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Pollution is nothing but the resources we are not harvesting. We allow them to disperse because we are ignorant of their value.
Buckminster Fuller |
On January 26, 1989, the United States Environmental Protection Agency (U.S. EPA) proposed a new pollution prevention policy that is changing the course of environmental protection. On this day the federal agency made a commitment to change its traditional focus from pollution control to pollution prevention. The proposed policy stated:
The Environmental Protection Agency's progress over the last 18 years in improving environmental quality through its media-specific pollution control programs has been substantial. However, EPA realizes there are limits as to how much environmental improvement can be achieved under these programs, which emphasize management after pollutants have been generated. EPA believes further improvements can be achieved by reducing or eliminating discharges and/or emissions through the implementation of source reduction and environmentally sound recycling practices.
EPA's proposed policy encourages organizations, facilities and individuals to fully utilize source reduction techniques in order to reduce risk to public health, safety, welfare and the environment. EPA firmly believes that all sectors of our society must work together to ensure continued environmental protection. Today's notice commits EPA to a preventive program to reduce or eliminate the generation of potentially harmful pollutants.
EPA also believes that State and local government must play a primary role in encouraging this shift in the environmental priorities of all sectors of industry and the public. This notice commits EPA to working with States to develop and implement specific strategies and technical assistance programs to encourage commercial and manufacturing industries, the agricultural sector and the general public to reduce the amount of pollution generated.
U.S. EPA's focus was affirmed by the Pollution Prevention Act of 1990. Congress established a national hierarchy for managing wastes. The environmental management hierarchy includes:
1. prevention (source reduction);
2. recycling;
3. treatment; and
4. disposal or release.
The highest priority in the hierarchy is preventing pollution through source reduction. Source reduction avoids the generation of waste and reduces the cost of collecting, storing and treating the waste.
What is Pollution Prevention?
U.S. EPA's definition of pollution prevention: Pollution prevention (P2) is source reduction and other practices that reduce or eliminate the creation of pollutants through the increased efficiency in the use of raw materials, energy, water or other resources, or the protection of natural resources by conservation.The Pollution Prevention Act of 1990 defines source reduction as 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. Some practices commonly described as "in-process recycling" may qualify as pollution prevention.
Ohio EPA's definition of Pollution Prevention is:
The use of source reduction techniques in order to reduce risk to public health, safety, welfare and the environment and, as a second preference, the use of environmentally sound recycling to achieve these same goals. Pollution prevention avoids cross-media transfers of wastes and/or pollutants and is multimedia in scope. It addresses all types of waste and environmental releases to the air, water and land.Source reduction means: any effort to reduce, at the source, the quantity of waste generated, toxic chemical use, or any release into the environment. Source reduction measures include, but are not limited to, process modifications, feedstock purity, material substitution, good operating and management practices, increases in the efficiency of machinery and recycling within a waste generating or other production process.
Recycling means: to use, reuse or reclaim a material. It does not include burning waste as fuel.
Reuse means: reusing a material in an environmentally sound manner that will not result in a hazard to human health or the environment. A material is reused if it is either:
- employed as an ingredient, including use as an intermediate in an industrial process to make a product, or
- used in a particular function or application as an effective substitute for a commercial product.
What Isn't Pollution Prevention?
Under the Pollution Prevention Act of 1990, recycling, energy recovery, treatment and disposal are not included within the definition of pollution prevention. Examples which do not constitute pollution prevention may include, but are not limited to, the following:- sending waste or toxic chemicals off-site for management other than environmentally sound recycling
- incineration or other thermal treatment
- treatment to reduce volume
- treatment to reduce toxicity
- bankruptcy or reduction in production volume
- use of equipment to reduce water content and volume
- installation of end-of-pipe equipment to comply with pollution control regulations.
