if the good housekeeping measures as outlined in Step 16 were
implemented, particularly those relating to the reuse of the significant pollution load associated
with the Lautertun drain and the control of caustic and acidic discharges, then future pH
control and flow/load balancing of combined flows in order to ensure compliance with discharge
standards would not be necessary.
Step 19: Environmental and Economic Evaluation of Waste Reduction
From the waste saving studies which were orientated around possibilities for reuse/recycling and
recovery, it was dear that following implementation of the measures drawn up the net discharge
of wastes to the environment would be significantly reduced. Thus, there would be a clear
environmental benefit.
The audit team then tabulated the estimated trade effluent charges with and without allowance
for the proposed waste saving measures (Table 4). This enabled the potential savings in these
charges to be identified.

Case Study 1: Beer Production
Table 4: Estimated Trade Effluent Charges
Savings in
Final run to
75° Hot Water Tank O/erflow
Brewhouse Vessels
Gauging Vessels
Fermenting Vessels
Storage Tanks
Yeast Storage and
Pauste riser
Caustic and
Acidic Wash at
Process Water
The trade efnuent charges listed in Table 4 were then compared with the expected total trade
effluent charge for the existing combined wastewaters, estimated at US$365,000 per annum for
the forthcoming year. This indicated a 26% reduction resulting from implementation of the flow/
load reduction proposals.
Based on the data set out for Step 16, the reduced average flows and loads would be some 1,400
nrVd, 4,170 kg COD/d and 1£70 kg SS/d. This corresponded to reduced average waste quanti-
ties per cubic metre of beer produced of 1.7 m3, S.0 kg COD and 1.5 kg SS.
Further examination of all the waste audit data obtained indicated that peak wastewater flows and
loads on any one production day could rise to 70% above these average discharge levels. How-
ever, the assessment of trade effluent charges based on average discharges was considered to give
a realistic estimate of the savings which could be expected over a full production year.
The audit team appreciated that in addition to savings in trade effluent charges, there would be
other cost benefits which were difficult to quantify during the time-frame of the consultant's brief
but which included costs associated with raw water, energy and the probable elimination of
combined wastewater treatment which would otherwise be required to meet discharge consent
conditions consistently.

Case Study 1: Be«r Production
It was also recognised that some capital expenditure would be required to implement the pro-
posed waste reduction programme. It was agreed with the brewery management that this aspect
was best costed by their own engineering staff but that since the capital sums involved would be
relatively small compared to the company's capital expenditure budget for the current year, and
related to progressive improvements in the brewery production operations, the company would
be likely to accept the waste savings proposals on the basis of the significantly reduced trade
effluent charge savings alone.
Step 20: Developing and Implementing an Action Plan: Reducing
Wastes and Increasing Production Efficiency
The results of the waste audit and waste reduction studies were formally presented to Company
A's management in the form of a technical report. The recommendations made were accepted
and plans were then made to implement the recommendations.
The waste audit had provided a sound understanding of all principal sources of waste arising
within the brewery. Furthermore, the brewery technologist assigned to assist the waste audit
team had benefitted greatly from being involved in the step--step approach adopted by the
company's consultants.
It was considered that the experience gained by the brewery would enable company staff to take
the lead in any future waste audit programme, particularly the assessment of the actual waste
reductions achieved following commissioning of the plant modifications and additions proposed.

Company B operates a tannery in south-east Asia processing cattle hides into finished leather,
mainly for side upper leather in shoe manufacture. Treatment of the hides involves a series of
batch operations involving application of a wide range of physical and chemical processes.
Wastewaters discharged contain pollutants from the hides, products from their decomposition,
and chemicals and various spent solutions used for hide preparation and during the tanning
process. Solid wastes and some atmospheric emissions also arise.
The company was required to meet new government standards for discharge of wastewater to the
local watercourse. This necessitated improvements to existing treatment facilities which were
then limited to crude settlement in three lagoons operated in series. Primary sludge produced
was disposed of in liquid form on a large area of surrounding land.
In the light of this situation, the company engaged a local consulting engineering firm to assist
their staff in carrying out a waste audit and waste reduction programme with a view to developing
the best and most cost-effective solution to the waste treatment and disposal problems.
The principal tannery operations carried out, typical of many tanneries throughout the world,
may be summarised as follows.
Pretanning (or Beamhouse) Operations
•	soaking of the imported, preserved (wet-salted) hide in water overnight to remove blood,
dung, curing salt and water-soluble and saline-soluble proteins;
•	unhairing (complete dissolving of all hair) by immersion in lime and sodium sulphide - and
subsequent retiming;
•	trimming and mechanical removal of extraneous tissue from the flesh side of the hides - and
subsequent splitting (lime splitting) of the upper two-thirds grain layer from the lower, less
valuable split layer;
•	deliming by treatment with a weak acid (lactic acid) and bating with an enzyme-
based chemical to remove hair remnants and degraded proteins;
•	pickling using salt and sulphuric acid solutions to give the required acidity to the skins to
prevent subsequent precipitation of chromium salts on the skin Fibres - pickled splits are then
sold to other tanneries for further processing, only the grab layers being tanned and finished
by Company B.
Thus, wastewaters from the beamhouse contain high levels of suspended solids and dissolved
organic matter, curing salt and grease, in addition to unused process chemicals (particularly
sulphides); they will also be alkaline, having a high oxygen demand.

Case Study 2: Loather Manufacture
Chrome tanning is carried out using chromic sulphate. The tanning process stabilises the
proteineous (collagen) network of the hide. Acidic effluents are produced which contain unused
trivalent chromium salts.
Post-Tanning Operations
These involve:
•	pressing (samming) to remove moisture;
•	a second levelling by shaving;
•	dyeing and softening of the tanned hide with emulsified oils (fatliquoring), preceded by
occasional secondary tanning using synthetic tannins (syntans) and tanning extracts;
•	drying and final trimming;
•	surface coating and buffing (finishing)
The following case study describes the waste audit/waste reduction approach taken.

Step 1: Audit Focus and Preparation
It was decided that the study investigations would be carried out by a chemical engineer from the
consulting firm's staff who had previous experience of carrying out waste audits, assisted by the
tannery's plant chemist.
Company B's own laboratory was not equipped to carry out many of the tests normally associated
with wastewater analysis and so arrangements had to be made to deliver samples to a local private
company providing laboratory analytical services.
In view of government pressures, it was decided to concentrate on wastewater discharges arising
from the beamhouse and subsequent tanning operations. However, atmospheric emissions were
also investigated having particular regard to health and safety. Solid waste arisings, in particular
wastewater treatment plant sludges, were also studied.
The waste audit team was keen to gain the support of production personnel in order to ensure
that comprehensive information on all tannery operations could be readily obtained. As a first
step therefore, the study objectives were fully explained to selected staff responsible for the
various production activities.
The investigations were initiated by gathering relevant information from company files. This
preliminary search yielded site and drainage plans, raw material purchase records and water
meter records associated with on-site borehole abstraction.
A preliminary check on water usage was carried out by calculating the water usage per tonne of
wet-salted hide processed. This was found to be 61 m3/tonne. It was noted that this was some
22% higher than the typical average working figure of SO m3/tonne reported in technical litera-
ture, suggesting that ways of introducing considerable water savings should be possible as a result
of the waste audit/waste reduction study.
Step 2: Listing Unit Operations
The consultant and the plant chemist started the tannery study by walking around the processing
and waste treatment areas, listing all the unit processes and making notes on their function and
use. Help was also sought from various plant operators who were familiar with the day to day
plant operations. The unit operations were listed in Table 1, with processes which did not
produce liquid waste shown in brackets.

0«m> Study 2: Leather Manufacture
Table 1: Unit Operations
Unhairtng and Retiming
(Trimming, Fleshing and Splitting)
Deltming and Bating
Chrome Tanning
Secondary Tanning, Dyeing and Fatliquoring
(Drying, Trimming and Sorting)
As part of the company's long-term planning, the plant chemist noted that consideration was
being given to moving the hide splitting operations further downstream the process line (after
tanning) in order to improve the accuracy of splitting and hence overall process control, as
commonly practised at other tanneries. The existing arrangement and design of process units,
many of which were relatively old, did not however lend themselves to this change being imple-
mented rapidly.
Step 3: Constructing Process Flow Diagrams
A flow diagram was then prepared to illustrate the interrelationship between the various unit
operations (Figure 1).

Figure 1: Schematic Diagram of Tannery Operations
imported wet-satted
Salted Stock
Bactericide, soda ash,
Lime, sodium sulphide,
Lactic add, bate,
chloride, water
Salt, sulphuric add,

Trimming, Fleshing
and Splitting

Deliming and Bating

^ Dirt-laden, saline
Hydrogen sulphide
Alkaline waste
Trimmings and fleshings

Alkaline wastewaters
Brine and
acid dilution
Chromic sulphate, salt,
syntan, sodium
soda ash, bactericide
Tanning extracts,
syntan.dyM, calcium
formate, flour, glue,
titanium dioxide, oil.
Surface coatings

	« At	«

rer hides
Chrome Tanning



Secondary Tanning,
Dyeing & Fatliquoring


Drying, Trimming
and Sorting

Leather Product
PicMed splits
Acidic wastewaters
containing Cr®+
syntan, salts
Press liquors
Shavings containing
Acidic wastewater
containing O3*,
tanning extracts,
syntan, dyes, fats
containing Cr34
Solvent vapours
¦containing hair, dirt, organic matter, salt
and excess lime, sodium sulphide



Step 4: Determining Inputs
The audit preparation phase (Step 1) had already highlighted the availability of well-documented
raw material purchasing records. The data produced also proved to be a good check on the raw
material quantities quoted by the plant foremen per unit operation.
The raw material usage data obtained were set out as in Table 2.
Table 2: Annual Consumption of Process Chemicals
Process Chemicals
Sodium Chloride (other than curing salt
present In raw hide)

Hydrated Lime
Sodium Sulphide (62% NajS)
Sulphuric Acid
Soda Ash (anhydrous sodium carbonate)
Bate (95% ammonium sulphate.
5% enzymes)

Calcium Formate
Lactic Add (30%)
Sodium Formate
Ammonium Chloride
Chemicals Absorbed by the h&de (i)

Tanolin (16% chromium)
Syntans A& B
D-1 Oil
Other Oils
Tannin Extracts
Soyarich Rour
Titanium Dioxide
Methyl Cellulose
Semi-Sol Glue
(i) Absorption estimated at 00%, 10% discharged to waste • except for Tanolin, absorption 75%. 25% discharge
to waste
Due to the nature of the raw materials and the well-organised materials storage system which was
found to be in operation, no significant handling losses were occurring.
It was noted that the company incurred no charges for consumption of water drawn from a site
borehole. A separate town water (potable) supply was available for domestic use. Domestic
wastewater passed to the nearby watercourse via a septic tank.

