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RE: Site Visits

In your analysis you neglected to discuss the EPA Federal Register item
that I cited.  It clearly states that the assessment is an important
program element but not the basis for the program itself.  That was my
point.  You cited the WMOA Manual (1988).  In Figure 1-3 you did cite the
first step.  It is difficult to get management commitment for P2 before any
assessment work has started (Assessment Phase).  It is also nearly
impossible to set realistic goals when there has been little information
collected.  The organization of the assessment program task force is just
getting ready for the assessment phase.  The focus is clearly on the
assessment in my reading of the manual.  Most quality-related programs
clearly set up the program first (perhaps better than the WMOA and its
second edition did).  This being said, I think environmental people need to
act as facilitators and resource persons in the waste elimination programs
and not set up stand-alone programs.  The waste elimination programs must
be INTEGRATED into core business practices.  If the company has a strategic
plan or productivity improvement plan, this is where the waste elimination
program should be centered.  It is highly unlikely that an environmental
person would be directing such an effort, but he or she does need to be
involved.  In my experience with industry, this effort is often lead by
someone with training in process characterization (hierarchical process
maps NOT process flow diagrams), problem solving and decision making.
Technical assistance providers and consultants can ask questions about the
company's other programs to eliminate waste (lean manufacturing initiative,
just-in-time, agility program, etc.).  If they understand the primary
motivation of these programs (i.e., to eliminate waste), it is possible to
get environmental wastes included in the program INSTEAD of setting up a
separate program.  Many P2 assessments ("a" approach) are not doing this.
I am real pleased to hear that you are using proven quality tools in your
work (the "b" approach).  I have found in my 11 years of teaching that
engineers have some difficulty using these tools.  Since the tools do not
use algorithms and computers for the most part, they are considered to be
"soft" to the engineer.  Instead, these tools provide structured analysis
that help TEAMS solve problems with available knowledge.  Engineers need to
be active in these teams or help them design and implement the alternatives
that were decided upon using the tools.

My answer to your questions:

P2 should NOT be taken away from us.  However, we need to learn how to
INTEGRATE our work into mainstream efforts within the firm.  We have to
learn more than P2 to do this effectively.  Will we take the time to do so?

Quality trained personnel have already learned how to use structured
analysis tools and how to set up effective strategic planning efforts with
management commitment.  This has been done under many names (lean
manufacturing, etc.).  Of all the wastes that they declare war on, rarely
are environmental wastes included.  So we cannot allow them to consider P2
without our involvement.  However if we do not learn their jargon, we will
be excluded from their efforts.  Often the quality people are in a better
position to facilitate the work.  Engineers like to solve problems not
study them.  However, they do need to be studied with employee teams before
an effective (local cultural considerations included) solution can be found
and implemented.

Government will always have a role in P2 and industry competitiveness.  The
new EPA Facility Pollution Prevention Guide will be available at the end of
this year with much more information on problem solving and decision
making.  The "b" component will be well described.  The NIST MEP program is
looking at using problem-solving and decision-making tools to integrate P2
into their lean manufacturing consulting practice.  They are now charging
companies a fee for their services to reduce the need for government funds.
 The Small Business Development Centers are working with the EPA
Environmental Accounting Project to expand the use of environmental
accounting.  These projects are aimed at INTEGRATION of environmental
programs into core business practice NOT setting up stand-alone programs.
Perhaps this is the key.  What we need to look at is how performance is
measured on EPA PPIS grants and how the incentives and rewards go to those
that leverage their work in the manner discussed in this discussion string.

The "b" approach is VERY EFFECTIVE in gathering information.  It does so by
involving employees and making them aware of other information as you
suggest.  If you have used this approach as you claim, you would know just
how effective the approach can be.  I refer you to Pat Gallagher's response
from her efforts in New Mexico.  The "b" approach encourages benchmarking
as a means of both gathering feasibility study information on best
practices and as a means of establishing meaningful metrics.  Often the "a"
approach uses benchmarking in a more limited fashion as a search for "right
answers."  This short circuits the use of problem-solving and
decision-making tools by employee teams.  The reason that the "b" approach
works so well is that everyone in the firm buys into the program and does
not get a "solution" imposed upon them by an outside group that may not be
facilitating team problem-solving.  It is interesting that in the New
Mexico program, companies cannot tell stories about their P2 gains.  They
must use metrics to describe the success.  This is required in the Malcolm
Baldrige criteria.  This may bring a new demension to our P2 case studies.

I would love to hear others answer Mike's questions - especially some of
the NIST MEP lurkers to this listserver.  Perhaps others have additional
questions that can be explored within this discussion.  I know that there
are a number of quality trained people on this listserver.  Has this helped
you in your work?  Jancie Hatcher thinks so.  Pat Gallagher thinks so.
What about you?

Mike Callahan writes:

Should P2 be taken away from the environmental groups and be given to the
quality groups ? 
Should the environmental groups just let the quality groups take it ?  
Should governments role in such programs be curtailed because it often
leads to "a" type thinking ?
Can a "b" approach work without upsets if there was no "a" type information
available for benchmarking ?


Dr. Robert B. Pojasek 
Pojasek & Associates 
P.O. Box 1333 
E. Arlington, MA 02474-0071
(781) 641-2422 
(617) 788-0288 (FAX)