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Re: Industry environmental initiative waning?

From another "closet enforcer"
When it comes to spending money on the Environment, most facility managers have always questioned why are we doing this?  Especially  if there are no clear regulatory requirements.  TCEQ has a regulatory requirement that forced many industries/companies to develop P2 plans.   Without this regulation, P2 planning in Texas would not be as widespread.    If the regulation had more teeth, more P2 would have been implemented; unfortunately over time the regualtion just became a paper exercise (I don't think there ahve been any enforcemnt actions that resulted in a fine).  If implementation of the P2 plans was enforced,  more P2 would have occurred.
P2 projects still get implemented without regulations if they have really good paybacks; unfortunately, most low-hanging fruit has been taken and remaining P2 projects may not be the best investment, especially when competing with other projects that have equal or better returns on investment.  
In my opinion, environmental regulations provide the trump card during the cost benefit analysis phase of a P2 project evaluation, especially if implementation of a P2 project results in the elimination/reduction of a regulatory burden.  
Case Study:
Chlorine is widely used for industrial water treatment, it is cheap to use, works well, and is familiar to all water chemistry staff.  One big problem, it has the potential to significantly impact human health and the environment.    Many years ago, there were several products that could have been used as a substitute for chlorine usage, but there was little regulatory pressure to cause change.   Despite readily available replacements for chlorine and the potential risk to human health, the project was not implemented.   Several years ago, EPA rules were put in place that addressed this issue.  The rules required facilities that used chlorine to develop Risk Management Plans (RMPS).   The RMPs defined the extent of a maximum release plume and required facilities to identify and notify all residential/commercial entities located within the area of the maximum release plume.  In addition, the facility was required to provide employee training to all personnel associated with the chlorine process.   With regulations in place, and re-occurring compliance costs, the facility once again looked at substituting chlorine with a less toxic product.    The cost benefit study was still the same as before; however, the added benefit of getting out of the RMP requirements provided the incentives necessary to cause change.   The facility now in the process of converting to a liquid bleach and is exempt from  RMP requirements.  Management celebrated the reduction in compliance/training costs.
The celebration should have been the elimination of a potential catastrophic chlorine release (120 people in the community and 400 employees were no longer at risk).   The risk was eliminated by employing the common P2 practice of product substitution.    
Environmental regulations can drive P2 more than any other factor - conversely if not written correctly, they can also prevent P2 more than any other factor as they commonly prescribe specific control technologies.
Mark L.  Johnson, PMP., CPEA.
Senior Environmental Coordinator
Lower Colorado River Authority
Email: mark.johnson@lcra.org
Phone (512) 473- 3200 ext 2868
Fax: (512) 473-3579
Fax (512) 473-3579

>>> "Melinda Dower" <Melinda.Dower@dep.state.nj.us> 12/17/02 08:00AM >>>
Having been a "closet enforcer" for many years, I am heartened to see
everyone's conclusions about the limited effectiveness of voluntary
programs--I feel like I can come out of the closet now. Even here in NJ,
where P2 Planning is mandatory but implementation of P2 measures is
voluntary, I have had numerous corporate representatives comment that
they would be implementing much more P2 if it were mandatory.
Regulations drive corporate behavior far more than anything voluntary
(with the exception of the maybe 10% high performers who are doing great
P2 and have integrated P2 into their own performance measures).
It is also important to note that government has not delivered on its
promises to provide flexibility.

Melinda Dower
Research Scientist
N.J. Department of Environmental Protection

>>> "Todd MacFadden" <Todd_MacFadden@uml.edu> 12/16/02 04:00PM >>>
Hey all,

It's a bit dated now (Nov 23), but I just came across the following NY

Times article in which the late Bill Bilkovich is acknowledged for his
to advance pollution prevention efforts at Dow.

Dialogue on Pollution Is Allowed to Trail Off


The article suggests a disturbing trend that industry is increasingly
moving away from voluntary and collaborative approaches to P2 - and the

concomitant gains in environmental protection - abetted by a more
permissive adminstration. (It was, case in point, published the day
Bush hobbled the New Source Review rules).

I am curious to know what people think about the fate and future of
voluntary environmental initiatives as a tool to protect the
For years, industry has pressed EPA and states for flexibility in
and more non-regulatory approaches to reduce pollutants. And the
seems to work - but (it would appear) only to the extent that more
stringent standards are imminent. Does your experience with voluntary
programs support this view? Are they just smoke and mirrors?

Todd MacFadden
Todd MacFadden
Training Specialist
Toxics Use Reduction Institute
One University Ave
Lowell, MA 01854

978.934.3050 (fax)


Because not everyone can live upstream.

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