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Re: Compliance issues in P2 awards programs

Hi Pat.

For exactly the reasons you describe, we have decided to look only at
current compliance status, rather than focusing on legacies, when
evaluating applications for our EcoStar Recognition Program. 

This policy has been tested, however. Last year, we awarded EcoStar status
to a medium-sized aviation repair/restoration facility. Because we always
consult with our DEQ and perform on-site assessments for all applicants, we
knew this facility had a rather significant history of non-compliance -
nearly enough to shut them down. 

But by the time of submission they had turned themselves around, hired an
environmental/safety manager and made impressive P2 strides. They now run
one of the tightest shops I have ever seen. They have since become the
source of many P2 case studies. 

So when a former disgruntled employee and a competitor called me in
disbelief that we could even consider such a company, I felt confident
defending our decision and the company's EcoStar status. 

This year while visiting a different EcoStar applicant, I noted some water
quality violations. They would otherwide have qualified easily, but we had
to turn them down this year. If they fix their problems and re-apply, I
would be very willing to re-consider them for recognition. After all, one
of the overarching goals of this program, in addition to providing
incentives to reduce waste, is to educate businesses about P2 and proper
environmental management. If they learn about a problem through our program
they otherwise wouldn't have known about -- and then take prompt corrective
action -- I am proud to say the program is working. 

The key, I believe, is a thorough review of the applications and careful,
patient scrutiny of their operations and regulatory history. 

Good luck, Cuzzin


At 12:13 AM 7/12/98 -0600, you wrote:
>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)
******************Montana P2 Program*******************

Todd MacFadden
Pollution Prevention Technical Specialist
MSU Extension Service
Taylor Hall				(406) 994-3451
Box 173580				(fax) 994-5417
Bozeman, MT 59717-3580	      toll-free (888) MSU-6872


*******Pollution Prevention Makes Business Sense*******