Ohio Prevention First

The State of Ohio's Voluntary Pollution Prevention and Pollution Reduction Planning Initiative

1.0 INTRODUCTION

Pollution prevention means the use of source reduction techniques in order to reduce risk to public health, safety, welfare, the environment and as second preference, the use of environmentally sound recycling to achieve these same goals. Pollution prevention avoids cross-media transfers of waste and/or pollutants and is multi-media in scope. It addresses all types of waste and environmental releases to the air, water and land. It is a subset of pollution reduction, which includes any type of activity which reduces the amount of waste and/or pollution released to the environment except land disposal. Pollution reduction includes pollution prevention activities as well as activities such as treatment and energy recovery, which are not considered to be pollution prevention.

There are three primary objectives of the Ohio Prevention First Initiative: The first objective is to seek a 50 percent reduction in the release of toxic chemicals and the amount of hazardous waste generated in Ohio by the year 2000. However, reductions of all types of pollution are included in this initiative. One method of achieving this objective is by requesting Ohio business and industry to make reduction commitments and prepare pollution prevention plans. As the first step toward achieving this objective, Governor Voinovich requested the top 100 toxic chemical reporters (based on 1991 Toxic Release Inventory reports) to prepare comprehensive pollution prevention plans. These plans are to identify cost-effective pollution prevention and pollution reduction options to help Ohio businesses become more competitive through reduced waste management costs.

The second objective is to encourage facilities to initiate or expand existing pollution prevention or pollution reduction practices through development of comprehensive pollution prevention plans. By demonstrating the economic and environmental benefits of pollution prevention, the facilities included in this initiative will serve as role models for other businesses throughout the state.

The third objective of this initiative is to publicize the exemplary pollution prevention or pollution reduction efforts being made by these and other organizations. Ohio EPA believes that recognizing outstanding achievements provides an incentive for companies by enhancing their public image related to the environment, and encouraging other organizations to complete similar activities.

1.1 Background

On September 1,1993, Governor George V. Voinovich requested the "Top 100" toxic chemical reporters, as identified using the 1991 Toxic Release Inventory, to prepare comprehensive pollution prevention plans. A draft Implementation Strategy for this initiative, entitled the Ohio Pollution Prevention 2000, was released by Ohio EPA on November 24, 1993, to the top 100 Toxic Release Inventory reporters and business and industry trade associations for review and comment. This draft Implementation Strategy proposed timelines and deliverables for fulfillment of Governor Voinovich's request.

Based upon comments received on the Ohio Pollution Prevention 2000 draft, the initiative was renamed the Ohio Prevention First initiative to acknowledge that the planning initiative incorporated activities other than pollution prevention. This name change also reflects several items that have been incorporated from a previous voluntary pollution prevention program entitled the Ohio 50 Plus that was proposed in 1992. The Ohio 50 Plus program was never formally initiated. The Ohio Pollution Prevention 2000 is now being used to describe a series of pollution prevention and pollution reduction related initiatives throughout Ohio. The Ohio Prevention First is one initiative of the Ohio Pollution Prevention 2000 program.

Other changes in the planning initiative have been made based upon comments received by Ohio EPA. These include: allowing "credit" toward reduction commitments for activities other than pollution prevention; only requesting nonconfidential summaries of plans, rather than the entire plan; and expanding the initiative beyond the businesses originally requested to participate by Governor Voinovich.

2.0 ELIGIBLE PARTICIPANTS

Although Governor Voinovich originally requested the "Top 100" toxic chemical reporters to participate in this initiative, the Ohio Prevention First is being expanded to include all business and industry, local governments, community groups, schools and schools districts, and individual Ohioans.

3.0 CRlTERIA AND LEVELS OF PARTICIPATION

The Ohio Prevention First has two levels of participation: "Ohio Prevention First Partnerships" and "Ohio Prevention First Industrial Leadership."

3.1 Ohio Prevention First Partnership

To participate at the "Partnership" level, participants are required to commit to one or more of the following pollution prevention or environmentally beneficial activities, and provide an annual progress report on activities, due one year after initially signing up for the initiative and annually thereafter:

Business and Industry

1. Prepare multi-media pollution prevention and/or pollution reduction plans to reduce the amount of all types of waste (i.e., hazardous, solid or other types of waste, wastewater, air pollution, and/or SARA 313 toxic chemicals) generated by a significant amount by the year 2000. Plans may focus on one or more of these wastes.
2. Establish water and/or energy conservation programs.
3. Participate in U.S. EPA's "Green Lights" Program.
4. Participate in U.S. EPA's "33/50" Program.
5. Conduct environmental audits to plan pollution prevention and/or pollution reduction projects to improve or maintain compliance.
6. Form a citizens advisory committee to establish a forum for interaction with the community.
7. Host conferences and workshops on environmental issues and pollution prevention.
8. Develop plans to decrease all forms of nonpoint source pollution above and beyond current Stormwater Pollution Prevention Planning requirements.
9. Organize or participate in a water quality monitoring group or ground water protection program.
10. Establish a company recycling program for paper and other materials and using manufacturing and office products made from recycled materials.
11. Completion of a facility-wide or process-specific pollution prevention assessment.
12. Support community programs involving household hazardous waste collection, ground water protection, surface water quality monitoring, environmental education or other programs that benefit the local community and Ohio's environment.
13. Promote environmental education by providing speakers, education materials or in-kind services for school or community environmental education.
14. Serve on city and state environmental committees and task forces.
15. Complete an assessment which identifies barriers to implementing pollution prevention practices and provide this information to Ohio EPA.
16. Provide pollution prevention technical assistance to suppliers to help them in their waste/pollution reduction activities.
17. Participate in one of U.S. EPA's "Energy Star" Programs.

Local Governments

1. Conduct an environmental audit to identify the amount and types of pollution being generated, to identify pollution prevention strategies and ensure proper control and disposal of pollution that cannot be prevented.
2. Develop community programs for composting yard waste, recycling household garbage, and collecting household hazardous waste and used motor oil.
3. Develop a ground water protection program.
4. Prepare multi-media pollution prevention plans to reduce the amount of all types of waste (i.e., hazardous, solid or other types of waste, wastewater, air pollution, and/or SARA 313 toxic chemicals) generated by a significant amount by the year 2000. Plans may focus on one or more of these wastes.
5. Sponsor or support citizen water quality monitoring, groundwater protection or cleanup programs.
6. Participate in U.S. EPA's "Green Lights" Program.
7. Participate in U.S. EPA's "Cool Communities" Program.
8. Create citizens advisory committees to help develop environmental action plans.
9. Purchase office products and other materials made from recycled materials.
10. Provide environmental and energy and water conservation information to local citizens.

Community Groups

1. Work with local government to implement a storm drain labeling program.
2. Implement a water or energy conservation education campaign or project.
3. Support or develop community programs that address commercial and household garbage recycling, composting yard waste, household hazardous waste collection, used motor oil collection and recycling, and other community environmental needs.
4. Organize or participate in a groundwater protection program.
5. Organize or participate in a citizen water quality monitoring group.
6. Organize or provide volunteers for community cleanup of roads, parks, lakes, rivers and neighborhoods.
7. Sponsor community workshops, or environmental education events or materials.
8. Assist local schools in environmental education by providing knowledgeable speakers, environmental materials or other assistance.
9. Promote the purchase of recycled goods.
10. Form "Citizen Advisory Groups" to work cooperatively with industry on pollution prevention and pollution reduction programs.
11. Work with local governments to promote pollution prevention.

Schools and School Districts

1. Provide environmental education at every grade level.
2. Implement recycling and composting programs within school facilities.
3. Conduct an environmental audit of labs, cafeterias, and other facilities to develop pollution prevention strategies and ensure proper control and disposal of hazardous materials and other materials.
4. Sponsor school environmental fairs, exhibits or other events that promote environmental education.
5. Purchase paper and other products made from recycled materials.
6. Implement energy and water conservation projects.
7. Participate in U.S. EPA's "Green Lights" Program.

All Ohioans

1. Participate in and support all community environmental and recycling programs.
2. Compost yard waste in your own backyard if a community program does not exist.
3. Use natural alternatives to pesticides and household products containing hazardous materials.
4. Buy products made from recycled materials and avoid products that are overpackaged.

