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Compliance issues in P2 awards programs

P2 techers:

We are developing the final award criteria for our state P2 program.  I
am interested in learning about how other similar programs are dealing
with compliance issues.  Clearly, a good compliance record is important
when giving awards for excellence.  However, we have some large
facilities with legacy waste issues and some operational compliance
issues, some of which are just the nature of larger facilities...100%
compliance is difficult to achieve and legacy wastes take forever to
clean up.  I don't want to discourage them from implementing P2 programs
because awards will never be within their reach due to past
problems...we want to reward people who want to make improvements.  As
well, I have seen the worst polluters transform into the best actors
through P2 initiatives.  How are other states dealing with this very
sticky issue?

Pat Gallagher
New Mexico Environment Department
Office of the Secretary
PO Box 26110
Santa Fe, NM 87502
505-827-2836 (fax)