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Re: Site Visits






This has been a fascinating debate. I agree the question is not "should programs
take an A  approach or a B approach."  I believe Bob and Mike are correct that
companies that take the B approach definitely are more likely to actually
implement P2. The question for me is how do we reach the 60-80% of companies
that aren't ready (and may not be willing) to take the B approach? In our
experience, companies are very willing to take the government up on offers for
free assessments or workshops, for the very reason that it requires a fairly low
investment of time or capital. Participation drops off significantly, however,
when they are called upon to assist in the assessment process - sitting down and
actually taking the time to map their material flows, their actual costs, etc.
In addition, national small business surveys have indicated their desire for
detailed, technical information to help them implement P2  (which leans us a
little toward the A camp).

This speaks to a "quantity helped" versus "quality of result" trade-off, which
to me brings up the measurement issue. Taking the A approach shouldn't let
providers off the hook for measuring results. Under GPRA, EPA is wrestling with
how to better measure environmental results, and that is infiltrating the P2
world. In our experience,  it is possible to measure the implementation rate of
suggested P2 fixes (the A approach), and even get a sense of the associated
pollution reductions. It does, however, take more time and imagination, and
providers (and EPA) have to be willing to recognize that such data comes at a
cost. If we don't do this - if our measures of success stay as crude as number
of workshop attendees or site visits - than we will never get a sense of whether
the A approach or B approach get better results. Despite Bob and Mike's
pessimism, we just don't know how many people walk away from a workshop or site
assessment and actually implement the suggestions, because very few programs
actually follow up.  And when we do know that, we can evaluate if the "benefit
per time spent" may be worse than, equal to or better than the B approach. (Do
the math: three workshops reach 100 people, three of whom actually implement the
recommendations, VS. 3 one-day on-site process/root cause sessions ===> equal
results - or is there a qualitative difference between the workshop group and
the process group?)

I'm not up on this literature -- how many businesses (especially small
businesses) actively practice TQM, just-in-time, lean manufacturing initiatives,
etc.?  It is certainly true that all of us will be better providers if we
incorporate these tools into our bag of tricks, but how relevant  are these to
small-medium businesses targeted by many local TAPs?  What have been people's
experience getting the B approach to work with large numbers of small
businesses? Do these themes and processes resonate?  Or do we have to reconcile
that different groups will respond to different approaches?

The fundamental challenge for the P2 community is not just choosing which
strategy to take, but how to penetrate a large percentage of businesses, rather
than simply dealing with the top 5-20% of highly motivated members reached by
either the A or B crowd. This is why Leif brought up regulatory levers - they
are a means to reach the full range of businesses. If the regulatory system
truly promoted P2 (including assessments of sources and material flows, rather
than simply mandating technologies), we could certainly get more P2 adoption
than any voluntary efforts alone. The South Coast solvent rule is just one
example of how effective that can be. Here in the Bay Area, one POTW includes a
P2 provision in all their permits, but has never had the technical expertise on
staff to 1) assist businesses in fulfilling that condition and 2) feel
comfortable enforcing it. What if they could? Any thoughts on how regulatory
tools can better forward both approaches?

Any thoughts would be appreciated. I'm learning a lot through this discussion.

John Katz
Pollution Prevention Coordinator
US EPA Region 9
415-744-2150
katz.john@epa.gov