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Re: Questioning the P2 Hierarchy



I began working on P2 in 1985, shortly after helping write HSWA as a
representative of my employer and trade association.

There really is no P2 'hierarchy' except in the minds of some who haven't
really thought through the issue.

The goal of the entire activity is to reduce the costs (to society, the
world, the locality and the business entity) of the needs met by the
products produced by the business entity.

Sometimes a greater cost reduction, in all terms (including environmental
effect) can be achieved by what is called treatment.  An example that
occasionally works that way is fuel substitution -- burning for fuel a waste
and thereby NOT burning coal or oil.

Sometimes it is achieved by efficient use of the material in the first
place, so that there is little or no waste.

Sometimes it is achieved by changing the product (note the lack of chrome
bumpers on automobiles -- that was an effective, if unintended, pollution
prevention).

Sometimes it could be achieved (but rarely is) by changing the perceived
needs of the clients or customers of the manufacturer.

A corollary problem is that we need to consider the reduction in the risk of
spills and other accidental releases, the lifecycle effects of the product
and associated costs, and so forth, when we determine the optimal pollution
prevention in a particular circumstance.

By doing a complete analysis, sometimes we find that the best outcome is
treatment, but not often.

The point is, there is no overall best solution.  Each specific situation
requires a broad analysis that is open to a variety of solutions and which
favors none but the one that results in the best outcomes for all of the
interests involved -- the environment, the client/customer, the manufacturer
or producer, the employees, and the locality/society, etc.

Ralph
Ralph E. Cooper, Ph.D.
J.D., Class of 1999
Case Western University School of Law
Cleveland, Ohio
216-991-6837

Reply to rec3@po.cwru.edu

-----Original Message-----
From: Callahan, Mike <Mike.Callahan@jacobs.com>
To: 'Kevin Dick' <dick@unr.edu>
Cc: 'P2Tech' <p2tech@great-lakes.net>
Date: Wednesday, October 21, 1998 9:24 PM
Subject: RE: Questioning the P2 Hierarchy


>In the early days (@1984-86), there was much discussion over definitions
and
>hierarchy as it related to waste minimization.  Waste minimization split
>into source reduction (product changes and source control) and recycling
>(reuse and reclamation).  Source reduction was ranked higher over recycling
>in terms of environmental desirability.
>
>In simple terms, it's reduce, reuse, recycle.  For the non-purist, you can
>add treat to the end of this list.  As you move down the chain, your energy
>and environmental impacts go.   The recycling of a waste material takes
more
>energy than if you can reuse it as is, and the reuse of a waste material
>takes more energy than if you reduce the initial generation of waste.
>
>What amazes me is that someone thinks this is worth a masters degree.  I
>believe all these relationships were discussed in the USEPA Report to
>Congress (EPA/530-SW-86-033) back in 1986.  A little digging through the
>popular literature around 1988-92 would uncover many pertinent articles.
>
>The law of entropy is not the issue.  The needed study is why do people
tend
>to think in the reverse order ?  Recycling may use more energy than source
>reduction but it tends to take less brain power and dedication.  Its easy
to
>throw something in a still and push a button, but to eliminate the use of
>some material takes creative effort.  This is not an engineering problem,
>it's a social problem.
>
>Just my two cents,
>
>Mike.callahan@jacobs.com
>
>> ----------
>> From: Kevin Dick[SMTP:dick@unr.edu]
>> Reply To: Kevin Dick
>> Sent: Wednesday, October 21, 1998 9:47 AM
>> To: p2tech@great-lakes.net
>> Cc: tw1712@erols.com
>> Subject: Re: Questioning the P2 Hierarchy
>>
>> What P2 Hierarchy??
>>
>> The Pollution Prevention Act includes an environmental management
>> hierarchy which identifies source reduction (P2) as the preferred
>> environmental management technique.  To call this a P2 hierarchy trashes
>> the whole concept of pollution prevention.  Not that it hasn't been
>> done, but it certainly shouldn't be referred to as a P2 hierarchy in a
>> masters thesis.
>>
>> Kevin Dick
>> BEP-UNR
>> (702) 689-6677
>>
>