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Re: EMS question

I think that Mark has hit a key point.  About 10 years ago, I was selected
jointly by a plant and a community group to conduct a pollution
prevention -- waste minimization audit of a large, old refinery that was
undergoing extensive modernization.  As the neutral, third party, my job was
to call it like I saw it.  I had carte blanche from both the company and the
group, in terms of what I saw, who I got to question, and what I reported as
a result.  However, the budget was limited (I basically gave away in work
about 10 times what I was paid).  The result was a very hard hitting report
that identified (1) the ways the current facility management was working to
reduce waste and adverse impact on the environment, (2) the ways that
current management was trying to clean up from 70+ years of environmental
ignorance, (3) a wide variety of ways in which the facility could further
reduce its waste.  The report also stated that some things were beyond the
ability of the plant management, like changing OSHA reporting requirements.

Many of the recommendations were adopted by the plant, because they were
reasonable.  Some were negotiated with the community group and modified to
make them more readily implemented in the plant or more palatable to senior
company (above the plant) management.

This audit served as a model that resulted in state legislation requiring
permitted hazardous waste facilities to conduct community participation
audits with third party inspectors.

The issue in this case was not only credibility with the community, but with
company senior management (outside the plant) and management within the
plant, but outside the environmental area.  Since I had performed other
refinery audits and had credibility with the state and industry, it made it
easier for management to implement the recommendations.


Ralph E. Cooper, Ph.D., J.D.
14139 Woodstream
San Antonio, TX 78231
210-479-5490 (4)

-----Original Message-----
From: WasteMin@aol.com <WasteMin@aol.com>
To: p2tech@great-lakes.net <p2tech@great-lakes.net>
Cc: WasteMin@aol.com <WasteMin@aol.com>
Date: Monday, June 07, 1999 10:09 AM
Subject: Fwd: EMS question

>Here is my take on your EMS question. I think the key here is how you
>credibility. It seems to me the Biocycle article is not talking about
>credibility of the EMS system itself, in the way you or I would evaluate an
>EMS to see if it WORKS. I think the article is speaking about public,
>PERCEIVED credibility, and that's a recycled plastic horse of a different
>Like it or not, the general public is too busy to evaluate the true
>of the EMS of a given facility or industry. Yet often the public is asked
>buy their products, or support their expansion, or approve their permits.
>the same time, there have been simply too many special interest
>organizations funded by industry toting the industry line, and too many
>"trust us... there's no spying going on here" claims by government. I think
>the public is inherently distrustful of any institution tooting its own
>yet they don't have time to evaluate the claims especially when technical
>issues are involved.
>This distrust is particularly evident in cases where one ulterior motive
>might be to avoid future regulations or oversight, such as voluntary
>of an EMS by a facility. I think the public is aware and suspicious of
>institutional self interest, even where industry and public interest may in
>fact coincide, such as with an effective EMS.
>Don't forget, the public LIKES environmental regulations on those dirty,
>nasty, money-grubbing industries and factories that produce nothing but
>toxic goo. Look at public opinion surveys. And the public understands
>history, when both government and industry created vexing environmental
>problems because they were focused on other issues of more short term
>importance to them rather than the long term health of the environment.
>So I think the article is saying that a disinterested third party might
>and that the public might trust the third party. I think the article is
>saying that one way to circumvent this inherent distrust is to have a) the
>EMS meet certain standards controlled by the public through our
>or, less directly, through government agencies, and b) have an EMS
>for efficacy by an impartial government agency with no vested interest, or
>better yet c) by the regulatory agency who HAS a vested interest in
>addressing the problems the facility EMS is designed to eliminate. Its a
>question of public trust. I think.
>And that's my cent and a half. (It used to be TWO cents, but I saved half a
>penny through source reduction...)
>Mark Boylan
>22 Executive Park Court
>Germantown  MD  20874