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p2 in inspections



Massachusetts has institutionalized the practice of inspectors looking for
P2 since the early 1990s, and there's a couple of points about the
experience worth sharing.  One is that one great thing was, to ensure that
it happen, the site visit notes template has a section that reads, Source
Reduction Opportunities Noted, or something like that (I haven't seen one
for a few years, maybe it's changed).  The point is, when the inspector
didn't come up with anything, there's nothing in that section.  Even worse,
it might say, "none noted".   This subtle message to the company that
there's nothing to do is not necessary.  Better just to leave the section
out than to have the title with nothing after it or the notation that
suggests there's no opportunities.

Another point is that there was an idea that the inspectors would get
training from the P2 assistance folks (in Massachusetts, OTA, the Office of
Technical Assistance for Toxics Use Reduction).  This training was in how
to spot opportunities.  The idea was that the inspectors were just going to
learn how to point out that the companies probably had opportunities for
doing P2, and that they would not give them specific advice that might be
interpreted as an order.  So they would say things like, "you might want to
check into the many alternative cleaners you might be able to use", rather
than "we think you should switch to NMP"; the training would help the
inspectors learn how to refer them to help - like that there's a guide to
alternative cleaners, folks at various assistance offices (not just OTA) to
help evaluate them, a cleaning lab at TURI that will try them out for you,
a vendor list, etc.  One useful idea was that in return, the assistance
folks would receive training from the enforcement folks on regulatory
requirements and what they look for in inspections.  Thus it was billed as
a mutual exchange and it could foster relations between the two sides, not
make one side look like the experts and one side look like the students.

Finally, each DEP notice of noncompliance refers the violator to the
assistance agency, and inspectors are supposed to do that, too.  Because
the assistance agency is confidential, the inspectors don't necessarily
hear back about what happens.  They tend to need adjusting to that concept,
but they can do so over time, if they learn enough generic and statistical
information about the groups, and confidentiality-waiving individuals, that
the assistance group ends up working with.