Case Study 2: Leather Manufacture
Having already tabulated the key production stages (Step 2), raw material usage listed in Table 2
was used to derive average quantities per unit operation throughout the tannery, on both a daily
basis and per tonne of hide processed.
The data compiled were set out in Table 3.
Table 3: Chemical Inputs per Tannery Unit Operation
Unit	kg/tonne hide	kg/tonne	kg/d
Operation	(at unit operation) wet-flatted hide
Bactericide	1.6
Sodium Carbonate	0.8
Hydrated Ume (unhairing)	48
Sodium Sulphide (62% NtijS)	43
Hydrated Ume (retiming)	58
Lactic Acid	5
Bate	10
Ammonium Chloride	1.3
Sodium Chloride	60
Sulphuric Add	21
Chrome Tanning:
Tanolin (basic chromic sulphate, 16% Cr3*)
Sodium Chloride
Syntan A
Sodium Formate
Sodium Carbonate
Syntan B
Secondary Tanning, Dyeing
and FalBquoring:
Calcium Formate
Syntan B
Soyartch Flour
Titanium Dioxide
Glue/Methyl Cellulose
Tannin Extracts & Oils
(i)	1.6	64
(i)	0.8	32
(1)	48	1,920
(i)	43	1,720
0	58	2£20
(ii)	4.3	172
(ii)	6.7	348
(ii)	1.1	44
(B)	51.9	2,076
(H)	18.2	728
8.9 (H)
10 (H)
20 (iO)
44 (iii)
16 (iii)
(i)	Based on 40 tonnes wet-salted hide per day
(ii)	Based on fleshed, split/trimmed hide, after retiming • 34.6 tonnes per day
(iii)	Based on chrome tanned leather, after pressing/shaving • 14.0 tonnes per day

Case Study Z. Leather Manufacture
Step 5: Recording Water Usage
The next step was to record the water usage at the tannery and determine how it was used. It was
noted that water obtained by the company from the she borehole was pumped to a covered
storage tank at ground level and then pumped again to a high-level storage tank. Water then
gravitated to the site distribution mains under static head via a water meter, readings for which
were recorded weekly in a log book.
Analysis of these records indicated a daily average total water consumption for the site of 2,450
m3/d. This figure was then broken down into average water usage per tannery unit operation in a
similar manner to that carried out for the process chemicals. Since the tannery wet processes
were all carried out in revolving vessels of known capacity, providing mechanical agitation to
accelerate the wet-chemical operations, batch process water inputs were readily quantifiable.
Rinsewater usage which was continuous for a fixed duration per batch was also known from
previous work carried out by the company. This had involved checking the time taken to fill a
vessel of known volume for a given water valve setting.
The results were summarised as set out in Table 4.

Case Study 2: Leather Manufacture
Table 4: Water Inputs per Tannery Operation
Unit	rrrVlonne hide	m3/tonne	m3/d
(at unit operation)
wet-salted hide


Process Water
Rinse Water

Process Water
Rinse Water
Soak Water (retiming)
Rinse Water

Prooess Water
rtune wnvf

Brine Water
Add Dilution Water
Chrome Tanning:

nDQ88l Waltr
Secondary Tanning, Dyeing

and FaUiquoring:

Prooess Water
Rinse Water
Prooess Water
General Floor and Plant Washwater


	l*»- »	
ntnso waters


• Total

0) Baaed on 40 tonnes wet-salted hide per day
(ii) Baaed on fleshed, spOt/Mmmed hide, after rellming • 34.6 tonnes per day
(ill) Based on chrome tanned leather, after pressing/shaving -14.0 tonnes per day
Step 6: Measuring Current Levels of Waste Reuse/Recycling
It was noted that no wastes were reused/recycled at the tannery.

Com Study 2: Luther Manufacture
Step 7: Quantifying Process Outputs
The audit team listed the process outputs from each tannery unit operation as set out in Table 5
Table 5: Process Outputs
Unit Operation
Waste Reuse
Process and
tii.i, I,
Prooesi and
Hnse Waters
Hydrogen Sulphide
Trimming, Fleshing and Splitting
Trimmings and
Process and
Rinse Waters
Process Brine/
Add Dilution
Pickled Hide Storage
Pickled Splits
Chrome Tanning
Prooess and
Hnse Waters
Pressing and Shaving
Press Liquors
Secondary Tanning, Dyeing and
Prooess and
Rinse Waters
Drying, Trimming and Sorting
Solvent Vapours
Final Product
w-'-'	¦ | . . tfc . i
rmmnmo Ltnmf
(grain layer)
Action was then taken to quantify these outputs in Steps 8,9 and 10.
Step 8: Accounting for Wastewater
Process wastewater flows were based on totalling up batch water inputs and making allowances
where appropriate for water retention by the hide at each process stage based on percentages
reported in technical literature.
Composite samples of the various discharges were also taken for laboratory analysis.
The results of this exercise were summarised in Table 6.

Com Study 2: Leather Manufacture
Table 6: Average Flows, Strengths and Pollution Loads of Strong Liquors
Unit Operation




% of
Un hairing
Delima and Bating
Chrome Tan & Press

Secondary Tanning,

Dyeing &


• 1st dump
• 2nd dump
It was decided that having quantified the main, strong-liquor pollution loads per unit operation,
separate quantification of running rinse water pollution loads per unit operation was not justified
since this would have meant setting up numerous V-notch weirs and many additional sampling
points, thus increasing significantly the time input and analytical work required.
The relatively weak continuous-flow rinse waters were thus monitored using a V-notch web
located in a common drain within the tannery and combining frequent spot samples to give a
daily composite for the whole tannery. Total rinse water flow including general floor and plant
washdown was estimated to be 1,944 m3/d with an associated BOD and SS strength of 273 mg/1
and 396 mg/1 SS. Corresponding pollution loads (flow x strength) were thus 530 kg BOD/d and
770 kg SS/d.
The overall wastewater flows and BOD and SS strengths and pollution loads were then tabulated
in Table 7.
Table 7: Combined Wastewater Flows, Strengths and Pollution Loads


Strong Uquora
4,680 Q)
6180 (I)
Rinse Waters/General
1,430 0)
1.950 (i)
(!) Concentrations calculated from flow/pollution load data

Caw Study 2: Laather Manufacture
Based on an average 40 tonnes of wet-salted hide processed, it was noted that these overall
figures equate to 65 m3 wastewater/tonne, 90 kg BOD/tonne and 121 kg SS/tonne, ie fairly
typical unit loads compared with average figures for similar tanneries elsewhere but some
20-25% high in terms of wastewater flow.
An assessment was also made of chromium and sulphide pollution loads based on selected
additional wastewater analyses carried out. This yielded pollution loads of 198 kg Cr/d and 412
kg S"/d, equivalent to 4.9 kg Cr/tonnc and 103 kg S"/tonne. Again, it was noted that these loads
were fairly typical in the consultant's experience even for well operated tanneries, although
somewhat higher (14% and 21% respectively) with respect to figures reported by WHO, 1982.
A number of other checks were also made. It was noted that while it was difficult to measure
combined wastewater flows entering the wastewater treatment system, the final lagoon effluent
discharged via a rectangular weir. In order to obtain some cross-check on the combined raw
wastewater flow set out in Table 7, the final effluent flow to the nearby watercourse was moni-
tored using this weir. An average flow over the study period of 2,200 m3/d was recorded.
A limited number of samples of the lagoon effluent were taken and results compared with the raw
wastewater analyses tabulated in Table 7. These indicated pollution load reductions averaging
40% BOD and 70% SS. Based on an average sludge concentration of 6% dry solids, calculations
indicated that the volume of primary sludge generated averaged 56 m3/d. The audit team noted
that while this sludge was periodically being disposed of on surrounding land, this practice would
not be allowed to continue in the future as liquid run-off caused additional pollution problems in
the nearby watercourse, particularly during wet weather.
Step 9: Accounting for Gaseous Emissions
It was decided that consideration of atmospheric pollution issues in the context of this project did
not justify the need for making use of portable gas detection equipment, such facilities in any
case not being readily available. It was also considered that resources required to quantify
gaseous emissions would be out of proportion to the extent of the problems occurring. However,
various useful observations were made during the site survey.
A strong smell of hydrogen sulphide (H2S) gas was evident at the primary sedimentation stage of
the wastewater treatment plant. H2S was also evident, although only to a limited extent, within
the tannery processing areas where alkaline bcamhouse liquors combined with subsequent acidic
streams within the internal drainage system.
The plant chemist knew that the hydrogen sulphide was a highly-toxic gas having a threshold limit
value (TLV) of 15 mg/m3 (100 ppm by volume) in air. He also knew that the extent to which H2S
could be released from solution to atmosphere was pH dependent, high pHs favouring the
ionised form (HS') and hence reduced risk of sulphide stripping. He therefore noted that any

Cue Study 2: Leather Manufacture
future wastewater treatment scheme would be best designed to allow pretreatment of alValinp
beamhouse liquors (pH at least 10) before they were allowed to mix with other, acidic waste
No release of ammonia associated with deliming/bating was apparent but it was noted that release
of some solvent vapours in the working areas associated with leather finishing could be a potential
health risk to production staff. Discussions with the management subsequently revealed that
plans were already underway to install forced-ventilation equipment to cater for this problem.
Step 10: Accounting lor Off-Site Wastes
The only wastes which were recycled were fleshings which were transported to a local rendering
company; these amounted to an average of 9,200 kg/d.
Trimmings and shavings were disposed of to a local municipal landfill site and amounted to
14,600 kg/d.
No sale costs associated with disposal of the fleshings could be readily identified at the time of the
waste audit. It was later established that no charge was levied by the tannery in return for the
rendering company providing transportation facilities at their cost.
Trimmings and shavings were disposed of at an annual cost of US$14,000.
Step 11: Assembling input and Output information for Unit Operations
From the information collected the preliminary material balances were started by assembling the
input and output data for the tannery and the wastewater treatment plant. These were tabulated
under Step 12.
Step 12: Deriving a Preliminary Material Balance for Unit Operations
A preliminary material balance of data associated with operations within the tannery was first
drawn up on an overall input/output materials basis. The information was tabulated as set out

Case Study 2: Luther Manufacture
A material balance was then drawn up on a unit operation basis with specific reference to chro-
mium and sulphide. A material balance for the wastewater treatment plant was also compiled.

