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From another "closet enforcer"
When it comes to spending money on the Environment, most facility managers
have always questioned why are we doing this? Especially if
there are no clear regulatory requirements. TCEQ has a regulatory
requirement that forced many industries/companies to develop P2
plans. Without this regulation, P2 planning in Texas would not be as
widespread. If the regulation had more teeth, more P2
would have been implemented; unfortunately over time the
regualtion just became a paper exercise (I don't think there ahve been
any enforcemnt actions that resulted in a fine). If implementation of the
P2 plans was enforced, more P2 would have occurred.
P2 projects still get implemented without regulations if they
have really good paybacks; unfortunately, most low-hanging fruit has been
taken and remaining P2 projects may not be the best investment, especially
when competing with other projects that have equal or better returns on
investment.
In my opinion, environmental regulations provide the trump card
during the cost benefit analysis phase of a P2 project evaluation,
especially if implementation of a P2 project results in the
elimination/reduction of a regulatory burden.
Case Study:
Chlorine is widely used for industrial water treatment, it
is cheap to use, works well, and is familiar to all water chemistry
staff. One big problem, it has the potential
to significantly impact human health and the
environment. Many years ago, there were several products that
could have been used as a substitute for chlorine usage, but there was little
regulatory pressure to cause change. Despite readily available
replacements for chlorine and the potential risk to human health, the
project was not implemented. Several years ago, EPA rules
were put in place that addressed this issue. The rules required facilities
that used chlorine to develop Risk Management Plans (RMPS). The RMPs
defined the extent of a maximum release plume
and required facilities to identify and notify all
residential/commercial entities located within the area of the maximum release
plume. In addition, the facility was required to provide employee training
to all personnel associated with the chlorine process. With
regulations in place, and re-occurring compliance costs, the facility once again
looked at substituting chlorine with a less toxic product. The
cost benefit study was still the same as before; however, the added benefit of
getting out of the RMP requirements provided the incentives necessary to
cause change. The facility now in the process of converting to
a liquid bleach and is exempt from RMP
requirements. Management celebrated the reduction in
compliance/training costs.
The celebration should have been the elimination of a potential
catastrophic chlorine release (120 people in the community and 400 employees
were no longer at risk). The risk was eliminated by employing
the common P2 practice of product
substitution.
Environmental regulations can drive P2 more than any other factor -
conversely if not written correctly, they can also prevent P2 more than any
other factor as they commonly prescribe specific control technologies.
Mark L. Johnson, PMP., CPEA.
Senior Environmental Coordinator Lower Colorado River Authority Email: mark.johnson@lcra.org Phone (512) 473- 3200 ext 2868 Fax: (512) 473-3579 Fax (512) 473-3579 >>> "Melinda Dower" <Melinda.Dower@dep.state.nj.us> 12/17/02 08:00AM >>> Having been a "closet enforcer" for many years, I am heartened to see everyone's conclusions about the limited effectiveness of voluntary programs--I feel like I can come out of the closet now. Even here in NJ, where P2 Planning is mandatory but implementation of P2 measures is voluntary, I have had numerous corporate representatives comment that they would be implementing much more P2 if it were mandatory. Regulations drive corporate behavior far more than anything voluntary (with the exception of the maybe 10% high performers who are doing great P2 and have integrated P2 into their own performance measures). It is also important to note that government has not delivered on its promises to provide flexibility. Melinda Dower Research Scientist N.J. Department of Environmental Protection >>> "Todd MacFadden" <Todd_MacFadden@uml.edu> 12/16/02 04:00PM >>> Hey all, It's a bit dated now (Nov 23), but I just came across the following NY Times article in which the late Bill Bilkovich is acknowledged for his work to advance pollution prevention efforts at Dow. Dialogue on Pollution Is Allowed to Trail Off By BARNABY J. FEDER http://www.nytimes.com/2002/11/23/business/23CHEM.html?tntemail1 The article suggests a disturbing trend that industry is increasingly moving away from voluntary and collaborative approaches to P2 - and the concomitant gains in environmental protection - abetted by a more permissive adminstration. (It was, case in point, published the day after Bush hobbled the New Source Review rules). I am curious to know what people think about the fate and future of voluntary environmental initiatives as a tool to protect the environment. For years, industry has pressed EPA and states for flexibility in standards and more non-regulatory approaches to reduce pollutants. And the approach seems to work - but (it would appear) only to the extent that more stringent standards are imminent. Does your experience with voluntary programs support this view? Are they just smoke and mirrors? Todd MacFadden *:-.,_,.-:*'``'*:-.,_,.-:*'``'*:-.,_,.-:*'``'*:*:-.,_,.-:*'*:-.,_ Todd MacFadden Training Specialist Toxics Use Reduction Institute One University Ave Lowell, MA 01854 978.934.3391 978.934.3050 (fax) todd_macfadden@uml.edu www.turi.org Because not everyone can live upstream. ,.-:*'``'*:-.,_,.-:*'``'*:-.,_,.-:*'``'*:*:-.,_,.-:*'*:-.,_,.-:*' * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * p2tech is hosted by the Great Lakes Information Network: http://www.great-lakes.net To unsubscribe from this list: send mail to majordomo@great-lakes.net with the command 'unsubscribe p2tech' in the body of your message. No quotes or subject line are required. About : http://www.great-lakes.net/lists/p2tech/p2tech.info * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * |