What is pollution prevention?

BACKGROUND

Reducing the amount of waste (air, water, solid and hazardous) produced at the source is the only permanent and practical solution to the myriad of problems caused by environmental pollutants. Additionally, pollution prevention and designing for the environment makes economic sense; today's generators are tomorrow's potentially responsible parties with legal liability even if current regulations are followed.

Pollution prevention means source reduction. Waste minimization means the reduction, to the extent feasible, of any solid or hazardous waste prior to any treatment, storage, or disposal. Waste reduction means the reduction of volume, and or toxicity, of waste after the waste has been generated and prior to disposal. The waste management hierarchy places pollution prevention or source reduction as the top priority in waste management decisions. The waste management hierarchy is 1) source reduction followed by 2) recycling. If these two preferred options are not possible then 3) waste treatment should be considered before the final and least preferable option of 4) disposal is considered.

Source reduction - procedures that either reduce or eliminate the generation of hazardous waste before the waste is produced.

Recycling - reuse of a waste stream as an ingredient in a productive process or recovery of a reusable product.

Treatment - the use of physical, chemical, biological, or thermal technologies to reduce the volume, toxicity and/or mobility of waste.

Disposal - the placement of waste into landfills or the underground injection of waste.

Source reduction is preferable to recycling from an environmental perspective. Recycling is less desirable because the generation of waste still occurs and the recycling process results in waste residues. Therefore, the waste management hierarchy is: source reduction, recycling, treatment and disposal.

The present focus of pollution prevention and waste minimization activities today are on hazardous waste, as defined by the Resource Conservation and Recovery Act (RCRA) and on air pollutants, as defined under the Clean Air Act (CAA) and its 1990 amendments. However, it is important that all pollutants emitted into air, water, and land be considered as part of a pollution prevention program.

REGULATORY REQUIREMENTS 

In 1984, Congress passed the Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA) which specifically states:

The Congress hereby declares it to be the national policy of the United States, wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of as to minimize the present and future threat to human health and the environment.

The HSWA of 1984 requires every hazardous waste generator to identify in their biennial reports the efforts undertaken to reduce the volume and toxicity of waste generated and reductions in volume and toxicity actually achieved. In addition, each generator must certify that he or she has a program in place to minimize waste generation. The certification statement, found on the Uniform Hazardous Waste Manifest, reads:

If I am a large-quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment, or, if I am a small-quantity generator, I have made a good-faith effort to minimize my waste generation and select the best waste management program.

Unfortunately, neither HSWA or subsequent regulations defined what constitutes a waste minimization program. The law only requires that a program be established and that waste minimization be evaluated.

The Pollution Prevention Act of 1990, established as the national policy of the United States, states that whenever feasible, pollution should be prevented or reduced at the source. Pollution that cannot be prevented at the source should be recycled in an environmentally safe manner. If the pollution cannot be prevented or recycled, it should be treated in an environmentally sound manner, and disposal should be employed only as a last resort. The Act defines

pollution prevention as source reduction, any practice which reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment prior to recycling, treatment, or disposal, and reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants.

Several Executive Orders have been issued by the President of the United States that specifically require federal agencies to comply with pollution prevention, waste minimization and recycling. Executive Order 12780 of October 31, 1991 (Federal Agency Recycling and the Council on Federal Recycling and Procurement Policy) and Executive Order 12873 of October 20, 1993 (Federal Acquisition, Recycling, and Waste Prevention) require federal agencies to promote cost-effective waste reduction and recycling of reusable materials from waste generated by federal government activities.

Executive Order 12856 of August 3, 1993 (Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements) establishes federal policy and requires federal agencies to incorporate the activities required by the Emergency Planning and Community Right-to-Know and the Pollution Prevention Act of 1990 into all aspects of agency programs. This order challenges the Federal government to publicly lead by example through applying source reduction in the management of its facilities and in its acquisition practices. By preventing pollution, the federal government not only protects the environment, it also saves taxpayers money by reducing waste management costs and long-term liability for expensive cleanups. There are many other worker health and safety and environmental laws and regulations that are impacted by pollution prevention activities. These include: Occupation Safety and Health Act; Toxic Substance Control Act; Clean Air Act; Safe Drinking Water Act; Resource Conservation and Recovery Act; Comprehensive Environmental Response, Compensation and Recovery Act; Superfund Amendment and Reauthorization Act; and the Hazardous Materials Transportation Act.

Pollution prevention and waste minimization require a dedicated commitment, careful planning, creative problem-solving, changed attitudes and sometimes capital investments.