Case Study 2: Leather Manufacture
Step 13: Evaluating the Material Balance
The waste audit team were confident that they had obtained an adequate material balance (within
5-10%) for the tannery as a whole as well as for the specific chromium and sulphide chemicals

Case Study 2; Leather Manufacture
The material balance for the wastewater treatment plant was also considered reasonable taking
into account that some water seepage was possibly occurring through the base of the crude
lagoons, thus contributing to the 13% difference between inflow and total outflows recorded.
Step 14: Refining the Material Balance
It was considered that the material balance information obtained was sufficient to meet immedi-
ate requirements but that it would be useful to cany out a further waste audit once any waste
reduction measures had been implemented.

Step 15: Examining Obvious Waste Reduction Measures
It was noted that the rinsewater usage following unhairing was appreciable, amounting to some
18% of the total water usage throughout the tannery.
It was considered that significant savings could be achieved at this stage by changing from a 4-
hour running rinse to a two-stage batch wash operation, each of 20-25 minutes duration. It was
anticipated following a short-term trial that it should be possible to achieve a consistent 60%
reduction in rinsewater usage, that is, from 440 m3/d to 176 m3/d.
The audit team also realised that considerable water wastage was taking place by tannery staff
leaving numerous hoses running in between general floor and equipment washdown operations.
On the basis of an average of 15 hoses in continuous use, it was estimated that water passing to
drain surplus to actual requirements could be as much as 136 m3/d, some 5% of the total waste-
water flow. Recommendations were therefore made for the fitting of pistol-grip self-closing
valves on all hoses in use throughout the tannery.
Thus, it was concluded that total wastewater flows could be reduced from 2,600 m3/d to 2,200
m3/d, reducing the wastewater production to a more respectable 55 m3/tonne wet-salted hide
Step 16: Targetting and Characterizing Problem Wastes
a) Sulphide Liquors
As indicated in Step 9, it was evident that pretreatment of all sulphide-containing liquors was
needed before they became mixed with other acidic flows; the possibility also existed of at
least partial recycle of fine-screened sulphide liquors in subsequent unhairing operations.
The management flavoured a flexible approach with the treatment system designed to handle
the total daily sulphide liquor flow if required, conscious that sulphide liquor recycle would
probably require a higher level of surveillance of the efficiency of the unhairing operation
which might not be readily achieved on a consistent basis in practice.
The audit team then proceeded to draw up design flow and strength data for the pretreatment
of sulphide-bearing waste streams; and also for the subsequent combined wastewater treat-
ment facility required to meet the government's new discharge requirements.
Sulphide-bearing liquors were taken as being all the process and rinsewaters associated with
the unhairing process and all wastewater associated with deliming/bating other than the final
rinse. The resultant average design flow and sulphide load assessed were as shown in Table 8.

Case Study 2: Leather Manufacture
Table 8: Characteristics of Sulphide-Bearing Wastewaters
590mJ/d •
412 kg/d (700 mg/1)
420 kg/d (700 mg/1 - ave.)

600 kg/d (1,000 mg/1-max.)
* assuming unhalring-stage rinsing carried out on a 2-stage batch basis to reduoe water usage (equivalent
to 27% ol totaJ wastewater flows following instigation of water saving)
An assessment was made of the likely BOD reduction due to oxidation of sulphide. The
theoretical oxygen uptake rate due to oxidation of sulphide was taken as 0.75-2.0 kg 02/kg S"
depending on the ratio of the thiosulphatesulphate oxidation products. Taking an average
1.4 kg 02/kg S" and a 97% S" reduction (down to 20 mg/1 S"), this gave a BOD reduction of
560 kg/d.
With reference to Table 7, the combined wastewater BOD load can be expected to reduce
from 3,600 kg/d to 3,040 kg/d, equivalent to 1^80 mg/1 BOD in a reduced flow of 2^00 m3/d.
Regarding the effect on suspended solids loads as a result of fine-screening of sulphide
liquors, actual removals were difficult to predict accurately without further test work. As a
conservative approach therefore, it was decided that the calculated total SS load of 4,825 kg/d
(Table 7) should be carried forward as a design SS load for sizing and budgetary costing of the
combined wastewater treatment plant; this gave a concentration of 2,190 mg/1 SS at the
predicted future reduced flow.
b) Chrome Liquors
The audit team considered the possibility of recovering chrome from the chrome-bearing
liquors by fine screening, addition of sodium carbonate to precipitate chrome hydroxide (at
pH 8-8S), filter-plate pressing of the resultant sludge and then conversion of the chrome
precipitate to soluble chromic sulphate using sulphuric acid.
Discussions with the management revealed that this possibility had been considered in the past
but was not favoured on overall technical and cost grounds unless the benefits of economy of
scale could be introduced by providing a centralised chrome recovery plant to serve all
tanneries in the local area. While some preliminary discussions had been held through the
national tannery association, such a scheme was not foreseen at this stage.
It was agreed therefore that for the present, the design of a new wastewater treatment plant
should assume that chrome would be precipitated and disposed of off-site as part of the
primary sludge generated.

Cue Study 2: Leather Manufacture
Step 17: Segregation
In order to segregate sulphide liquors for separate pretreatment, it was decided to divert existing
drainage outlets in the unhairing area to a batch treatment plant located within the existing
tannery process building.
Treated flows would then be combined with all other wastewaters at a new treatment plant
located close to the existing settlement lagoon facility.
Step 18: Developing Long-Term Waste Reduction Options
The waste audit consultant was responsible for drawing up outline proposals for the required new
wastewater treatment facilities.
Consideration was given to available methods of sulphide treatment These included:
•	acidification to pH 2-3 and aeration, with absorption of the resultant hydrogen sulphide gas in
caustic soda solution within packed-tower scrubbers prior to discharge of the resultant liquor
to drain or reuse;
•	precipitation with ferrous or ferric salts;
•	oxidation using chlorine or hydrogen peroxide;
•	oxidation using aeration with a manganese catalyst.
The latter method was considered the most technically satisfactory and cost-effective solution
following fine screening. This view was supported by reference to available information sources
concerning operational experience elsewhere.
It was decided to divert existing drainage outlets in the unhairing area to a mechanical self-
cleaning screen (1 mm) located in a modified floor channel, the upper end being designed to
convey screenings to an adjacent skip.
Screened flows would then gravitate to a submersible pumping station to lift flows into one of two
batch-treatment oxidation tanks, one to be used for treatment and the other to be available for
receiving the next batch of liquor. A diffused-air system, using non-clog coarse-bubble diffusers,
was selected to provide mixing and aeration in each tank and a facility for dosing a solution of
manganese sulphate catalyst was incorporated.
The main treatment plant for pretreated sulphide liquors combined with all other wastewater
flows involved the following features:

Can Study 2: Laather Manufacture
•	flow/pollution load balancing incorporating coarse-bubble aeration/mixing;
•	pH correction (if required), chemical flocculation with alum and polyelectrotyte and subse-
quent primary settlement;
•	extended aeration treatment using low-speed mechanical surface aerators (sized to provide a
robust biological system capable of withstanding fluctuating loads);
•	batch storage/thickening of mixed primary and surplus secondary sludges prior to pumping to
drying beds and subsequent disposal of sludge cake to landfill.
Provision for iron salt dosing to the sludge storage/thickening tank was incorporated to precipi-
tate any sulphide formed as a result of anaerobic activity within the tank and hence to minimise
odour problems occurring.
A schematic diagram of the proposed treatment plant was compiled as illustrated in Figure 2.
Step 19: Environmental and Economic Evaluation of Waste Reduction
Company B was placed in a position of having to upgrade its wastewater treatment system in
order to comply with new discharge standards imposed by the government, part of a new empha-
sis on the need to control pollution of the environment
The new effluent discharge standards laid down were 40 tng/1 BOD and 60 mg/1 SS. Hence,
provision of a new treatment facility designed to meet these standards consistently was expected
to improve the quality of the local watercourse substantially.
There was a clear need to minimise capital and operating costs of the treatment scheme to ensure
the overall financial viability of the company's operations. Therefore, in preparing outline designs
for budgetary purposes, particular attention was paid to providing a plant which would be robust
and relatively simple to operate.
The cost of the treatment scheme drawn up was estimated at US$500,000 including contingencies
and design/construction supervision fees. This reflected a conservative approach to the sizing of
the activated sludge process, particularly in terms of aeration capacity. It also took into account
the availability of two redundant water storage vessels suitable for use as sulphide-liquor treat-
ment tanks.
This approach was adopted to provide some flexibility over the mode of operation of the plant
with a view to minimising operating costs • it would allow the primary settlement stage to operate
without addition of chemical flocculants if desired, with consequent higher strength effluent

Figure 2: Sen m tic Diagram of Proposed Wastew terTre tment
Alkaline Sulphide Liquors
Other Wastewater#
Fine Screening
Batch Catalytic
*to Landfill
Possible Recycle to
-tUnhairing Prooess
Fine Screening
Sludge Liquors
Primary Sludge
X Surplus Seoondary
— Sludge
Drying Bads
-*	»—¦
Sludge Cake
to Landfill
Rnal Effluent To
to Landfill
Sulphuric Add/
Caustic Soda
(H necessary)

Case Study 2: Leather Manufacture
passing forward to the biological stage; overall sludge yields requiring ultimate disposal off-site
would also be minimised. Provision for chemical flocculants at the primary stage was included
however since it was felt that their use could enable the required final effluent quality to be
achieved more consistently.
Step 20: Developing and Implementing an Action Plan: Reducing
Wastes and Increasing Production Efficiency
The consultants engaged to carry out the waste audit/waste reduction studies presented the
results of their findings to Company B's management. The data presented were used as a basis
for submitting a planning application to the local government office for approval to design and
install the proposed wastewater treatment plant
During a subsequent meeting with the government concerning timing of the proposed design and
construction work, Company B was informed that the introduction of a charging system for
borehole abstraction was under consideration for possible implementation the following year.
This development emphasised to the tannery management the importance of having carried out
the waste audit/waste reduction investigations and the need to be alive to further water-saving
possibilities in the future.
The waste audit/waste reduction investigations achieved the following objectives,
e A thorough appreciation of all the sources of waste at the tannery.
•	Identification and quantification of the major sources of wastewater including waste sulphide
and chromium contributions.
•	Evaluation of processing efficiencies from assembled information on unit operations, raw
materials, water usage, products and waste generation.
•	Reduction of water usage and associated wastewater disposal problems.
•	Identification of problem wastes (ie sulphide liquors) requiring special attention.
•	Development of a waste management system which would comply with discharge regulations
and result in a much-improved local environment.

