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RE: Compliance vs pollution prevention assistance



MA OTA has delivered combined P2/compliance assistance since 1990, and
it's a good combination.  Compliance seems by far to be the strongest
driver to: 1. get them interested in your help and 2. get them thinking
about really doing something.  It is also a big factor in getting
management to agree to implement something.

Yes, there is also compliance assistance that comes from a perspective
that doesn't place prevention first.  That perspective might be more
interested in the familiar control strategies. That's going to be a
problem, I would think, with even a group that is ideologically
committed to P2 - if they don't actually know how to do it and what it
consists of.  They will fall back on what they know and what will get
the pollution problem solved.  They will have to.  So I think you really
need P2 experts to get it right.

If compliance assistance is provided by a group that is well steeped in
prevention, the problem shouldn't arise.  Treatment options will be
looked at after prevention.

The difficulty in this approach is ensuring that the P2 experts are very
well steeped in compliance.  In the early years, MA DEP was wary of the
compliance advice given by nonDEP people.  They didn't trust that we
could give good advice and some tried to stop us from doing it.

OTA did a few things to address this.  One, we trained OTA in the law
and in talking about the law accurately.  We required people to call DEP
all the time when they had any questions at all about how the law was to
be applied in each situation.  We arranged for regular meetings with DEP
so the DEP people getting the calls from OTA knew who they were and what
they were doing.  We convinced DEP to send people to OTA once they were
in trouble, so they would be exposed to P2 options instead of just
control.  All of these things took a couple of years but eventually we
did succeed in establishing good knowledge of the law at OTA, and
confidence at DEP that OTA could do quality compliance assistance.  DEP
has been referring companies to OTA routinely for over a decade and we
have had maybe one complaint about OTA maybe giving bad compliance
advice over that period, too.    

-----Original Message-----
From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net]
On Behalf Of Bruce Taylor
Sent: Monday, November 14, 2005 11:57 AM
To: Cindy McComas; p2tech
Subject: Re: Compliance vs pollution prevention assistance


In response to your question of what happens to Pollution Prevention
(P2) in 
ralation to Compliance Assisstance, a lot depends on the regulators 
involved.  In my experience, many compliance program timetables are
partial 
to end-of-pipe approaches.  There is a perception that P2 approaches are

less certain and take longer. However, this is not always the case.

In the case study below, the regulator agreed to a timetable based on P2

followed by end-of-pipe (if necessary).  Within 4 months, the in-plant 
measures had reduced the target contaminant (methylene choride) by more
than 
99%.  The target compound was subsequently completely eliminated from
the 
site in March of this year.

http://www.oceta.on.ca/TORSUS/Trimac.pdf

Regards

Bruce

Bruce Taylor, P.Eng.
President
Enviro-Stewards Inc

Ph  (519) 578-5100
Fax (519) 669-5002

www.enviro-stewards.com
----- Original Message ----- 
From: "Cindy McComas" <mccom003@umn.edu>
To: "p2tech" <p2tech@great-lakes.net>
Sent: Monday, November 14, 2005 10:39 AM
Subject: Compliance vs pollution prevention assistance


>I am looking for any historical information as to what happens to  
>Pollution Prevention assistance when it is combined or placed in the  
>same group as compliance assistance.  For example:  Does compliance  
>assistance take precedence over P2 assistance and P2 suffers?  Or does

>compliance assistance integrate P2 concepts and more P2 assistance  
>occurs.  Or does something else happen?  Thanks for your response.
> -- 
> Cindy McComas
> Director
>
> Minnesota Technical Assistance Program
> University of Minnesota
> 612/624-4678, 800/247-0015
> http://www.mntap.umn.edu
>
> Helping Minnesota businesses maximize resource efficiency, prevent
> pollution and reduce costs.
>
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> 


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p2tech is hosted by the Great Lakes Information Network:
http://www.great-lakes.net To unsubscribe from this list: send mail to
majordomo@great-lakes.net with the command 'unsubscribe p2tech' in the
body of your message. No quotes or subject line are required. About :
http://www.great-lakes.net/lists/p2tech/p2tech.info

This list is managed by the Great Lakes Regional Pollution Prevention
Roundtable (http://www.glrppr.org), part of the P2Rx national network of
regional P2 information centers (http://www.p2rx.org ).

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
p2tech is hosted by the Great Lakes Information Network:
http://www.great-lakes.net
To unsubscribe from this list: send mail to majordomo@great-lakes.net
with the command 'unsubscribe p2tech' in the body of your message. No
quotes or subject line are required.
About : http://www.great-lakes.net/lists/p2tech/p2tech.info

This list is managed by the Great Lakes Regional Pollution
Prevention Roundtable (http://www.glrppr.org), part of the
P2Rx national network of regional P2 information centers
(http://www.p2rx.org ).