EPA VOLUNTARY REDUCTION PROGRAMS

There are a variety of volunteer programs that encourage pollution prevention and waste minimization. Programs that are managed by the EPA include: Design for the Environment, 33/50 Program, Green Lights Program, Green Chemistry, Green Chemistry Challenge, and the Energy Star Program.

Design for the Environment (DfE) - The EPA Office of Pollution Prevention and Toxics (OPPT) also houses a program directed at assisting small and medium sized businesses in targeted industries in considering environmental impacts in the product design phase. The Design for the Environment Program has targeted dry cleaners, printed wiring board manufacturers, and the printing industry (screen and lithography). The DfE program conducts Cleaner Technologies Substitutes Assessments (CTSA) which provide detailed environmental, economic, and performance information on traditional and alternative manufacturing methods and technologies. To help industry implement some of the new technologies identified during CTSA development, DfE provides a variety of outreach tools, which may include fact sheets, bulletins, pollution prevention case studies, software, videos, and training materials.

EPA 33/50 Program - In 1991, the EPA created the 33/50 Program, an experimental pilot program that challenges industry to become voluntary partners in prevention pollution nationwide. The EPA Office of Pollution Prevention and Toxics manages the 33/50 Program. Its name is derived from its goals - an interim goal of a 33 percent reduction by 1992 and an ultimate goal of a 50 percent reduction by 1995 in releases and transfers of 17 high-priority toxic chemicals, compared to a baseline of 1988. These targeted chemicals are toxic, have high production volumes, and have high pollution prevention potential. Approximately 1,300 companies, operating more than 6,000 facilities nationwide, pledged to reduce the release and transfer of the 17 high priority chemicals. National emissions for the 33/50 program chemicals were voluntarily reduced by an additional 100 million pounds in 1993, bringing the total reduction between 1988 and 1993 to 685 million pounds or 46 percent. Release of FY 1996 data (covering calendar year 1994) indicates that the 33/50 program exceeded its ultimate 1995 50% national pollution reduction goal by 10 million pounds, a full year ahead of schedule.

Green Lights Program - The EPA's Green Lights Program is a market-driven, voluntary program which encourages voluntary reductions in energy use through more efficient lighting techniques. Participants have agreed to have energy audits conducted in their facilities and upgrade lighting to more energy efficient systems when economically feasible. The Green Lights program has resulted in a reduction in electrical usage for a $6.9 million annual savings.

Green Chemistry and the Green Chemistry Challenge - Green chemistry is the design, manufacturing, and use of environmentally benign chemical products and process that prevent pollution, produce less-hazardous waste, and reduce environmental and human health risks. As part of the Reinventing Environmental regulations Initiative, on March 16, 1995, President Clinton announced the Green Chemistry Challenge Program to "promote pollution prevention and sustainability through a new Design for the Environment partnership with the chemical industry."

The Green Chemistry Challenge has two phases. First is a recognition of accomplishments in chemistry that have been used to achieve pollution prevention goals. Second, the Challenge program will promote basic research through EPA research grants and encourage industrial and university collaboration to develop innovative approaches to achieve pollution prevention.

Energy Star Program - The Energy Star Program is a volunteer program between the EPA and manufacturers of desktop computers, laser printers, and fax machines in the United States. These consumer items have internal energy saving systems and are easily recognizable by the Energy Star logo.

WHAT ARE POLLUTION PREVENTION TECHNIQUES?

Pollution prevention and waste minimization techniques, as defined by the EPA can be broken down into two major categories: source reduction and recycling. It should be pointed out that waste minimization does not include such processes as incineration, treatment, storage or disposal. Source reduction and recycling should always be considered before treatment and/or disposal.

Source Reduction includes:

* inventory control,

* improved housekeeping,

* production/process modifications,

* product substitution or reformulation,

* waste segregation and new uses.

Recycling includes the use or reuse of the material as an effective substitute for a commercial product or as an ingredient or feedstock in a process. It includes the reclamation of useful constituents within a waste material or the removal of contaminants from a waste to allow it to be reused.

Purchasing and Inventory Controls

In the past, the basic purchasing consideration for chemicals was cost with little or no attention given to the expenses and liability incurred during disposal. As a result, chemicals were often purchased in large quantities. In addition, various brands were purchased to take advantage of sales. This created hazardous waste disposal problems that can be easily solved by following some of the following suggestions.

* Require supervisor approval prior to purchasing hazardous chemicals. This forces workers to think twice before requesting that a hazardous chemical be purchased, and it makes management aware of when and how often chemicals are being added to the inventory.

* Keep the inventory of hazardous chemicals to a minimum. This will assist in container rotation and reduced shelf-life problems. In addition, when less product is available, workers generally use less.

