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Re: Measuring pollution prevention performance: metrics

I have some trouble with the one about tracking the full true costs --
sometimes one can get close without spending inordinate resources on
accounting.  It is my complaint with much of the EPA approach to waste
minimization and pollution prevention.  A company that is committed to
finding better ways and reducing pollution will sometimes make investments
that are not otherwise cost effective -- they do it because it is the right
thing to do.  That company should score better than one that spends a lot of
effort on and waits for the results of an extensive pollution accounting

Ralph E. Cooper, Ph.D., J.D.
14139 Woodstream
San Antonio, TX 78231
----- Original Message -----
From: "Burt Hamner" <bhamner@cleanerproduction.com>
To: <p2tech@great-lakes.net>
Sent: Friday, March 17, 2000 9:20 AM
Subject: Re: Measuring pollution prevention performance: metrics

> Over a year ago I asked a similar question re comparative metrics, and the
> result was similar to what I am reading on P2Tech so far:  There are
> for process-level P2 performance, and some tools for compaing between
> comanies in the same industry, but not for comparing across industries.
> After a lot of interesting discussion, I proposed that a "de minimis"
> approach to metrics be taken;  What is the simplest set of indicators we
> could use that would tell us if one organization is doing better on P2
> progress than another?  This would at least help us focus TA and also
> identify firms that can be benchmarks for the laggards in their groups.
> The criteria I came up with - and no one on P2TECH seemed to disagree -
> as follows:
> 1.  Firm has some kind of organized EMS that the middle managers and
> employees can describe, ie. they are organized about their efforts to
> improve;
> 2.  They practice toxics reduction as a formal priority; ie. they really
> understand that prevention is better than cure
> 3.  They understand and track the true full costs of environmental
> management and waste; ie. they are capable of making informed investments
> P2
> 4.  They participate in the P2 network of TA, training etc; ie. they know
> enough to look around for best practices and free help.
> In my opinion, those 4 simple metrics can be used to quickly compare
> progress of firms.  Many firms in states with mandatory P2 planning will
> ok on most of these criteria, perhaps with exception of 3. Costs - many
> firms still don't understand how much money they lose to waste, and that
> probably because P2 planning laws generally don't require such analysis
> beyond "describe your environmenatl accounting methods".
> If your objective is to target TA, to rank facilities on a relative scale
> P2 competence or potential for sustainability, or to figure out which of
> criteria need the most program support, the four simple metrics would work
> fine.  If your objective is to determine whether P2 has made one facility
> pollute less than another, that's very hard.  If you want to prove to
> legislatures that the P2 program is really reducing total pollution
> generated, then the best you can do is normalized waste generation in the
> target groups.  So the question back atcha is,  what do you want metrics
> FOR?  What is the minimum amount and type of data needed to choose between
> alternatives in support of your goals?  Unless you are doing basic
> the only reason to do an evaluation of P2 progress is to decide between
> alternative future courses of action.  If metrics don't enable you to make
> decision about what to do, then they are the wrong metrics.
> ************************************************************
> Burton Hamner
> Hamner & Associates LLC/ CleanerProduction.Com
> 5534 30th Avenue NE
> Seattle, WA USA 98105
> tel:  206-526-5308
> fax: 208-279-4991
> email: bhamner@cleanerproduction.com
> ----- Original Message -----
> From: "Kirsten Sinclair Rosselot" <rosselot@ix.netcom.com>
> To: "Jenna Latt" <LATTJ@state.mi.us>; <p2tech@great-lakes.net>
> Sent: Thursday, March 16, 2000 5:33 PM
> Subject: Re: Measuring pollution prevention performance: metrics
> > There's a big difference between measuring environmental performance and
> > measuring environmental progress.
> >
> > I've compared the environmental performance of chemical plants that have
> > similar product slates by looking at potency-weighted releases on a per
> unit
> > of production basis.  What we saw was that there are vast differences
> > one facility to the next not only in how much waste was generated on a
> > per-unit-of-production basis but in how the wastes were managed.  Some
> > facilities were clearly ahead of others on the pollution prevention
> > This is very useful and interesting information, and comparing a
> to
> > other like facilities in this manner is an excellent way to evaluate
> > environmental *performance*.  As time goes on, it's becoming clear that
> > environmental performance is linked to shareholder value and I expect
> > of these types of studies to be done.  However, this is a really
> complicated
> > and expensive type of analysis, requiring a knowledge of what compounds
> are
> > emitted during the production of each product, what production
> > are, etc.
> >
> > Even within the chemical industry, it would be misleading to adopt any
> > indicator of production (sales, man-hours, cost-of-production,
> > pounds-of-production, etc.) across the board and measure environmental
> > performance using that single metric.  Using a single metric across many
> > industries would be even less meaningful.
> >
> > Evaluating environmental *progress* for a facility is simpler.  For
> example,
> > potency-weighted releases, summed by facility over time and adjusted for
> > production, give a quantitative measure of environmental progress and
> > fairly easy to develop.  However, a facility can make a tremendous
> of
> > environmental progress and still not have good environmental
> > and that distinction must be made.
> >
> > ===============================
> > Kirsten Sinclair Rosselot, P.E.
> > Process Profiles
> > P.O. Box 8264
> > Calabasas, CA 91372-8264
> >
> > rosselot@ix.netcom.com
> > http://home.netcom.com/~rosselot
> >
> > (818) 878-0454
> > ===============================
> >
> > ----- Original Message -----
> > From: Jenna Latt <LATTJ@state.mi.us>
> > To: <p2tech@great-lakes.net>
> > Sent: Wednesday, March 15, 2000 8:35 AM
> > Subject: Measuring pollution prevention performance: metrics
> >
> >
> > > I was wondering whether anyone have information on corporate or state
> > programs that are measuring pollution prevention progress or
> > Usually this is referred to as environmental performance indicators or
> > metrics and goes beyond the traditional SARA TRI data reporting, "pounds
> > released" or emissions reporting. For example, measurements used can be
> > "amount of constituent reduced per amount of product produced," or some
> > other similar metrics. I am particularly interested in what state
> > are doing in this area.
> > >
> > > Are there any websites or reports (specifically report names) I can be
> > referred to? I have already checked www.epa.gov and the EPA P2 site but
> > may have missed a particular report.
> > >
> > > Thanks,
> > >
> > > Jenna Latt
> > > Pollution Prevention Section
> > > Environmental Assistance Division
> > > Michigan Dept. of Environmental Quality
> > >
> >
> >