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RE: Providing P2 Advice During Compliance Inspections



Michael Crow  (mcrow@tellus.org) asks, in part:

	> We are assisting
	> the Ohio EPA in developing training for hazardous waste inspectors
to
	> encourage facilities to think about the benefits of P2.  Given
that
	> businesses may have a negative view of receiving information from
	> inspectors, we are interested in coming up with hands-on ways that
	> inspectors can cut through communication obstacles that might
prevent the P2
	> message from getting across.

Michael --

I will be very interested in following the results of your work, and hope
that Ohio EPA will keep the rest of the P2TECH list posted on their
training.  While trained and inclined to be primarily a "P2 person," one of
the hats I wear is as the technical director for ChemAlliance, a national
compliance assistance center established for the chemical industry.  I have
taken the liberty of forwarding your message to our list server
(http://www.chemalliance.org/Lists/listinfo.htm), since there are a number
of compliance inspectors and enforcement people who subscribe to the list.
Perhaps they will have some thoughts.

I'll also note that we are in the process of updating our "virtual chemical
plant tour" (http://www.chemalliance.org/RegTools/plant/index.htm).  This
feature emphasizes basic familiarity with regulatory obligations from a
plant operator perspective but we are updating it to incorporate P2/BMP
recommendations and self-auditing information.  You should check back on
this towards the end of the summer, if you are looking for ideas on simple
ways to incorporate this info in an online environment.

In addition to the Chemical sector, there are compliance centers for:

*	CCAR-GreenLink® - The Automotive Compliance Information Assistance
Center 
*	National Metal Finishing Resource Center (NMFRC) 
*	The National Agriculture Compliance Assistance Center (Ag Center) 
*	Printed Wiring Board Manufacturing Center 
*	Printers National Compliance Assistance Center (PNEAC)  
*	Transportation Compliance Assistance Center
*	Local Government Environmental Assistance Network (LGEAN)
*	The Paints And Coatings Center

I should note that most of these sector-specific OECA Compliance Centers
have their own list servers or other mechanisms for communicating with its
members.  Each also has more or less incorporating P2 into compliance
assistance.  It would probably be worth your while to check into these
centers and post your request to each of their lists.  

You can find URL's for the rest of the centers at:
http://es.epa.gov/oeca/mfcac.html

Hope this helps.

Scott Butner (butner@battelle.org) 
Technical Director, ChemAlliance
Senior Research Scientist, Environmental Technology Division
Pacific Northwest National Laboratory
4000 NE 41st Street, Seattle WA   98105
(206)-528-3290 voice/(206)-528-3552 fax
http://www.chemalliance.org/