Company C manufactures double-sided and multi-layered circuit boards for the telecommunica-
tions and computer markets. The manufacturing of printed circuit boards involves a complex
series of physical and chemical processing stages and as a result the wastewaters which are
generated are complex, of variable composition and difficult to treat. To compound the treat-
ment problems, many of the processing solutions contain proprietary chemicals whose composi-
tion is not readily available.
The main pollutants in printed circuit board manufacturing wastewaters are heavy metals, par-
ticularly copper. Company C's wastewater frequently exceeded the local authority's standards for
discharges to the public sewerage system. Although the company had implemented some im-
provements to its wastewater treatment system in recent years, discharges in excess of the 5 mg/1
limit on copper continued to occur and the local authority eventually decided to take legal action.
In response to these problems the company decided to conduct a waste audit in order to:
•	bring to the attention of production personnel the importance of minimising wastage at source
with a view to improving overall production efficiency while at the same time reducing both
raw material costs and waste treatment costs;
•	identify the sources of contamination;
•	develop a waste reduction strategy to minimise contaminants at source;
•	develop a sound understanding of the wastewater problems to facilitate the design of a cost-
effective wastewater treatment system to comply with discharge standards.
The printed circuit board material is composed of a glass-fibre sheet with copper laminate on
both sides. The uncut boards are received from the suppliers in large sheets and pass through a
shearing stage to cut them to the desired size. The boards are then drilled and pass through a
surface conditioning stage (deburring) before undergoing a series of treatments in the sensitising
area (electroless plating). This treatment essentially coats copper into the holes and prepares the
holes for electroplating.
The next stage involves the application of a photopolymer-resist material which masks off areas
which do not need to be electroplated. The printed circuit areas are subsequently developed (to
remove unexposed resist areas which arc to be plated) and pass through microetching, copper
electroplating, solder electroplating, resist stripping, copper etching and a number of other
selected finishing treatments as specified by the customer. The last stages of manufacture involve
final fabrication and electrical testing.
It can thus be seen that the printed circuit board manufacturing plant is complex and a great
number of different process wastes are generated. The following case study describes the ap-
proach taken to overcome the long-standing waste treatment problems encountered by the
company. The investigations were based on the stcp-by-step approach described in this waste
audit manual and the studies highlighted a number of areas where processing and treatment
efficiencies could be improved.

Step 1: Audit Focus and Preparation
The waste audit programme was initiated by selecting an investigating team to carry out the
required work and compiling all existing documentation and information relevent to the project.
In view of the scale of the investigatory work required, the audit team included representatives
from each key manufacturing section. This not only increased employee awareness of and
support for the study programme but enabled a full understanding of the factory processes and
particular problem areas to be developed.
The audit team studied the practical aspects of initiating the required studies. It was decided that
wastewater flow measurements and sampling could be readily conducted using internal resources
but that it would be necessary to engage a contract laboratory to carry out the numerous wastewa-
ter analyses required.
Step 2: Listing Unit Operations
Due to the complex nature of the printed circuit board plant it was not considered appropriate to fist
all the unit operations in fine detail. Instead, following a detailed walk around the factory, the various
manufacturing stages were compiled in terms of processing areas. Furthermore, as copper was by far
the major contaminant of interest, it was decided at this stage to conduct the waste audit with specific
reference to copper.
Figure 1 shows the general schematic process flow diagram which was constructed from the initial
plant investigations. The areas where waste copper was generated were found to be the:
•	debarring operation (sensitising);
•	sensitising line (electroless plating);
•	electroplating line (copper electroplating, solder electroplating, moist strip and copper etch);
•	oxide coating area (including oxide deburring, oxide coating, solder stripping and lacquer
Step 3: Constructing Process Row Diagrams
Once the main processing areas which generated waste copper had been identified the process flow
diagrams were constructed for each area. This involved a more detailed study of each processing
area and the identification of process inputs and outputs. In addition to the four processing areas
mentioned, a process flow diagram of the existing wastewater treatment plant was also developed.
Figures 2-6 show the process flow diagrams for these main processing areas. It should be noted that
some diagrams are simplified for the purposes of the case study.

(Chr ornate
Areas Where Watte
Copper i* Generated
- -- ¦*<-»
C 3
-	Before Backwash: 2.0 mg/l
-	After Backwash: l.0m(j/l
(Ffeedwater Suspended
Solids Concentration
Before Backwash 104 mg/l)

3 0?J
S I 61.?
Mains I
Water I
30.7 kg
3.0 kg
I	Mains I
i I	Water!
i 1
Mains I
Water I

: . |T
-~ -at' „~ *2
10% HO
, Mains I
Water I
0»«h^ 01+ D9^



Dt -WaaMy to Procaaa Drain
03 ¦ Bmy 2 WMa to Onim* or HoMng Tank
D4 - Emy S Mentha to Orum» tor Storaga
09 ¦ Etmy to Waaka to HoWng Tank
08 ¦ Yaaity to Holding Tank
07 - Evaiy S-7 WaaM to Oiuma to Batch Traatmant
(Not dumpad during tfudy period)
OS • Daiy to Procaaa Drain
(24.0 kg)
Nota: Tank Volumes afl 0.4m3
Except Those Shown Thus •,
which are 0.58m3
BATH - Contains
Chelators (Air)
Figure 4: Process Row Diagram for 9000 Line (Cu Electroplating Sn/Pb
Electroplating, Resist Strip and Etching
Copper Anodes
Air Knife
(100kg) I
Mains Water
Mains Water
Etch Solution^










Mains Water
2 • STAGE Sn/Pb
Etch Sol'n
Air |
Mains ^


Return Etch
a I issj^i ipso|
ToBcti n»co»«ry
Byatwn Oyitillw
C • Total Ooppw Caneoilntlan
~1 - Dally to procra tmmr
OS • Monthly to holding tank
D3-D>By to hotting tank
D4-Chang* ffMctquailarty

Matna Wafer
Persulphate Etch Sol'n Mftin* Water
IL_ iLik' il fcj'it'

(How Only White
Detainer In Operation)


Firifi CmI'm
CfCfl 901 n
D1 • Every 2 - 5 Weeks to Holding Tank
02 - Weekly to Prooraa Drain
D3 - Weekly to Holding Tank	03
C - Total Copper Concentration
0 - Ftowrate





2! 3
~i	co
«	c
zL	^
^	o
_	01
d	3

¦ VI




(45m3) .
— —


T	A ». | SAND |	.
/ ux

C • Total Copper Concentration
D- Olaaotwd Coppf Concentration
SS- Suspended Sollda Concentration
SOLtra ^kh BsTnTa.
Butiulm Cu. Add ,
TANK (9.9m3)

• •
(Cu < 5ppm?)
(To Dicuti

Due to the relative complexity of the printdd circuit board plant the inputs and output informa-
tion collected for the unit operations were recorded on the process flow diagrams based on Steps
4 -10 of the waste audit manual. Any areas of inefficient operation and any opportunities for
waste reduction were also noted. These opportunities are discussed later in Steps IS -18.
Step 4: Determining Inputs
Input information was obtained from measuring chemical additions and water use and recording
the area of copper circuit boards processed (etched);etching of the copper circuit boards involves
acid treatment for surface conditioning, or finishing, and represents a significant copper input. In
the case of the electroplating line the weight of copper anode used (the source of copper for
electroplating) was estimated from past data. The wastewater treatment plant inputs were
determined by measuring the total wastewater flows and concentrations.
Copper input information for the five processing areas was then recorded on the process flow
diagrams in Figures 2 - 6.
Due to the nature of the copper raw materials (copper sulphate solutions and copper laminated
boards) no handling losses were considered to occur prior to the processing operations.
Step 5: Recording Water Usage
The rinse water flowrates were measured at the inlet to the rinse tanks by measuring the time to
fill a known volume container or by draining down the rinse tanks and measuring the time to
refill. The company had recently installed flow restrictors on the rinsewater feed pipes, a good
water conservation measure, in order to limit the amount of water being used in the rinsing
operations. In general, the flowrates measured were in accordance with the ratings for the flow
The water usage data was also recorded on the process flow	(Figures 3 - 6).
Step 6: Measuring Current Levels of Waste Reuse/Recycling
Copper-containing wastes were not generally reused at the plant. However, there was an on-line
crystalliser on the sulphuric/peroxide etch stage of the electroplating line. The etch solution is
pumped from the etch tank through the heat exchanger and into the copper sulphate crystalliser
where the spent etch solution is cooled to 16°C. Copper sulphate crystals are precipitated and
then conveyed to storage tanks, drained and subsequently sold to a local plating shop. The
recovered etch solution is returned to the etch feed tank. The quantity of etchant reused is
described as an input in Figure 4.

Case Study 3: Printed Circuit Board Manufacture
Step 7: Quantifying Process Outputs
The copper-related process outputs were identified and then quantified from copper plating
records and the measurement of waste masses, volumes and concentrations. Apart from the
quantity of copper plated on to the printed circuit boards, which was determined from production
information and plating thickness used, the process output information was obtained from meas-
urements taken in the plant
Step 8: Accounting lor Wastewater
All the wastewater streams which were identified as containing copper (from Steps 1 and 7) were
investigated in a thoroughly planned and conceived sampling programme. The sampling was
performed over a production week in order to cover the full range of operating conditions and to
ensure representative data. Composite samples were taken for all running wastewater streams
whereas spot samples were obtained in the case of bath tanks and dumpings. Samples were also
taken of the outputs from the wastewater treatment plant. The samples were carefully labelled, ..
logged and sent out to an independent laboratory for copper and supporting analyses. Wastew»
ter flows and tank volumes were also recorded. The wastewater information is described in
Figures 2-6.
In addition, a process flow diagram describing the layout of the process drains was constructed
(Figure 7). Dye tests were performed to determine the fate of the wastewater streams and the
layout and interconnections of the surface drains. These studies highlighted some unnecessary
and complex rinse water piping arrangements which were subsequently modified by plant engi-
neering staff.

Cam Study 3: Prtntad Circuit Board Manufacture
Figure 7: Layout of Process Drains
Step 9: Accounting for Gaseous Emissions
The she investigations indicated evidence of a number of gaseous emissions. These were largely
associated with forced-ventilated fume hoods to remove air-borne particulates from grinding
operations and also acid and solvent fumes from subsequent process areas.
As wastewater issues were considered to be of priority concern for the current waste audit, it was
decided that gaseous emissions would be a subject for further study at a later date.

