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Re: Site Visits

Hi Guys,

There are over 300 Toxics Use Reduction Planners trained and certified by
the state of Massachusetts who might consider themselves your type "b".  A
small portion of them come from a quality systems background, and many
quality tools are used.  Other tools and approaches include process
engineering, process safety management, total cost accounting, design for
environment, and environmental management systems. The scope is broader
than a traditional quality program, which could certainly be the point of
entry if the organization has such a culture. I hope we are open to many
approaches, learning from each other.

Janet Clark
Toxics Use Reduction Institute
University of Massachusetts Lowell

At 08:16 PM 1/23/99 -0800, you wrote:
>Your "a" type of pollution prevention assessment dates back to the printing
>of the EPA Waste Minimization Opportunity Assessment Manual.  It was for
>environmental people to use both outside  (technical assistance providers
>and consultants) and inside the companies.  Technical assistance providers
>often get their support money from the EPA (PPIS grants) and must measure
>their performance.  This performance measurement is often accomplished by
>citing the number of visits made and the number of "right answer" solutions
>provided.  Little effort is spent to follow up with the firm to see if they
>actually implemented the right answers or continued to operate them for
>years later.   You will note that the EPA Facility Pollution Prevention
>Guide (second edition of the above mentioned EPA Guide) clearly calls for
>the assessment to be used to establish the program. 
>Your "b" type of pollution prevention goes back to about the same time when
>I started teaching the Systems Approach to Pollution Prevention at Tufts
>Unversity.  In this "quality-based" approach, the ASSESSMENT is only one
>(somewhat minor) component of a pollution prevention program.  Within the
>program, outside assistance (often management consultants) may help people
>within a company eliminate waste (Japanese refer to waste as MUDA).  The
>role of assistance is to FACILITATE the process of problem-solving and
>decision-making.  Waste (of any type) IS a PROBLEM to be solved using
>internal (cultural) information.  This is the type of assistance that Pat
>Gallagher of New Mexico described and it is the type of assistance that the
>EPA "Nothing to Waste" environmental justice program addresses.  I do not
>know of any other P2 technical assistance efforts outside of the NIST MEP
>arena that is currently using this approach.
>The EPA made a pitch for P2 Programs that had a "program element" in it for
>conducting periodic waste minimization assessments.  It was published in
>the FEDERAL REGISTER ( June 12, 1989 - Vol 54, No. 111, pp 25056-25057) as
>the basis for the "program in place" that every company that signs
>hazardous waste manifests is certifying that they have (yeah right!).  The
>final document was published in the FEDERAL REGISTER in 1993.  It is
>important to realize that this document specifies the program as being
>important and the assessment as only being part of the program.  This
>contrasts markedly with your "a" case.
>So you see, Mike, there was never a "split" as you called it.  You either
>did "a" or you did "b."  Both are valid and have sound bases in EPA
>publications.  I can tell you are an "a" man.  So be it.  No need to get
>stressed out over it.
>Those of us in the "b" camp, Mike, do not believe it is proper to do
>brainstorming (we prefer brainwriting) until AFTER root cause analysis is
>completed.  It is important to know why the waste exists BEFORE trying to
>eliminate the waste.  There was no coverage of root cause analysis in the
>EPA FAcility Pollution Prevention Guide.  However, the DOE Pollution
>Prevention Guide does have something that looks like a cause and effect
>diagram included in it.  We believe that there are champions for
>eliminating wastes in companies and our process finds the champions and
>place them on teams that solve problems.  Many people on P2 TECH want right
>answers and have even stopped brainstorming with employees.  Options (we
>call them alternatives) are coming from this listserver and are fed to the
>companies in some cases.  State P2 technical assistance providers may need
>to have this information for their performance evaluations.  This is not a
>split.  It merely follows the dictates of who is providing the money.
>Mike, you seem to suggest that the "b" approach is hard to sell or is much
>more expensive and should only follow the "a" approach.  A technical
>assistance provider offering a free service can go into a company and
>prepare a hierarchical process map and identify all the P2 opportunities
>inside a half day in most firms.  If they spent the entire day, they could
>take one of the P2 opportunities and conduct the root cause analysis,
>generate alternatives, select alternatives, and prepare an action plan.
>The employees can then use this information to work on other P2 projects.
>A program can be easily established around this information.  It is not
>more expensive.  It is only an issue in that the technical assistance
>provider will have to learn how to use the problem-solving and
>decision-making tools in the Systems Approach or other quality-based
>program.  You are right about your "old saying."  Some P2 technical
>assistance providers still love the methods they use.  However, this string
>started as some of these very providers are beginning to question the
>methods they have been using since 1989.  Lean manufacturing and
>just-in-time consultants are eliminating waste (includes environmental
>varieties of waste) using the "b" method.  The NIST MEP's are now charging
>for some of their services so they do not have to rely on the government
>funding that is dictating the ways of those using the "a" method.
>The notes that Pat Gallagher, Rick Grote, Dale Francke, Burt Hammner,
>myself and others have been sending to this listserver are informing those
>who use the "a" approach that the "b" approach can work well if you are
>properly trained.  Much information exists on these tools (refer to
>previous notes).  However, as Pat Gallagher will attest, you have to go out
>and use the tools in order to master them for working with your clients.  I
>believe that she said that the companies that participated in her program
>had "fun."  How much fun does a company have with a checklist and a listing
>of "right answers" that are provided to them.  Maybe New Mexico is "on to"
>something BIG here!
>There is a rumor that the P2 providers using the "b" approach are no longer
>using their asbestos suits.  You might ask some of the participants in this
>string for some really cool subsitutes for asbestos suits.  I think there
>is a company that is melting the asbestos rendering it nonfriable.  Sounds
>like a "right answer" to me. We all want to know where you stand on the two
>methods, if you are in facile with problem-solving and decision-making
>approaches (remember that they youngest tool in the Systems Approach goes
>back to 1943 - long before EPA was even thought about). 
>At 01:47 PM 1/22/99 -0800, you wrote:
>>I have some questions/comments regarding site visits that may get me flamed,
>>but so be it.  Am I correct in my understanding that the two major
>>approaches are a) outsiders do the assessment and give the plant personnel a
>>shopping list of measures versus b) work with the plant personnel to develop
>>an understanding of the process and then have them come up with solutions ?
>>And why is it that "a" types seem to be associated with environmental
>>programs while "b" types are associated with quality programs ?  How did
>>this split occur ?
>>If there is a split, then we have a generation of people in the
>>environmental field who have been misled and mistaught as to how to conduct
>>a P2OA.  What ever happened to "product champion" ?  What happened to
>>brainstorming sessions and option screening by the "team" members ?  All of
>>these relate to the "b" approach and they did not come from quality
>>programs.  They are rooted in the common ancestors of both programs.
>>As the old saying goes "What works, works."  If you offer free advice and
>>the company doesn't want you to take time away from their employees, then
>>you can only follow the "a" model.  Maybe nothing will happen, or maybe you
>>planted some seeds that can take root for a future "b" approach.  And if the
>>company spends money to take the "b" approach, then you can be assured
>>something will happen because its expected.
>>Does anyone know of a substitute for asbestos suits ?
>Dr. Robert B. Pojasek 
>Pojasek & Associates 
>P.O. Box 1333 
>E. Arlington, MA 02474-0071
>(781) 641-2422 
>(617) 788-0288 (FAX)