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RE: Industry environmental initiative waning?

This has indeed been an interesting thread.

Having worked in the Pollution Prevention realm starting when it was Waste
Minimization I have seen varying degrees of interest by industry personnel
throughout the different levels of responsibility.  I have to agree with
those that see a dual need for regulatory and voluntary incentives to keep
P2 efforts moving forward.

 Early in my career, after being unable to convince senior management of the
benefit of replacing an aging piece of equipment (maintenance headache, lost
production, inefficient, etc.) I asked my supervisor why they were so
"stupid that they could see this need".  I was told that it was not really
their stupidity but a failure on my part to adequately present the case to
them so that they understood the need.  I have never forgotten this.  That
is the job of engineers or others trying to get management "to see the
better way."  We must present the picture completely and correctly using the
terms and justification required by the decision making group.  My point
with this example is that I think this points to a major error on the part
of P2 effort.

I believe that regulatory requirements for reporting, emission permitting,
fines for permit violations and requirements such as the HESHAPs was the
main driver for early efforts in the P2 arena.  Corporate officials,
particularly those that were facing fines or major capital investments, saw
P2 as a means to reduce the costs of these items.  As expertise developed in
the manufacturing ranks many of the people involved saw the savings not
limited to just fines or capital expenditure reduction but also started
realizing they were saving manpower (in not handling wastes) and raw
materials.  They saw the benefits to workers in reduced exposures or reduce

The problem I see now is that we have many local and regional assistant
programs that are doing a good job at pointing out P2 opportunities to small
and mid-size companies but are not able, generally due to workload, to
provide the needed engineering to identify the exact costs to implement, the
design changes and the true benefits/savings that will be realized.  [I
apologize to those providers that may be providing this level of involvement
but I have not seen it with the programs I have talked to people about. ]
When these small and mid-size companies are left without the ability to move
to the next step nothing happens whether they want to or not.

All that being said I think the following needs to be done.
1.  Regulatory requirements to minimize waste/emissions must be in existence
with sufficient fines to ensure a true desire to meet the limits with some
comfort.  I don't mean that "Which hunting" should be started every time an
enforcement person visits an industry.  Cooperation is still necessary.
2.   P2 assistance providers need to work with companies after they have
identified opportunities.  I think this next step is to get the companies in
contact with private company personnel (consultants, engineering firms,
experts, etc.) that can provide them with the designs and economic analysis
to justify implementation.
3.  P2 Assistance Programs, Regulatory Groups and Private Industry and
Companies need to meet and cooperate on exchanging information on P2
opportunities, regulatory and assistance needs and the availability of
qualified, non-government assistance to define and implement systems and
processes to implement P2 opportunities.

I have said enough or more probably too much but I hope some of it helps the
discussion and the future of P2 as a voluntary activity.  My thanks to all
who have been providing very interesting discussion of this topic.

My Best Wishes to all of you for the Holiday Season.

Dale H. Francke, P.E.
Engineering Service Professionals, Inc.
Fax: 509.756.3985
e-mail:   dale@espsupport.com

Professional Engineer - State of FL

Visit us at:   www.espsupport.com

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-----Original Message-----
From: owner-p2tech@great-lakes.net
[mailto:owner-p2tech@great-lakes.net]On Behalf Of Terry Foecke
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

--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,
> 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
> 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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