Cue Study 3: Printed Circuit Board Manufacture
Step 10: Accounting for Off-Site Wastes
The quantity of waste material stored on site and transported off-site for disposal was estimated
from in-plant investigations and study of company records. The registerable wastes disposed of
off-site included copper fines (270g/100m2 of board), cartridge filters, and filter-press cake (1360
kg/week). The tin lead activator dump (0.7 m3/annum) was stored on-site as registerable liquid
Step 11: Assembling Input and Output Information for Unit Processes
The material balances were started by assembling the complete input and output data, converted
to standard units, on the process flow diagrams (Figures 2 • 6).
Step 12: Deriving a Preliminary Material Balance for Unit Processes
From the collated information the preliminary balances were constructed for each processing
a) Sensitising Deburrer
The deburrer located in the sensitising area is operated in a recycle mode (see Figure 2).
Return water is continuously filtered to remove copper fines before being fed back to the
deburrer. Captured copper fines are subsequently backwashed from the sand filter and
collected in the bag filter. Essentially the copper inputs are from the brushed boards and the
outputs are from the sand filter backwash bag filter and the cartridge filter. An accurate mass
balance could not be constructed from the available information as the thickness of copper
removed from the boards could not be determined precisely. However, the company did plan
to purchase a high-resolution microscope in the near future which would enable accurate
determination and control of copper thicknesses removed.

Caaa Study 3: Printed Circuit Board Manufacture
b) Sensitising (Electroless Plating)
-The preliminary material balance for the electroless plating line is shown below. ¦
c) Electroplating Line (Micmplate 9000line)

Case Study 3: Printed Circuit Board Manufacture
No make-up or dump of the sulphuric acid/peroxide etch tanks was made during the study period
and as the crystalliser maintains a constant copper concentration in the etch tank these inputs and
outputs were not considered in the material balance study.
d) Oxide coating area
* No conoantratad copper solutions treated In the atudy period

Casa Study 3: Printed Circuit Board Manufacture
The volume of the filter-plate press sludge was estimated by difference as the sludge was with-
drawn from the darifier on an irregular and infrequent basis.
In addition, a material balance was constructed from all the rinse waters and daily dumps to the
process drains and the feed to the wastewater treatment system over days 1 • 4. (This mass
balance primarily represents the rinsewaters as most of the dumps are carried out on day 5.)
Copper Inputs (kg)


Alkaline cleaner rinse
Microeteh rinse
Add rinse
Add rinse
Electroplating Line

Floor capture
Etch rinse
Oxide Area


Electroplating Line

Mircoetch rinse
Electroplate rinse
Etch rinse

Goooar Outputs Acq)
"¦pr"1 r*i(/

Treatment plant influent (total)
Step 13: Evaluating the Material Balance
Each material balance drawn up showed a good agreement considering the complexity of the printed
circuit board manufacturing plant and the large number of waste copper sources. Approximately 91
percent of the copper loading into the treatment plant during production days 1 - 4 was accounted for
by the measured wastewater sources. The extra 9 percent was probably due to copper being washed
from contaminated floor areas and further minor sources of copper which wctc not included in the
survey (eg gold plating line).

Case Study 3: Printed Circuit Board Manufacture
The following conclusions were made.
•	The microetch rinse accounted for approximately 90 percent of the total sensitising area
copper loading.
•	The microetch rinse accounted for approximately 56 percent of the plant's total rinsewater
copper loading on the treatment plant.
•	Other major sources of rinse water contamination were electroplating rinse, sulphuric/perox-
ide etch rinse and the deburrer (oxide area) rinse.

Step 14: Refining the Material Balance
The preliminary material balance work, while giving very satisfactory results, had included a
number of assumptions and estimates (by difference) had to be made; this particularly applied to
the oxide-coating and wastewater treatment areas. A decision was therefore made to refine the
material balance backing up the estimates by further monitoring and information gathering.
Step 15: Examining Obvious Waste Reduction Measures
From the information accumulated from the waste audit and observations which were made while
investigating the plant in detail a number of obvious waste reduction and efficiency improving
measures were identified. These again split into the four processing areas and the wastewater
treatment plant.
a)	Deburring operations (sensitising area)
It was noted that the sand filter associated with deburring operations was backwashed with
return (dirty) water which would lead to entraimnent of copper fines throughout the sand bed.
This could lead to fines being released into the filtered water. The deburred spray water had
a suspended solids concentration of 104 mg/1. This high concentration probably accounted for
the fine powder layer which was observed on the printed circuit boards after the deburrer
drier. While this only represented a small input of copper into the sensitising line (0.04 kg/
week), it created a potential adverse effect on product quality control
The waste copper fines which were collected on the backwash bag filter system (2.6 kg per
3 days production) are transported to a secure landfill site together with sludge cake from the
filter press. However, the fines are relatively pure copper and investigations confirmed them
to have a value of approximately US$0.9/kg corresponding to a small potential income of
USS275 per annum.
b)	The sensitising line (electroiess plating)
As discussed previously, the results of the wastewater characterisation showed that a very high
copper loading was from the microetch rinse (90 percent of the sensitising rinse water copper
load). The sensitising line is a manually-operated plating line and it was observed that no drip
time was used after the microetch. A one minute drip time was thus introduced and a moni-
toring programme initiated to record improved waste loadings. It was subsequently concluded
that a static-rinse drag-out tank should be installed in the longer term to reduce further the
running rinsewater loading from this source.
c)	Electroplating line
It was noted that the recirculation pumps on the copper electroplating line had leaking
mechanical seals leading to copper crystallisation on the pump shafts and surrounding floor
areas. This copper material was subsequently picked up by the developer rinse, which flowed
directly onto the floor, and discharged to the floor drain leading to Pit 12. The copper loading
from this source at one floor drain closed to the electroplate rinse was approximately 70 g/d.

Case Study 3: Printed Circuit Board Manufacture
It was considered that although this pollution load passing to a drain was small, a satisfactory
maintenance programme to prevent all such leaks and installation of drip trays and general
cleanliness in the copper electroplating areas could reduce this source of waste loading on the
treatment plant. Good housekeeping in all copper processing and handling areas could
prevent copper waste loading from other areas (eg copper etch and crystallisation) from
reaching the drain system.
d)	Oxide coating area
The rinsewater from the deburrer in the oxide coating area was discharged directly to the
process drain. A bag filter was attached to the pipe at the outlet to the drain but during the
in-plant study the capturing device was inefficient leading to significant quantities of copper
fines being released to the drain system. Contact with acid wastewaters would subsequently
dissolve the fines in the process drains. Using existing equipment stocks, a closed-loop
filtration system similar to the one in the sensitising area was added as a relatively simple
control measure, eliminating this source of waste copper.
e)	Wastewater treatment system
A number of inefficient operations in the wastewater treatment system were highlighted in the
waste audit. First, alum was added to the pH corrected (pH 8 J) wastewater in Pit 1. Alum is
an effective coagulant for colloidal material but is not necessary for metal hydroxide precipita-
tion and increases the volume of sludge produced.
Second, the existing sedimentation basin was of poor design. Inadequate sludge removal
capability and floating sludge were creating effluent discharge problems.
Third, in an effort to overcome the periodic high levels of copper being discharged to the
public sewer, two sand filters were installed in parallel after the sedimentation tank. However,
from the results in Figure 6 it can be seen that the sand filters were not effective in removing
suspended solids or copper from the wastewater.
Assuming a SO percent reduction of copper loading from the sensitising microetch rinse
through improved rinsing, and elimination of the copper loading from the deburrers and
electroplating area floor drain, a 40 percent reduction in rinsewater loading to the wastewater
treatment plant could be achieved.
Step 16: Targeting and Characterizing Problem Wastes
From Figure 6 it can be seen that the sand filter input concentrations of suspended solids and
copper are approximately equal to the output concentrations from the filter. Furthermore, the
copper discharged to the public sewer was primarily dissolved (75 • 95 percent of total copper
concentration) and in excess of the sewer discharge limits on days 2 and 5. Previous experience
with the treatability of the printed circuit board wastewaters had established that the electroless
copper wastewaters were particularly difficult to treat because of the presence of chelating agents

Case Study 3: Printed Circuit Board Manufacture
in the electroless copper plating solution. In addition, chelating agents were present in the resist
stripping solution. It was noted that when the treated resist strip was dumped to Pit 2 on days 2
and- 4, significantly higher copper concentrations were observed in the discharge to the public
sewer than on days 1 and 3. Day 5 (Friday) represents an atypical waste treatment day as weekly
dumping of tanks in the sensitising and oxide areas occurs on this day.
The chelate containing copper wastewater and combinations of copper and chelate containing
wastewaters were therefore considered to be 'problem wastes'.
Wastewater treatability tests using alum, sodium hydroxide, lime and a range of flocculants were
conducted on samples from each individual pollutant source and on combined samples. The tests
indicated that most copper containing wastewaters could be treated very successfully by metal
hydroxide precipitation. However, the chelating agents in the electroless rinse and resist strip
rinse affected copper hydroxide precipitation and should therefore be segregated and treated
As indicated in Table 1, the tests on the influent wastewater treatment plant indicated that copper
could be reduced from relatively high concentrations to less than the 5 mg/1 standard using lime
and anionic polymer flocculant. In general, lime produced a more dense and settleable precipi-
tate than sodium hydroxide although it generated more sludge.

Case Study 3: Printed Circuit Board Manufacture
Table 1: Treatability Tests using Lime and Anionic Polymer
Total Copper in

Supernatant (mg/1)

Microeteh rinse

Electro less rinse

Electroplating Line

Microeteh rinse

Copper electroplate rinse

Copper electroplate rinse
Resist strip rinse (50:50)
Bectroplate floor drain

Sulphuric/peroxide etch rinse

Oxide Coating

Microeteh rinse

Wastewater Treatment

11 74 13 73 8.4"

0.4 0.6 0.4 4.0 0.7
•Hourly spot samples
Step 17: Segregation
It was clear from the findings of the waste audit investigations that waste segregation would form
a necessary part of any long-term waste reduction programme in order to develop a technically
satisfactory and cost-effective system. This aspect will be described in Step 18 below.
Step 18: Developing Long-Term Waste Reduction Options
While the waste reduction alternatives described in Step 15 will reduce pollutant loadings and
result in significant cost savings, an efficiently designed and operated end-of-pipe treatment

Caaa Study 3: Printed Circuit Board Manufacture
section describes the wastewater treatment and recovery system design which was developed from
the waste audit and treatability studies with the assistance of a consultant engineering company.
The major points for consideration in the system design were as follows.
•	Segregation of all the chelate-containing wastewaters from the conventional metal hydroxide
precipitation system.
•	Segregation and separate treatment/recovery of all the chelate-containing rinsewaters and
concentrated bath-dumps.
•	Collection of all general bath dumps (non-chelate containing) in a holding tank for metering
back to the conventional treatment system at a controlled rate (to prevent surges in copper
•	Upgrading of existing pH adjustment, polymer addition, clarification and sand filtration
systems for efficient metal hydroxide precipitation and subsequent discharge of high quality
Information on the type of chelator or chelate concentration was not readily available from the
chemical suppliers.
The sources of chelate containing wastewaters were as follows:
Flowrate (l/h)
Copper Concentration

or Volume (litres)
Mild Alkaline Cleaner Bath
400 litres
Mild Alkaline Cleaner Rinse
518 litres
0.8 (max 1.7 mg/l)
Electroless Plating Bath
5SB litres
Bectrotoss Plating Bleed
10 l/h
Electroless Plating Rinse
770 l/h
7.7 (max 10.3 mg/l)
Resist Strip Bath
920 litres
Lms than 5.0
Resist Strip Rinse
390 l/h

The proposed treatment system incorporates the following key elements.
•	Collection of all non-complexed rinsewaters in a common sump for pH adjustment with
caustic (or lime) to pH 9.0 • 9 J.
•	Installation of a static-rinse tank after the electroless copper plating bath. The static-rinse
tank will collect most of the drag-out loading from the electroless plating bath and will
then be dumped daily for electrolytic recovery. The subsequent continuous-flow rinsewater
(chelate-containing), operated on a counter-current principle, will then be discharged
directly to the public sewer.
•	Segregation, cartridge filtration and direct discharge of resist strip rinsewaters (chelate-
containing) to the clarified water storage tank.
•	Segregation and direct discharge of electroless plating running rinsewaters and cleaner
rinsewaters (chelate-containing) to the clarified water storage tank.