3.2 Ohio Prevention First Industrial Leadership

To participate at the "Industrial Leadership" level, participants are required to complete all of the following:

Within Six Months

1. Provide a reduction pledge to Ohio EPA for the types of wastes and/or pollution deemed appropriate by the company.
   
   
2. Provide a signed pollution prevention policy statement to Ohio EPA from a high ranking corporate official, preferably the CEO or an individual with authority and fiscal responsibility for the facility. 3. Provide a summary of previous and existing pollution prevention and/or pollution reduction efforts to Ohio EPA.
   
   
3. Provide a commitment from the company to report all reductions achieved through pollution prevention activities separately from reductions made through treatment, energy recovery or other pollution control or pollution reduction methods.

   Within Two Years

4. Develop a pollution prevention and pollution reduction plan and provide a non-confidential summary of this information to Ohio EPA within two years.

   Annually thereafter

5. Provide a annual report to Ohio EPA on the companies progress towards meeting its reduction commitment.

An explanation of each of these items is provided below. A discussion of deadlines for submittal of information is contained in Sections 4.0 and 5.0.

3.2.1 Within six months, provide a reduction pledge to Ohio EPA for the types of wastes and/or pollution deemed appropriate by the company.

In order to provide a measure of progress to the public, a reduction pledge is being requested from companies participating in this initiative. This pledge should specify the types of pollution to be prevented or reduced and the timeframe when reductions will occur. One of the objectives of the Ohio Prevention First initiative is seeking a 50 percent statewide reduction in toxic chemical releases and hazardous waste by the year 2000. While companies are encouraged to make reduction pledges consistent with this objective, they may make any reduction pledge they believe is appropriate. Ohio EPA realizes that reduction pledges may be tied to anticipated research and development activities. Therefore, companies are provided the flexibility to modify reduction pledges based on the success of these activities or for other unforeseen reasons that are beyond the direct control of the company.

Even though this initiative is emphasizing the reduction of toxic releases and hazardous wastes, companies are encouraged to provide reduction pledges for all of the various types of pollution they may generate. These may include air emissions, wastewater discharges, non-hazardous solid wastes, and nonpoint source pollution in addition to toxic chemical releases and hazardous waste.

3.2.1.1 Baseyear

Companies are encouraged to use the 1988 reporting year for all reduction commitments. This baseyear is also used for U.S. EPA's 33/50 Program. Using 1988 provides credit to those companies who volunteered to participate in the 33/50 Program. Companies may use another baseyear if they deem it more appropriate. Companies are encouraged to provide reduction commitments for all of the toxic releases at their facilities and not just the 17 chemicals targeted in the 33/50 Program.

3.2.1.2 Types of Waste

Companies are encouraged to go beyond toxic chemical releases and hazardous wastes and make reduction pledges for any other type of pollution they may generate. For these other types of pollution, companies are encouraged to use a 1988 baseline year unless another baseyear is more appropriate. Reductions pledges may vary between different types of pollution.

3.2.2 Within six months, provide a signed pollution prevention policy statement to Ohio EPA from a high ranking corporate official, preferably the CEO or an individual with authority and fiscal responsibility for the facility.

Examples of pollution prevention policy statements that may be used for this item are included on page 21 of Ohio EPA's Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual. This type of high-level commitment is needed to ensure that pollution prevention practices receive support throughout the company. Companies are encouraged to modify these examples as they see fit. Some companies may already have this type of corporate policy and are encouraged to submit these policy statements to fulfill this requirement for participation at the "Industrial Leadership" level. However, the policy statement must clearly state that the company adheres to the waste management hierarchy identified in the federal Pollution Prevention Act of 1990. This hierarchy states as national policy that wherever feasible, source reduction should be pursued over recycling, recycling should be pursued over treatment, and disposal should be used only as a last resort.

Ohio EPA understands that technical and economic considerations may make strict adherence to this hierarchy difficult and believes that companies should have the flexibility to choose the options best suited to their needs. However, adherence to this hierarchy only commits a company to investigate source reduction options first, and then determine whether this or other pollution prevention and/or pollution reduction options should be pursued.

