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RE: Industry environmental initiative waning?



As a P2Tech member I would like to state this has been a very interesting
thread. I disagree with Jim Walsh that we should not reply to all. Deleting
some messages that may not interest you at this time is not that big a deal,
Mr. Walsh. Many of us are being served well by this discussion.

Terry Foecke, if memory serves my right, the last time I saw Bill Bilkovich
was at a plating shop in Virginia and you were there also. 

Rudy Moehrbach
Staff Engineer
Waste Reduction Resource Center
Phone 800-476-8686
Web http://wrrc.p2pays.org
Check out DPPEA marketplace for waste material: www.ncwastetrader.org 


-----Original Message-----
From: Terry Foecke [mailto:tfoecke@matprod.com]
Sent: Tuesday, December 17, 2002 12:00 PM
To: Katz.John@epamail.epa.gov; Minicucci, Bob
Cc: NPPR@great-lakes.net; P2Tech@great-lakes.net
Subject: Re: Industry environmental initiative waning?


>From my perspective, the future of voluntary initiatives is now.  I am
unsure of the dynamics, but the combination of compliance-driven approaches,
education approaches, and all the other elements of the effort to shift the
focus from exclusively end-of-pipe has had tremendous unseen positive
results.  Both my client work and my work in "green" investing has revealed
a substantial shift in risk perception, in favor of intervening early and
often to eliminate potential problems at the source.  This is occurring in a
deeply integrated way, in product design, process design and R&D, and is
clearly driven less by regulations than it is by a growing understanding
that earlier is better.  So in that sense it is voluntary, but with a notion
of outrunning regulations.

This somewhat optimistic assessment applies mostly to large firms that have
control of design and research functions, of course, but the trickle-down is
straightforward: specs are changing, and suppliers will have reduced EH&S
impacts as a result.  Is it happening fast enough?  No.  Is it targeting
what we as specialists would desire?  Not very often.  But improvements are
happening, and they don't get talked about much for the best reason of all:
they confer competitive advantage.

It is impossible to assign specific credit, but I see real change happening,
and all of the actors deserve some recognition for their parts played.  Our
best project just had its 7th birthday, and it has benefited from every one
of the forces mentioned in today's responses, but more than anything from
patience. 

 
--Terry Foecke
Managing Partner
Materials Productivity LLC
6701 Penn Avenue South, Suite 200
Richfield, MN  55423
(p) 612-243-3605
(f) 612-243-3608 


> From: Katz.John@epamail.epa.gov
> Date: Tue, 17 Dec 2002 08:36:43 -0800
> To: "Minicucci, Bob" <rminicucci@des.state.nh.us>
> Cc: NPPR@great-lakes.net, P2Tech@great-lakes.net
> Subject: RE: Industry environmental initiative waning?
> 
> 
> I agree with Bob, except the green eye shade crowd rarely looks at the
> environmental benefits of enforcement. While voluntary programs - and P2
> in particular - are increasingly required to justify themselves with
> quantified reductions and environmental benefits, I have not seen a
> similar pressure on the compliance crowd to show how they are improving
> the environment. Their success measure continue to be number of
> inspections, number of violations, amount levied in fines and penalties
> - none of which indicate any benefit to human health or the environment.
> Begs the question about the relative benefit of a dollar spent promoting
> P2 and a dollar spent on enforcement.
> 
> That said, I agree with Leann that a hybrid approach is the most
> effective in getting P2 implemented. Combining P2 with compliance
> assistance and enforcement improves all the programs - the enforcement
> folks get their "beans", the facilities have both the motivation and the
> assistance to do the right thing, and we are more likely to see
> immediate and long-term reductions through implementation of P2.
> 
> John Katz
> Pollution Prevention Coordinator
> US EPA Region 9
> 75 Hawthorne Street, WST-7
> San Francisco, CA  94105
> 415-972-3283
> 415-947-3530 (fax)
> katz.john@epa.gov
> 
> 
> 
> "Minicucci, Bob" 
> <rminicucci@des.s        To:       Mark Johnson <Mark.Johnson@lcra.org>,
> tate.nh.us>               Melinda.Dower@dep.state.nj.us,
NPPR@great-lakes.net,
> Sent by:                  P2Tech@great-lakes.net, Todd_MacFadden@uml.edu
> owner-p2tech@grea        cc:
> t-lakes.net              Subject:  RE: Industry environmental initiative
> waning?        
> 
> 
> 12/17/2002 07:33 
> AM               
> Please respond to
> "Minicucci, Bob" 
> 
> 
> 
> 
> 
> 
> No one doubts that regulation is a good and useful tool.  An insistence
> that it be theonly  tool seems misplaced however.
> 
> On the other hand, in the absence of good cost/benefit accounting,
> regulatory pressure has become, arguably, the best way to answer the
> "why are we doing this?" question from the green-eye-shade crowd.
> 
> Bob Minicucci
> NH DES
> 603-271-2941
> -----Original Message-----
> From: Mark Johnson [mailto:Mark.Johnson@lcra.org]
> Sent: Tuesday, December 17, 2002 10:21 AM
> To: Melinda.Dower@dep.state.nj.us; NPPR@great-lakes.net;
> P2Tech@great-lakes.net; Todd_MacFadden@uml.edu
> Subject: 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
> 
> 
> 
> 
> 
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