* Reduce the number of brands or products used for the same purpose. Numerous brands of the same product increase shelf-life problems.

* Purchase only what will be used within a short period of time. Manufacturing facilities call this "just-in-time" (JIT).

* Use simple labeling codes, such as an orange sticker, to identify chemicals that contain hazardous constituents. Train individuals who are using these chemicals to recognize the code and to use proper handling and disposal techniques.

Improved Housekeeping

Improved housekeeping can solve a variety of hazardous waste generation problems. In addition, housekeeping changes can be implemented quickly and with little cost. Sloppy housekeeping, which includes leaks from tanks, pumps and valves and release of product onto the floor, can dramatically increase the volume of hazardous waste. Other practices such as tank overfills, lack of drip boards, and chronic spills and leaks add to the hazardous waste stream. Not only is valuable product lost, but the volume of waste generated is increased due to the materials (rags, floor dry and water) used during cleanup. Other housekeeping problems involve improper storage practices, inefficient production startup and shutdown, scheduling problems and poorly calibrated control devices.

Good housekeeping can solve a variety of hazardous waste generation problems. In addition, housekeeping changes can usually be implemented quickly and with little cost.

Production/Process Modifications

Outdated equipment and traditional production methods can generate large volumes of hazardous waste, especially when production is the goal and waste generation is largely ignored. Although the capital investment to purchase new equipment or to modify existing equipment can be high, the investment payback is usually significant when compared to disposal and liability costs.

Product Substitution and Reformulation

Substituting a non-hazardous chemical for a hazardous one has obvious benefits for pollution prevention, environmental protection and worker health and safety. Many products are being reformulated by chemical manufacturers due to increased pressure being placed on them by industry.

Waste Segregation

Many wastes are actually mixtures of hazardous and nonhazardous waste, such as chlorinated solvents in waste oil. When this happens, regulatory definitions may place the entire waste stream in the hazardous waste category. By segregating key constituents, generators can realize substantial cost savings on waste disposal.

Waste segregation can also assist in recycling and reuse. An unsegregated waste stream may be too costly to recycle because of the large component of nonrecyclable waste. Also, waste separation may not be possible for certain solvent mixtures because of similar boiling points or other limitations when the waste is processed during recycling.

New Use and Reuse

When a waste material can be reused as in recycling or when a "new use" can be found for the materials, several advantages occur. Disposal costs are reduced or eliminated, and raw material purchase costs are also reduced. Operations are encouraged to seek out new and environmentally sound uses for waste materials which were previously treated and/or disposed. Some assistance can be found with the expanding waste and chemical exchange programs being established across the United States.

Waste or chemical exchange is a matchmaking operation based on the premise that one company's waste may be another company's feedstock. The goal of waste exchange is to minimize waste disposal expenses and to maximize the value of reusable manufacturing byproducts.

There are two basic types of waste exchanges: information exchanges and material exchanges. Information exchanges act as a clearinghouse for information on the wastes that are wanted. Most information exchanges are nonprofit organizations that receive funds from government agencies. In contrast, material exchanges take actual physical possession of the waste and may initiate or actively participate in the transfer of waste from generator to user. Material exchanges are usually private companies.

Recycling

Both on-site and off-site recycling programs are available for a variety of waste products. Probably the most commonly recycled hazardous wastes are organic solvents. These wastes can often be recycled by distillation, and small recovery units that handle 55 gallons at a time are commercially available. The pay-back time for such units in often less that one year.

In some cases, simple filtration will allow the waste stream to be recycled. This methods is used in machining operations where cuttings oils are contaminated with metal shavings that can be removed by filtration.

Off-site recycling is commercially available, especially for organic solvents. The recycler picks up the waste from the generator, treats it, and returns it to the generator. This process, called tolling, is available in most metropolitan areas. In some cases, portable recycling units are brought to the generator and the recycling takes place on-site.

POLLUTION PREVENTION BENEFITS

Economic incentives more than compensate for what is lacking in regulations. Short-term costs of waste disposal have increased dramatically in recent years and will continue to increase. Potential long-term waste disposal costs, due to environmental impairment liability under CERCLA, cannot be estimated and have no financial ceiling. Therefore, these short-term disposal costs and long-term liability exposure have combined to make waste minimization attractive economically.

Businesses have strong incentives to reduce the toxicity and sheer volume of the waste they generate. A company with an effective, ongoing pollution prevention plan may well be the lowest-cost producer and have a significant competitive edge. The cost per unit produced will decrease as pollution prevention measures lower liability risk and operating costs. The company's public image will also be enhanced.