3.2.3 Within six months, provide a summary of previous and existing pollution prevention and/or pollution reduction efforts to Ohio EPA.

Ohio EPA believes that many companies participating in this initiative may already be undertaking pollution prevention and/or pollution reduction activities. In order to acknowledge these activities and provide recognition for ongoing programs, a summary of previous and existing pollution prevention and/or pollution reduction efforts is requested. This summary does not need to be highly detailed or comprehensive and must not contain any confidential or proprietary information. Appendix H in Ohio EPA's Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual discusses confidential and proprietary information. A detailed format is not being specified for this summary, however, companies are requested to provide the following information:

1. Any existing pollution prevention policy statement from a high ranking corporate official, preferably the CEO or an individual with authority and fiscal responsibility for the facility. This policy statement can also be used for Section 3.2.3 as long as the criteria listed in that section are met;
2. Non-confidential summaries of any existing pollution prevention/reduction plans or descriptions of existing pollution prevention and pollution reduction activities;
3. The amount and types of pollution prevented or reduced;
4. Any economic savings realized through pollution prevention or pollution reduction efforts; and
5. A description of the manufacturing or industrial processes at the facility where pollution prevention or pollution reduction activities were completed.

3.2.4 Within six months, provide a commitment from the company to report all reductions achieved through pollution prevention activities separately from reductions made through treatment, energy recovery or other pollution control or pollution reduction methods.

Reduction commitments can be met through pollution prevention or pollution reduction activities. However, it is extremely important for companies involved in this initiative to report all reductions achieved through pollution prevention activities separately from reductions made through treatment, energy recovery or other pollution reduction methods.

3.2.5 Develop a pollution prevention and pollution reduction plan and provide a nonconfidential summary of this information to Ohio EPA within two years.

Ohio EPA has completed the Ohio Pollution Prevention and Waste Minimization Guidance Manual to assist companies in preparing plans. This guidance has been reviewed by a number of Ohio companies, industry and trade organizations and public groups. Companies are encouraged to prepare plans using this guidance but may use whatever format they deem to be appropriate. When preparing plans for this initiative, companies should be aware of the following points:

a. Companies are encouraged to use the guidance manual in preparing plans for this initiative. However, use of this guidance is not required. This guidance is provided solely to assist companies if they choose to use it. Companies may use any guidance or format they deem appropriate. Companies who choose to use the guidance only need to complete the portions of the guidance which they deem appropriate and only need to implement options they deem to be technically and economically feasible.

b. Confidential and proprietary business information will not be accepted as part of a company plan summary. One of the primary objectives of this initiative is to publicly recognize companies' pollution prevention and pollution reduction efforts by making plan summaries available to the public. This cannot be achieved with confidential and proprietary information.

c. Pollution prevention and pollution reduction plans should cover all wastes and/or types of pollution a facility may generate. Plans should not be limited solely to the types of pollution addressed in the reduction pledge. However, facilities may focus on whatever types of wastes and/or pollution they consider to be a priority. The Office of Pollution Prevention is available to provide assistance in plan preparation and answer any questions you may have regarding this part of the initiative.

3.2.6 Provide a annual report to Ohio EPA on the company's progress toward meeting its reduction commitment.

In order to publicize the progress companies are making toward meeting their reduction commitments, Ohio EPA is requesting companies to submit an annual progress report to the Office of Pollution Prevention on annual basis. The first progress report is due one year after the company submits detailed summary of its plan. In other words, the first progress report is due three years after a company signs up to participate in the program. The last progress report will be due in 2000. Due dates for progress reports for the "top 100" are discussed in Section 5.0.

4.0 DEADLINES FOR SUBMITTAL OF INFORMATION

Organizations or individuals wishing to participate at the "Partnership" level should provide a written summary of their activities along with their name, address and phone number. A progress report should submitted one year after the date this summary has been submitted, and annually thereafter through 2000.

Companies wishing to participate at the "Industrial Leadership" level should initially submit items 3.2.1 through 3.2.4 within six months after submitting a written request Ohio EPA to participate in the initiative. A non-confidential summary of their plan (item 3.2.5) should be submitted to Ohio EPA within two years from the date a company submits their written request to participate in this initiative. The first annual progress report should be submitted one after the non-confidential summary of their plan (item 3.2.5) is submitted, and annually thereafter.