Case Study 3: Printed Circuit Board Manufacture
ion exchange unit) segregation pumping and piping, instrumentation and control and 40 m2
building was US$265,000. However, considering the company's history of pollution problems, the
impending legal action and the amount of time being spent by senior personnel on day to day
waste management problems, the implementation of the waste segregation and treatment/recov-
ery system could be considered money well spent and an investment for the future.
Step 20. Developing and Implementing an Action Plan: Reducing
Wastes and Increasing Production Efficiency
The results of the waste audit and the waste reduction/treatment studies were presented to the
company's management and plans were made to implement the recommended waste reduction
measures and the treatment/recovery system.
The waste audit-reduction approach achieved the following objectives.
•	A sound understanding of all the sources of waste copper at the manufacturing plant.
•	Identification and quantification of the major sources of waste copper.
•	Evaluation of processing efficiencies from assembled information on unit processes,
raw materials, water usage, products and waste generation.
•	Identification of waste reduction opportunities.
•	Elimination of some wastes and associated disposal problems.
•	Identification of problem wastes requiring special attention.
•	The development of a cost-effective, integrated waste segregation and wastewater treat-
ment/recovery system.
•	The development of a waste management system which would comply with discharge
regulations and result in improved public relations.


Wastewater Flow Measurements
This section describes simple methods of measuring flows in open channels using triangular-
notch (V-notch) or rectangular thin-plate weirs.
The discharge over thin-plate weirs is a function of the depth (head) of liquid on the weir, the
size and shape of the discharge area, and an experimentally determined coefficient.
Thin-plate weirs should be vertical and perpendicular to the walls of the channel, constructed
in steel, wood or similar smooth-surfaced robust material.
The intersection of the weir plate with the walls and floor of the channel should be watertight
and firm, putty or other suitable material being used as a sealant as appropriate. Weirs are
best installed under no-flow conditions to ensure that a good seal is obtained. Where wastewater
flows normally arise 24 hours per day, 7 days per week, this can create problems unless produc-
tion can be temporarily stopped. In such circumstances, the weir should at least be installed
under low-flow conditions in order to facilitate the installation procedure and to minimise
risk of leaks around or under the weir occurring.
In general, the weir should be located in a straight, horizontal, rectangular channel if
possible. Ideally the length of the approach channel should not be less than 10 times the width of
the jet (nappe) formed by the flow over the weir at maximum head.
The shape and size of the channel downstream from the weir is of no significance, but the level
of the water in the downstream channel should be a sufficient vertical distance below the crest
to ensure free, fully-ventilated discharges.
V-notch weirs permit the accurate measurement of much lower discharges than do rectangu-
lar weirs. Also, the discharge over a V-notch increases more rapidly with the head than in the
case of a rectangular weir. Thus, where flow variations over a working day are large, use of a
triangular-notch (V-notch) weir is preferable. For large flows however, a broad-crested rectan-
gular weir may be necessary.
Where significant suspended solids are present, care should be taken to ensure that there is
no accumulation of floating debris or settled solids behind the weir at the time of water level
(head) measurement.
Triangular-Notch (V-notch) Weirs
The triangular weir consists of a symmetrical V-shaped notch in a vertical thin plate. A dia-
grammatic illustration is shown in Figure A.
The bisector of the notch should be vertical and equidistant from the two walls of the channel.

Appendix 1: Wastewater and Gas Flow Measurement Methods
Figure A: Triangular-notch, thin-plate weir
The plane surfaces of the notch should form sharp edges at their intersection with the upstream
face of the weir plate. The width of the notch surfaces, measured perpendicular to the face
of the plate, should be 1-2 mm. The downstream edges of the notch should be chamfered if the
weir plate is thicker than 2 mm, the maximum allowable width of the notch surface. The
surface of the chamfer should make an angle of not less than 45° with the surface of the notch.
An appropriate formula, the Kindsvatcr-Shen formula, for all notch angles (GC) between
20° and 100° degrees is:
Q = Ce15V2gtan?he5/2
where Q = wastewater flow in cubic metres per second
Ce = coefficient of discharge (non-dimensional)
g = acceleration due to gravity, =¦ 9.81 metres per second squared
a = the notch angle included between the sides of the notch, in degrees
he = the measured head over the weir, in metres
= h (measured head) + (which compensates for the combined effects
of viscosity and surface tension)
Also, p " the height of the weir crest above the upstream channel bed; and B = channel
width at the weir section (ref. Figure A).
The factor kh is small and can be ignored for all practical purposes with only minimal loss of
accuracy; hence he can be assumed to equal h.

Appendix 1: Wastewater and Gas Flow Measurement Methods
Ce is a function of the three variables • h/p, p/B and (X. For most purposes, use of a stand-
ard value of 0.6 will give sufficient accuracy. For further information on the small varia-
tions of Ce under different weir conditions, reference may be made to the International Stand-
ard 'Water Flow Measurement in Open Channels using Weirs and Venturi Flumes', ISO 1438/1,
The V-notch weir formula can therefore be simplified to:
Q = 1.42 tan 2h5/2
For reasons related to measurement-error and lack of experimental data, limitations applicable
to the use of this formula are:
•	h/p limited to the range 0.1-2.0 for a 90° V-notch, and not greater than 35 for all other
angles within the range 20°-100°;
•	p/B limited to 0.1-1.0 for a 90° V-notch, and 0.1-1.5 for other values of (X;
•	h not less than 0.06 metres;
•	p not less than 0.09 metres.
In the absence of continuous level recording equipment (which may be of a type which auto-
matically records levels as flow for a given weir type and size), weir height readings may be
taken using a calibrated dipstick positioned in the centre of the channel upstream of the
weir, away from the immediate point of turbulence at the weir. The location of the dipstick
will be satisfactory if it is at a distance equal to 4-5 times the	anticipated head (4-5
h„.J upstream from the weir.
With the bottom of the dipstick in contact with the base of the channel, the depth of immer-
sion at any one point in time will equal h + p. Knowing p, h can then be calculated by differ-
ence and inserted into the weir formula to obtain the corresponding flow rate (Q).
Alternatively, it is recommended that a calibration curve be drawn up for any one weir size
for a range of h values and corresponding Q values. This should be done before commencing
flow measurement work so that Q values can be assessed quickly from the graph as soon as
values of h are recorded.
Level/flow rate measurements should be taken at least once per hour. More frequent meas-
urements may be necessary depending on the pattern of flows experienced. The data can then
be assessed to give an average daily flow (m3/d) as well as an indication of minimum and maxi-
mum instantaneous discharge rates.

Appendix 1: Wastewater and Gas Flow Measurement Methods
Rectangular Weirs
A rectangular thin-plate weir is a general classification in which the rectangular-notch weir is the
basic form and the full-width weir is a limiting case.
A diagrammatic illustration is shown in Figure B with intermediate values of b/B and h/p. When
b/B = 1, that is, when the width of the weir (b) is equal to the width of the channel at the
weir section (B), the weir is a full-width weir type (also referred to as a 'suppressed' weir, be-
cause its nappe lacks side contractions).
where Q ¦= wastewater flow in cubic metres per second
Ce = coefficient of discharge (non-dimensional)
g = acceleration due to gravity, = 9.81 metres per second squared
be = the effective width in metres
= b (measured width) + 1^ (which compensates for the combined effects of
viscosity and surface tension)
h( = the measured head over the weir, in metres
= h (measured head) + (compensating factor similar to kj )
Also, as for V-notch weirs, p = the height of the weir crest above the upstream chan-
nel bed; and B = channel width at the weir section (refer to Figure B).
Figure B: Rectangular-notch, thin-plate weir
A formula for rectangular weirs (the Kindsvater-Carter formula) is as follows:

Appendix 1: Wastewater and Gas Flow Measurement Methods
The factors 1^ and kh are small and can be ignored for all practical purposes with only minimal
loss of accuracy, hence b£ and h( can be assumed to equal b and h respectively.
For rectangular weirs, Ce is a function of the two variables - h/p, p/B. As for V-notch weirs,
use of a standard value of 0.6 will give sufficient accuracy in most cases.
The rectangular weir formula can therefore be simplified to:
Q = 1.77 b hw
For conservative practice, limitations applicable to the use of this formula are:
e h/p not greater than 2J;
•	h not less than 0.03 metres;
•	b not less than 0.15 metres;
•	p not less than 0.1 metres;
•	either (B-b)/2 = 0 (weir full width of channel) or
(B-b)/2 is not less than 0.1 metres (concentrated weir).
As in the case of V-notch weirs, the location of the head-measurement section will be
satisfactory if it is at a distance equal to 4-5 times the maximum anticipated head (4-5 h^)
upstream from the weir.
Gas Flow Measurements
In the course of gathering gas flow data for environmental control or a waste audit, flow measur-
ing equipment is often lacking, or the velocity of the gaseous emission is too low for measure-
ment Even when the velocity is high enough for meter methods, the geometry of the system
may make the measurement difficult or subject to error. Consequently, a method is needed
for a quick and fairly accurate measurement of gas flow, that can be operated without the use of
expensive or time-consuming installations.
In most cases the following method will work (or serve as a valid double-check) if only the gas
can be made to flow through an accessible open-ended pipe or duct; it has been developed by
the Chesapeake Corporation, Virginia, USA.