Reduced Risk of Liability

A company will decrease both civil and criminal liability by reducing the volume and toxicity of the waste streams generated in the production process. Environmental regulations at the federal and state levels require that facilities document the pollution prevention and recycling measures taken and report the percentage or volume reduction achieved. Companies that produce excessive waste (hazardous waste) may risk heavy fines, and their managers may be subject to fines and imprisonment if potential pollutants are mismanaged.

Civil liability is increased by generating hazardous waste and other potential pollutants. Waste handling affects public health and property values in the communities surrounding production and disposal sites. Even materials not currently covered by hazardous waste regulations may present a risk of civil litigation in the future.

Workers compensation costs and risks are directly related to the hazards of the chemicals used and the volume of waste materials used and generated.

Reduced Operating Costs

An effective pollution prevention program can yield cost savings that will more than offset program development and implementation costs. Cost reductions may be immediate savings that appear directly on the balance sheet or anticipated savings based on avoiding potential future costs and liability. Cost savings are particularly noticeable when the costs resulting from the treatment, storage or disposal of waste are allocated to the production unit or service that produces the waste (cost allocations).

Materials costs can be reduced by adopting production procedures that consume fewer resources, thereby creating less waste. As wastes are reduced, the percentage of raw materials converted to finished products increases, with a proportional decrease in materials costs.

Waste management and disposal costs are an obvious and readily measurable potential savings to be realized from pollution prevention. Federal and state regulations require specific waste handling and management criteria, training and record keeping and reporting. The costs of complying with these regulations are a direct cost to business.

Energy costs will decrease as pollution prevention measures are implemented in various production areas. Facility cleanup costs may result from a need to comply with current regulations such as the upgrading of underground storage tanks and the costs associated with remediation of soil and groundwater contamination.

Improved Company Image

As the quality of the environment becomes an issue of greater importance to society, a company's pollution prevention policy and practices will influence the attitudes of employees and community members.

Employees are likely to feel more positive toward their company when they believe that management is committed to providing a safe work environment and is acting as a responsible member of the community by taking a proactive role in waste reduction. By participating in pollution prevention activities, employees can interact positively with each other and with management. Helping to implement and maintain a pollution prevention program should increase their sense of identity with company goals.

Community attitudes will be more positive toward companies that operate and publicize a thorough pollution prevention program. Creating environmentally compatible products and avoiding excessive consumption and discharge of materials and energy resources will greatly enhance a company's image within the community and with customers.

Public Health and Environmental Benefits

Reducing production wastes and emissions provides upstream benefits from reducing ecological damage due to raw material extraction, production and refining operations. Subsequent benefits are the reduced risk of emissions during the production process and during recycling, treatment and disposal.

Environmental compliance costs and the costs associated with fines and penalties are reduced with effective pollution prevention programs.

POLLUTION PREVENTION AND WASTE MINIMIZATION INFORMATION AND RESOURCES

Successful pollution prevention programs make use of ideas and techniques developed through interactions with other companies, federal agencies, trade associations, technical assistance programs, or professional consultants. Sharing successful pollution prevention techniques and case studies greatly increases the acceptance of these "new ideas" which reduce waste and positively impact the bottom lines of businesses' financial statements. A variety of pollution prevention assistance and information dissemination mechanisms are available for additional resources on pollution prevention techniques and strategies.

U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics (OPPT), Design for the Environment (DfE) Program

Businesses operating in the 1990's face a variety of competing demands - keeping costs low and quality high, staying competitive in a global marketplace, and meeting consumer preferences for more environmentally friendly products. Design for the Environment is an effective strategy for organizing and managing these demands. Building on the Design for the Environment (DfE) concept pioneered by industry, the U.S. Environmental Protection Agency (EPA's) DfE program helps businesses incorporate environmental considerations into the design and redesign of products, processes, and technical and management systems. Through the DfE program, EPA develops and provides businesses with information to make environmentally informed choices and design for the environment. DfE forms voluntary partnerships with industry, public interest groups, universities, community colleges, research institutions, and other government agencies to develop environmentally friendly alternatives to existing products and processes.

DfE is working with several industries to identify cost-effective pollution prevention strategies that reduce risks to workers and the environment. DfE helps businesses compare and evaluate the performance, costs, pollution prevention benefits, and human health and environmental risks associated with existing and alternative technologies. The goal of these projects is to encourage businesses to consider and use cleaner products, processes, and technologies. DfE cooperative industry projects include: Printed Wiring Board, Dry Cleaning, Screen Printing, Flexography, Lithography, and Metal Finishing Projects.

DfE is also working with the accounting, insurance, and finance industries to identify and quantify the economic and environmental savings that can be achieved by implementing innovative pollution prevention methodologies.