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Re: Targeting top TRI reporters for reductions

Good for Minnesota.  Most regulatory agencies won't reach out to the top
polluters in their jurisdiction, and one sensitive area you're probably
already aware of is that you can't let such a program lead to the
perception that the regulators are in bed with industry.  I've been
involved in a few workshops and roundtables that were intended to reach
refineries and large chemical manufacturers (at least one of which was
inexplicably aborted much to the disgruntlement of the industry group),
and I might have some insight here. 

If you really want to know how best you might be able to assist the top
polluting facilities in reducing their releases, you should ask them. 
They know what they need.  Often the environmental personnel need an
additional point of leverage they can take to management.  You've got a
stick (bad publicity due to being one of the top polluters), and there's a
carrot in there somewhere too. 

Start by inviting the environmental people from these facilities to a
brainstorming meeting that includes speakers from industry, pollution
prevention academic types, and regulatory personnel that specialize in
pollution prevention.  Make sure that some of the regulators that attend
the meeting are technical people.   

My guess is that the best thing for the facilities might be
roundtable/training sessions, with self-selected breakout sessions. 
Pollution prevention for the big guys doesn't follow cookie-cutter
methods, which is another of the reasons regulators shy away.  Plant
personnel stand to learn a lot from each other (and so lawyers might have
to attend for anti-trust reasons).  The plant personnel are generally
going to be the best experts on their processes that are available.  
These types of sessions have a special kind of magic.

If it turns out that roundtable/training sessions are the way to go, 
Minnesota will benefit from having better trained regulators as well.

Hope this helps.

Kirsten Sinclair Rosselot, P.E.
Process Profiles
P.O. Box 8264
Calabasas, CA 91372-8264


> Minnesota is considering embarking on a project to target our top 15-20 TRI 
> reporters in the state this coming year toward reducing their releases. 
>  They include such companies as 3M, Koch Refinery, ADM, paper companies, 
> Ford, food companies, and others.  We would like to help them help each 
> other, and to offer what we can in the way of P2 services to help them 
> further reduce their releases.  Have other states taken this approach?  What 
> has worked?  What has not?  What are these large companies looking for from 
> us as P2 assistance providers? Or is there anything we can do for them? 
>  Your response would be appreciated.
> Cindy McComas
> University of MN
> 1313 5th Street, #207
> Mpls, MN  55414
> 612-627-4556
> 612-627-4769 (fax)
> mccom003@tc.umn.edu