Appendix 1: Wastewater and Gas Flow Measurement Methods
A plastic bag with a hole cut in it is placed over the end of the pipe or duct, causing a 
Appendix 1: Wastewater and Gas Flow Measurement Methods
The simplified formula is as follows:
0 = 0.00257 DVh/p
where Q <= gas flow in litres per second (to within ±4%)
D = the orifice diameter in millimetres
h = the pressure drop in millimetres
p = the gas density at the gas temperature in grammes per litre
In selecting a suitable orifice size, a pressure drop of 25-100 mm water gauge should be sought.
Less ~*"»" 25 mm is difficult to measure, and greater than 100 mm may make the bag slip off
the pipe. If a rough estimate of the gas flow is known, the hole diameter (mm), necessary to
produce a pressure drop of 63 mm, is approximately:
D - 7.65VQ
Several features of the design can minimis error. These are as follows.
e The position of the manometer probe should project slightly through the bag wall, so that
the axes of the vent pipe, the bag orifice and the probe end are all perpendicular (ref. Figure
C), and so that a true indication of static pressure can be obtained.
e The bag should be large enough to minimise the effects of approach velocity and to pre-
vent flapping or tearing.
•	The orifice diameter should be measured during operation, so as to obtain true operating
dimensions; if stretching causes an elliptical orifice, the area should be based on the
product of the major and minor axes.
•	Thin-walled bags, high temperatures and high velocities should be avoided since fluting
outward of the orifice edges will tend to occur; when pronounced, the effect would be to
increase the discharge coefficient as the shape of the orifice approaches that of a nozzle.
Finally, when members of the waste audit team make a bag orifice measurement, it is important to
ensure that adequate steps are taken to prevent burns or fumigation.

BODs: biochemical oxygen demand; a measure of the quantity of dissolved oxygen consumed by
microorganisms as a result of breakdown of biodegradable organic constituents. The standard
test is carried out at 20°C over a S-day period.
By«Product: a secondary or incidental product of a manufacturing process.
Catalyst: a substance that increases the rate of a chemical reaction without itself undergoing any
permanent change.
COD: chemical oxygen demand; a measure of the quantity of dissolved oxygen consumed during
chemical oxidation of wastewater with potassium dichromate.
Counter-Current Rinsing: the introduction of water or a solvent in the opposite direction to the
product flow.
Discharge Points: this term refers to the points of exit for wastewater leaving the site. A dis-
charge point may also refer to the place where an incoming tanker discharges a load.
Drainage: refers to the effluent collection system on a site.
Emission: an emission usually refers to fugitive or waste discharges from a process. Emissions
are traditionally associated with atmospheric discharges. All such discharges are termed waste
within the context of this manual.
Energy Audit: a quantitative account of the energy inputs and outputs to and from a unit opera-
tion, a process, a plant or an industry.
Gaseous Emissions: gaseous emissions can be classified into several categories; pure gases or
vapours, combinations of gases and solids, combinations of gases and liquids and combinations of
gases, liquids and solids. The last three categories are considered to be gaseous emissions
because the gas is the carrier for the solid or liquid phase.
Material Balance: a precise account of all the inputs and outputs of a process, based on the law of
conservation of mass.
Monitoring Programme: a monitoring programme that describes a timetable for regular sam-
pling and testing of equipment, pumps, products, wastes and general operations to ensure that
any deviations from the norm are noticed and can be rectified before problems result.
Operating Costs: also known as variable or running costs; they refer to costs which vary directly
with the rate of output, for example labour costs, raw material costs, fuel, power, etc.

Appendix 2: Glossary
Plant: in the context of this manual a plant refers to the factory site. A plant may comprise a
number of processes, administration buildings, site waste treatment facilities, site storage facili-
ties, etc
Pollution: the term describes the presence of harmful, hazardous or detrimental constituents in
an environment. A polluted environment describes a state that occurs when the assimilative
capacity of the environment is exceeded, resulting in undesirable ecological changes.
Process: in the context of this manual a process is taken to include all operations involved in
production. Therefore, a process may begin with receipt of raw materials, storage and handling
through process technology to product handling and waste treatment.
Process Flow Diagram (PFD): an essential tool in developing an organised diagrammatic presen-
tation of a process.
Process Inputs: defined as one half of the material balance equation. Inputs to a process may
comprise raw materials, water, energy, etc. -
Process Outputs: the second half of the material balance equation. Outputs from a process may
include a product, a by-product, wastewater, gaseous, liquid and solid wastes, heat, etc.
Product: the useful material output from a process.
Purchasing Records: documentation of invoiced purchases.
Raw Material: a material on which a particular manufacturing process is carried out
Recovery: waste minimisation can be achieved by recovering valuable material from a waste. For
example, draning solvent can be recovered from waste oiL Recovery often involves advanced
technology such as ultrafiltration or reverse osmosis, although simple settlement can separate oil
and water solutions.
Recycle: this term represents an important aspect of waste minimisation. The recycling of wastes
within a process often reduces the fresh material input requirement. For example, a solvent used
for cleaning engine parts can often be used twice before its cleansing power is exhausted.
Reuse: this is an important consideration in waste minimisation. If a waste cannot be reduced
can it be reused? Reuse represents a secondary line of action in a waste reduction plan.
Segregation: the term segregation refers to isolating hazardous and/or strong wastes from less
polluting wastes. For example, uncontaminated surface drainage should be collected in a sepa-
rate system from contaminated effluents from process areas. If the two wastes are not segregated
the volume of wastewater requiring treatment is greater.

. Appendix 2: Glossary
Services: in the context of this manual the term services is taken to mean supporting facilities
such as a power supply.
Stockpile: refers to solid material such as coal or gravel stored outside on the ground. Stockpiling
should comply with legislation to minimise pollution.
Stoichiometric Estimations: mass or concentration calculations based on the exact molecular
relationship between constituent elements, taking into consideration atomic and molecular
Unit Operation: a process will comprise a series of unit operations. A unit operation may be
pulping or bark stripping in a pulp and paper mill, or distillation in a chemical manufacturing
process. Unit operations may be intermittent such as tank washing and steam cleaning.
Waste: in the context of this manual waste is taken as a broad term to cover any non-product
discharge from a process. Thus, it describes discharges in the gaseous, liquid and solid phases.
Waste Audit: a waste audit is a thorough account of the wastes from an industry, a plant, a
process or a unit operation. A waste audit requires the derivation of a material balance for each
scale of operation. The waste audit should result in the identification of wastes, their origin,
quantity, composition and their potential for reduction.
Waste Reduction Plan: a waste reduction plan should include a series of scheduled actions to be
undertaken with the overall aim of reducing the amount of waste generated.
Wastewater the aqueous effluents from a process that pass to drain or to storage.
Wet Scrubber pollution control equipment designed to treat off-gases. A wet scrubber will
involve water or a chemical solution to strip certain gases from the gaseous phase before dis-
charge to atmosphere. The wet component may be a once-through scrub or a recirculating
solution (with a bleed to drain), the solution strength needing to be topped-up either continuously
or periodically.

(a)	References used in the Preparation of this Manual
Rapid Assessment of Sources of Air, Water and Land Pollution, WHO Offset Publication
No 62, World Health Organization, Geneva, 1982.
Profiting from Waste Reduction in Your Small Business: a guide to help you identify,
implement and evaluate an industrial waste reduction program, D Wigglesworth, Alaska
Health Project, 1988.
Towards Zero Waste: 101 Waste Busting Hps, Orr & Boss, Michigan, USA, 1991.
Prepare Manual: A Manual for the Prevention of Waste and Emissions, Dutch Ministry of
Economic Affairs, June 1991.
CEF1C Guidelines on Waste Minimisation, European Chemical Industry Federation,
CEF1C, 1990.
Calculation and Shortcut Deskbook, published by Chemical Engineering, USA.
Water Flow Measurement in Open Channels using Weirs and Venturi Flumes, ISO 1438/L,
1980. International Organization for Standardization (ISO).
Industrial Waste Audit and Reduction Manual, Ontario Waste Management Corporation
(OWMC), Canada, Second Edition July 1989.
(b)	Environmental Management in Industry
Environmental Auditing, Technical Report Series No 2, UNEP/1EO, 1990.
Environmental Auditing • special issue of'Industry and Environment', Vol 11, No 4,1988,
Environmental Auditing in Cleaner Production Strategies, Seminar Proceedings, April
1991, Dept of Industrial Environmental Economics, Lund University, Sweden.
Our Common Future, World Commission on Environment and Development, Oxford
University Press, 1987.
Business and the Environment, G Winter, McGraw-Hill, 1987.
Environmental Guidelines for World Industry, 1990, International Chamber of Commerce,
38, Cours Albert ler, 75008, Paris.

Appendix 3: FWtranow
Environmental Impact Assessment • Bask Procedures for Developing Countries, UNEP,
(c) Qeaner Production and Pollution Prevention
Waste Minimization Opportunities Assessment Manual, US EPA, 1988.
Techniques for Industrial Pollution Prevention, M R Overcash, Lewis Publishers, 1986.
Profit from Pollution Prevention, M E CampbeD and W M Glenn, Pollution Probe Foun-
dation, Toronto, 1981
Prosperity without Pollution • the Prevention Strategy for Industry and Consumers, JS
Hirschhorn and K U Oldenburg, Van Nostrand Reinhold, 1991.
Tanneries and the Environment - A Technical Guide to Reducing the Impact of Tannery
Operations, Technical Report Series No 4, UNEP/IEO, 1991.
Environmental Aspects of the Metal Finishing Industry - A Technical Guide, Technical
Report Series No 1, UNEP/IEO, 1989.
The Storage of Hazardous Materials - A Guide to Safe Warehousing of Hazardous
Materials, Technical Report Series No 3, UNEP/IEO, 1990. (Available in Fngfali and
(d) Training Materials
Environmental Management Training (5 Vols), joint UNEP - ILO publication, 1986.
The Competitive Edge', video by Ontario Waste Management Corporation, Canada.
*MoacgrDonn> the Drain', video by Ontario Waste Management Corporation, fnnaHn
Trepan tor Tomorrow*, video for the Prepare Project, NOTA, The Netherlands.
ToOution Prevention • The Bottom Line', a video by Coastal Video Communications
Corporation, USA.
ToOution Prevention - Reducing Wastes in the Workplace', a video by Coastal Video
Communications Corporation, USA.

