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Re: EMS question -Reply

Mr. Allen

I would like to invite you to discuss your article for the P2 Tech list
You can see the discussion on your article at

At the bottom of this e-mail is a comment posted that hasn't
made it to the thread yet.

Finally, I am wondering: What is the value of government
involvement?  I think of UL listings (look at virtually any electrical
item); UL has broad public acceptance, companies will ensure
the product is UL listed without government encouragement or
oversight.  Most people could care less about UL- few even know
what UL is (I am not sure of the details myself).  What they do
know is that they can trust the electrical appliances not to
explode in flames.  UL takes a back seat.  The government
doesn't seem involved at all (or is it?).
Thomas Vinson
Pollution Prevention and Industry Assistance
PO Box 13087
Austin, TX 78753

512 239 3182

>>> "Ralph +or Meg Cooper" <rmcooper@flash.net> 06/07/99
11:06am >>>
I think that Mark has hit a key point.  About 10 years ago, I was
jointly by a plant and a community group to conduct a pollution
prevention -- waste minimization audit of a large, old refinery that
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
ignorance, (3) a wide variety of ways in which the facility could
reduce its waste.  The report also stated that some things were
beyond the
ability of the plant management, like changing OSHA reporting

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
permitted hazardous waste facilities to conduct community
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
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
>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
>PERCEIVED credibility, and that's a recycled plastic horse of a
>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
>buy their products, or support their expansion, or approve their
>the same time, there have been simply too many special
>organizations funded by industry toting the industry line, and too
>"trust us... there's no spying going on here" claims by
government. I think
>the public is inherently distrustful of any institution tooting its
>yet they don't have time to evaluate the claims especially when
>issues are involved.
>This distrust is particularly evident in cases where one ulterior
>might be to avoid future regulations or oversight, such as
>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
>history, when both government and industry created vexing
>problems because they were focused on other issues of more
short term
>importance to them rather than the long term health of the
>So I think the article is saying that a disinterested third party
>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
>or, less directly, through government agencies, and b) have an
>for efficacy by an impartial government agency with no vested
interest, or
>better yet c) by the regulatory agency who HAS a vested interest
>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