All information should be submitted to the Office of Pollution Prevention (see contact information below).

5.0 DEADLINES AND SUBMITTAL OF INFORMATION FOR THE "TOP 100"

Companies in the "Top 100" (those requested by Governor Voinovich to prepare pollution prevention plans on September 1, 1993) are being requested to participate at the "Industrial Leadership" level in order to fulfill the Governor's request. Companies were selected for the Ohio Prevention First initiative using 1991 Toxic Release Inventory data. Only data pertaining to toxic chemical releases was used to derive the "Top 100" list. Release numbers were taken directly from the information provided to Ohio EPA by companies required to report.

On October 20, 1993, Governor Voinovich informed the CEO's of the "Top 100" about this initiative through personnel correspondence. Governor Voinovich has asked the Ohio EPA to coordinate Ohio Prevention First, and more importantly, provide assistance to participating companies. Many of the companies involved in this effort have already demonstrated their support for Governor Voinovich's initiative. Ohio EPA looks forward to working with all companies to complete this initiative in a cooperative manner.

Companies in the "Top 100" are requested to provide Ohio EPA with initial information (items 3.2.2 through 3.2.5) within six months, and a non-confidential plan summary (item 3.2.1) within two years. This initiative is scheduled to formally begin on March 15, 1994. All timelines for information submittal are based on this date.

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SUMMARY OF DEADLINES FOR THE "TOP 100"

* ITEMS 3.2.1 THROUGH 3.2.4 IN THE "INDUSTRIAL LEADERSHIP" SECTION ARE BEING REQUESTED BY SEPTEMBER 15, 1994.

* NON-CONFIDENTIAL SUMMARIES OF POLLUTION PREVENTION PLANS (ITEM 3.2.5 IN THE "INDUSTRIAL LEADERSHIP" SECTION) IS REQUESTED TO BE SUBMITTED TO OHIO EPA BY MARCH 15, 1996.

* ANNUAL PROGRESS REPORTS (ITEM 3.2.6 IN THE "INDUSTRIAL LEADERSHIP" SECTION) ARE REQUESTED TO BE SUBMITTED TO OHIO EPA BY MARCH 15, 1997 AND ANNUALLY THEREAFTER WITH THE LAST PROGRESS REPORT SUBMITTED ON MARCH 15, 2000.

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6.0 REWARDS AND RECOGNITION

An important aspect of Ohio Prevention First is the recognition participants receive for outstanding environmental projects and their contributions to pollution prevention and pollution reduction. Ohio EPA will be tracking the submittal of information by participating companies, organizations and individuals. Updates on participation will be provided on a biannual basis through a Ohio Prevention First progress report. All organizations and individuals participating in the program will be recognized in progress reports. Due to changes in the Toxic Release Inventory and other environmental databases since 1988, Ohio EPA will primarily rely on data and information submitted by participants to gauge the progress being made towards achieving reduction commitments.

All Ohio Prevention First "Partners" will receive a Certificate of Participation from Ohio EPA. Companies participating at the "Industrial Leadership in Pollution Prevention" level will receive a Certificate of Participation from Governor Voinovich and be encouraged to apply for the Annual Governor's Award for Outstanding Achievements in Pollution Prevention for those activities which meet the criteria established for that program.

Ohio EPA will be working with interested parties to develop additional recognition programs to help promote Ohio Prevention First throughout Ohio and provide incentives for participation.

7.0 CONCLUSION

The Ohio EPA Office of Pollution Prevention will provide technical assistance in preparing plans if requested by participating companies. We encourage you to contact the Office of Pollution Prevention if you would like to arrange a meeting, discuss your pollution prevention program, or have Office of Pollution Prevention staff visit your facility. The Office of Pollution Prevention can be contacted at (614) 644-3469.

Ohio EPA looks forward to working with your organization on completing this initiative. A cooperative relationship is essential in demonstrating the substantial environmental benefits that can be gained through non-legislative and nonregulatory approaches to pollution prevention. This initiative provides a very important opportunity for Ohio business and industry and others to demonstrate a leadership role in environmental protection without the need for additional regulatory mandates.