Appendix 3: References
(e) Information Systems/Bulletins/Newsletters
"Cleaner Production', a biannual newsletter of the Cleaner Production Programme of
international Geaner Production Information Gearinghoase (ICPIC), an on-line, compu-
ter-based information service, UNEP/IEO (see this manual, Appendix 4).
NETT, a network for environmental technology transfer, Ave Louise 207, Box 10, Brussels,

Recognising the need to prevent pollution and minimise waste, the UNEP Governing Council, in
May 1989, look Decision 37 urging UNEP 'to continue its catalytic role to promote, with govern-
ments industry, research organisations and other relevant institutions, the establishment of a
network which will allow the transfer of environmental protection technology'.
To implement this decision, the UNEP Industry and Environment Office (IEO) convened a
group of 23 senior level experts from various countries and international organisations for advice
on the steps to be taken. Their recommendations led to the establishment of the UNEP/IEO
Cleaner Production Programme. The Programme links existing sources of information on low
and non-waste technologies and promotes cleaner production worldwide through four primary
activities: the International Cleaner Production Clearinghouse (ICPIC), expert working groups, a
newsletter, and training activities.
(a)	Working Groups
Working Groups are composed of experts who seek to identify cleaner production methods in
specific industries (leather-tanning, textile, solvent, metal-finishing and pulp and paper industries),
and to identify other experts and some working publications. Groups also cover wider issues, such
as data networking, education and policies promoting cleaner production.
(b)	Gamer Production Newsletter
The newsletter includes news and information on cleaner technologies and products, and steps
taken by governments and organisations to promote cleaner production.
The newsletter is available in English, French and Spanish.
(c)	International Qeaner Production Information Qearinffiouse - ICPIC
This computer-based information exchange holds over 600 case studies and programme summa-
ries, a directory of experts and an extensive bibliography. The system can be accessed by users in
more than 100 countries.
(d)	Training Activities
In order to support the initiation and development of national cleaner production programmes in
different regions of the world UNEP/IEO organises workshops and seminars.
The International Cleaner Production Information Clearinghouse - ICPIC
ICPIC contains information on cleaner production methods, and on industries using such technolo-
gies. It also acts as a pointer to more detailed sources of information. ICPIC was established in
cooperation with the US EPA and is based on their Pollution Prevention Information Exchange
System PIES. Data are also contributed by users • either individuals or organisations • of the ICPIC

Appendix 4: UNEP/IEO CtMnar Production Programme
In addition to the mam database, the ICPIC system incorporates an interactive message centre where
users can leave information and questions for other network users. Also listed are bulletins concern-
ing developments in the field of deaner production, and subsidiary databases on individual subjects.
The main databases contain;
Message Centre
An on-line feature allowing communication with other network members.
Latest news and announcements in the international clean technology community.
Calendar of Events
Listing of upcoming national and international conferences, training seminars and workshops.
Case Studies
A database of technical and programme case studies highlighting industry and waste involved,
economic incentives and cost recovery time.
Programme Summaries
Descriptions of national and international programmes on deaner production, as weD as
programmes adopted by industries.
On-line Bibliography
A bibliography of hundreds of dean technology documents, with information for ordering.
Directoty of Contacts
An automated version of UNEFs Cleaner Production Directory.

Appendix 4: UNEP/IEO Cleaner Production Programme
Twenty-four hour access is free of charge to individuals and organisations with an Apple, an
IBM-compatible computer or a terminal equipped with a modem (2400 baud or less) and
appropriate communication software. The system can be connected either through direct
telephone lines, or through Telenet data-packet switching network.
Different ways to access the system:
•	via direct dial, set your software to 8 data bits, 1 stop bit, no parity and telephone number
to 33-1-40 58 88 78 - omitting country and city code as appropriate if calling from France;
•	directly via SPRINTNET (Telenet) by telephoning local Telenet access node and enter
access code 762 006 04000;
•	if connecting indirectly via another packet switching network, the Telenet and ICPIC
access code is 3110 762 006 0400. In the latter case, the software settings may be different
and dictated by the network being used.
Contact UNEP/IEO or US-Sprint to find out your local Telenet service address of national-
packet switching networks appropriate to access ICPIC A list of packet-switching networks
which allow you to connect ICPIC via Telenet is also available in the ICPIC User Guide
available from IEO.
Further information from UNEP/IEO by faxing 33-140 58 88 74.

Step I prepare and organise audit team and resources
Step 2 divide process into unit operations
Step 3 construct process flow diagrams linking unit operations

The Industry and Environment Office (IEO) was established by UNEP in 1975 to bring industry
and government together to promote environmentally sound industrial development. The IEO is
located in Paris. Its goals are:
(1)	to encourage the incorporation of environmental criteria in industrial development plans;
(2)	to facilitate the implementation of procedures and principles for the protection of the
(3)	to promote the use of safe and 'clean* technologies;
(4)	to stimulate the	of information and experience throughout the world.
IEO provides access to practical information and develops co-operative on-site action and
information exchange backed by regular follow-up and assessment. To promote the transfer of
information and the sharing of knowledge and experience, IEO has developed three complemen-
tary tools: technical reviews and guidelines, 'Industry and Environment' review; and a technical
query-response service. In keeping with its emphasis on technical co-operation, IEO facilitates
technology transfer and the implementation of practices to safeguard the environment through
promoting awareness and interaction, training activities and diagnostic studies.
Some recent UNEP/IEO publications
Industry and Environment Review (quarterly), ISSN 0378-9993. Issues deal with topics such as:
hazardous waste management, technological accidents, environmental auditing, industry specific
problems, environmental news.
Environmental Aspects of the Metal Finishing Industry - A Technical Guide, Technical Report
Series N° 1, ISBN 92 80712160,91 p, 1989.
Environmental Auditing, Technical Report Series N° 2, ISBN 92 80712535,125 p, 1990.
Storage of Hazardous Materials - A Technical Guide for Safe Warehousing of Hazardous Materi-
als, Technical Report Series N° 3, ISBN 92 80712381,80 p, 1990.
Directory of Information Sources on Air and Water Pollution • INFOTERRA/IEO, ISBN 92 807
12330,387 p, 1989.
APELL - Awareness and Preparedness for Emergencies at Local Level: a Process for Respond-
ing to Technological Accidents, ISBN 92 80711830,62 p, 1988.
Tanning and the Environment • A Technical Guide to Reducing the Environmental Impact of
Tannery Operations, Technical Report Series N° 4, UNEP/IEO, ISBN 92 80712764, HOp, 1991.

As the lead agency for industrial development in the United Nations system, UNIDO is closely
involved in the growing international co-operation on industry-related environmental matters. In
mid-1990 UNIDO consolidated its various environmental activities under the umbrella of the
UNIDO Environment Programme. UNIDO is well placed to transfer new technologies and
cleaner production processes to developing countries in such important sectors as leather,
cement, textiles, food processing, metal working, iron and steel, and others. Its assistance takes
such forms as technical projects, provision of equipment and/or advisory services, investment
promotion schemes, human resource development through training and fellowships.
The immediate emphasis of the UNIDO Environment Programme is on: (1) incorporating
environmental considerations into the activities of UNIDO; (2)	the awareness of
developing countries of the need to include environmental considerations in their industrial plants
and policies; and (3) assisting developing countries to prevent and cure the effects of environmen-
tal degradation attributable to industry through practical technical	projects and other
activities such as cleaner technologies and processes, environmental audits, environmental impact
assessments, energy efficiency, studies and technical reports, and provision of training and
information. Specific support can also be given in design, installation and operation of indiisfrial
pollution abatement facilities.
Inquiries about UNIDO's programmes can be channelled through UNDP offices in developing
countries, or sent directly to UNIDO headquarters, P O Box 300, A-1400 Vienna, Austria.

IV. International P2

A. EP3 Clearinghouse

sponsored by
U.S. Agency for International Development


Pollution Prevention

The Use of Processes, Practices, or
Products That
•	Reduce or Eliminate the Generation of
Pollutants or Wastes at the Source
•	Protect Natural Resources Through
Conservation or Increased Efficiency
~	Improved Employee
Morale, Safety, and Health
~	Enhanced Public Image
~	Improved Public Health
and Environment
~	Reduced Liability
Investment With "Payback"
Improved Manufacturing Efficiency and
Product Quality
Reduced Operating

Transfer Pollution Prevention
Expertise and Information
Develop Sustainable Country
Support Efforts to Improve
Environmental Quality

Assistance to
Industry and
Urban Sector

Technical Assistance to Industry
and Urban Sector
Use U.S. Pollution Prevention and Industry
Experts to Conduct Diagnostic Assessments/
Select Industries That Can Benefit From Pollution
-	Tanning
-	Textiles
-	Metal Finishing
-	Others
Provide Ongoing Assistance for Implementing
Pollution Prevention Measures

EP3 Training and Outreach
•	Develop Materials, Courses, Tools, and Data
•	Train Government, Industry, and Urban
•	Provide Study
Tours and Other
U.S. Opportunities
•	Train Core
Staff In-Country
So They Can
Train Others

EP3 Information Clearinghouse
•	Furnish Information on Pollution
•	Provide Access to Vendors of
Prevention Equipment and
•	Inform on Conferences
and Training
•	Set Up and Support
In-Country Clearinghouses

Assessments and Ongoing Assistance to Industry
and Urban Sector
Policy and Institutional Support to Governments
• Worldwide
Network of

Environmental Strategies
Feasibility Analysis
Environmental Project
Development Support

In-Country Governments
Urban Sector

Bailly &
16 Subs


EP3 is Using a Tripartite Approach to Implement EP3 and
Encourage Sustainable Country Programs

Water Environmental Federation/
EP3 Partnership
Accessing Pro Bono Expertise
EP3 Advisory Board
Specific Industrial Sectors
and Facilities
State, County and Local Government
Professional Associations
Academic Institutions
Non-Profit Organizations

•	Tunisia
•	Chile
•	Other Program Initiatives

•	Rapid Industrial Growth
•	Unsustainable
Development Practices
•	Commitment to
•	Efforts to Develop
T 42009-1-17

-	Establish EP3 Office to Manage
-	In-Country Staff Provide Technical
Assistance, Training, and Information
Activities Underway
-	First Assessment Completed and More Are
-	Regional Workshops for Industry and
-	Training Courses Planned
-	In-Country Clearinghouse Established
-	Cooperative Agreements with Government,
Industry Associations, and NGOs

-	Build In-Country Capability by Using
Chilean Consultants and Firms
-	Establish Partnerships Between AID
and American Chilean Chamber of
4 Audits Completed and More Are
-	Two Tanneries, Two Textile Dyeing
-	Results Have Generated Increased

Sri Lanka
Indonesia *
	 »- * s t	?' i . > 5;
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•	Environmental Strategy in India
•	Evaluation of
Potential Projects
in Eastern Europe
pa | jft wmmm	mm	¦
•	EIA Training in
•	Environmental
Assessment in

•	The existence of a group of individuals (or
one or more organizations) who are
committed to pollution prevention and who
have credibility with local industrial, urban,
and government decision makers
•	A set of agreed to goals and measures of
accomplishment leading to a sustainable
local pollution prevention program
•	Examples of leadership and excellence in
pollution prevention practice
T42009 1-30

B. UNEP Cleaner
Production Program