- delisting of a hazardous waste or toxic chemical
- energy recovery
Benefits of Pollution Prevention
The potential benefits of pollution prevention are numerous. Benefits can occur in the areas of the environment, health, economics, regulations, liability and public image.Environmental Benefits
Environmental benefits can include: protection of the environment from further degradation, prevention of irreversible environmental problems, and a reduced rate of depletion of natural resources.Health Benefits
Pollution prevention is beneficial to both the public and workers. Benefits include reduced risks to human health and safety, and reduced worker exposure to toxic chemicals.Economic Benefits
Pollution prevention has the potential to increase the efficiency and competitiveness of American industry. Economic incentives can be significant, depending on the type of industry, the nature of the processes and the competitive business environment. Cost savings can include:- reduced waste treatment and disposal costs
- reduced raw material costs
- reduced transportation costs
- reduced compliance costs for permits, monitoring and enforcement
- reduced production costs through better management
- income derived through sale or reuse of waste
- reduced energy costs
Regulatory Benefits
Companies will find it easier to maintain compliance after a pollution prevention program has been established. Reduced regulatory requirements are also a result of pollution prevention initiatives.Liability Benefits
Pollution prevention can reduce liability for environmental problems at both on-site and off-site treatment, storage and disposal facilities. It also can lower the risk of spills, accidents and emergencies, and it helps protect workers.Public Image Benefits
Society is becoming increasingly aware of the environmental hazards associated with all types of waste. U.S. EPA publishes details of companies' waste and pollution prevention efforts through the Toxics Release Inventory. The U.S. EPA publicly recognizes those companies that make voluntary commitments to pollution prevention. To enhance their public image companies are implementing and publicizing pollution prevention activities. Measurement criteria for management systems like ISO 14000 can also be improved by implementing pollution prevention.Barriers to Pollution Prevention
Despite the incentives, a variety of perceived or actual barriers exist. Barriers exist in the current institutional, economic and financial structures and in informational and regulatory frameworks.Economic factors can be substantial barriers. Many firms have an insufficient capital base for investing in source reduction technologies. Many firms operate on a time horizon that is too short to realize significant economic benefits from pollution prevention activities. In many organizations, pollution costs are still treated as overhead, when they should be allocated to individual products or cost centers. This reduces the incentive to invest in pollution prevention. Firms that develop preventive technologies may be reluctant to share their trade secrets with competitors. Over time, these and other barriers will be eliminated through education, partnership initiatives and a strong commitment to pollution prevention.
Legal Barriers to Pollution Prevention
Stringent legal requirements such as some in permits and rules can create disincentives to pollution prevention implementation. U.S. EPA and the states are implementing changes and reviewing options for making the regulatory system less likely to discourage prevention. Revised regulatory requirements could give waste generators incentives to reduce more waste and avoid permits or rule requirements.Examples of Successful Pollution Prevention
All of the pollution prevention programs described in this section resulted in net savings to the organizations through reduced material costs and reduced expenses for the treatment, storage and disposal of wastes.The City of Cincinnati replaced solvent based paints with waterborne paints for highway line striping lowering their Violatile Organic Hydrocarbon (VOC) emissions by 36,000 lbs. and lead releases by 33,000 lbs. The Chrysler Corporation, Toledo Assembly Plant, through product reformulation, developed a surfactant to replace a glycol-ether auto body wash system. This reformulation resulted in decreased glycol ether air and water emissions of 400,000 lbs. per year.
The University of Cincinnati through the EPA's Green Lights Program, retrofitted lighting fixtures with new fluorescent lamps. The result was an energy savings of $1.3 million dollars per year. These savings averted layoffs and provided training for existing and new employees.
Honda of America Manufacturing, East Liberty, installed water-based painting for finishing auto bodies which significantly reduced VOC emissions. Amko Plastics, Cincinnati, was among the first to use water-based inks for plastic bag printing to reduce air pollution. Ball Metal Container, Findlay, the Chrysler Corporation Toledo Assembly Plant, and others have established returnable container programs for shipments received, reducing solid waste and avoiding the need to manage pallets, cardboard and similar waste.
What Is Government Doing?
The Pollution Prevention Act of 1990 established a new, national goal for environmental protection: to reduce or eliminate waste at its source. Since then, U.S. EPA has advanced this policy through practical applications in cooperative efforts, rule development, permits, enforcement, state grants and its budget. Programs are accompanied by voluntary initiatives such as environmental excellence and life cycle analysis projects. U.S. EPA's Green Lights is a voluntary program that encourages the widespread use of energy-efficient lighting.
Many pollution prevention programs also integrate pollution prevention into their regulatory programs. Pollution prevention may be encouraged or actually mandated. The most common vehicles for regulatory incorporation of pollution prevention include: inspections; enforcement; permits; rules; multimedia inspection and permitting; and legislation.
As an example, pollution prevention can be incorporated into enforcement settlements via P2 supplemental environmental projects (SEPs). SEPs are environmentally beneficial projects that a violator agrees to undertake when settling an enforcement action. P2 SEPs generally require a violator to reduce waste generation beyond what is required by law and require the violator to implement more P2 projects than it would in the normal course of business. P2 SEPs generally include specific P2 projects, or a facility-wide audit to identify of pollution prevention opportunities. SEPs provide an additional environmental benefit to the more common compliance and deterrence benefits of standard enforcement.
Ohio EPA continues to focus on more P2 regulatory integration for its functions, including: an initiative to plan an Alternative Regulatory System for a large auto assembly facility and a pilot program to test multi-media pollution prevention (M2P2) inspections.
Ohio and many other state governments now offer a variety of P2 assistance options to industry. Information is provided through telephone hot lines, fact sheets, newsletters, and on the internet. Education is provided through seminars and courses. Technical assistance can be provided by telephone, e-mail or through on-site consultation. Research and financial assistance can also be made available. Ohio EPA offers a Pollution Prevention Loan Program to assist business in implementing P2 projects. Voluntary programs, such as Ohio Prevention First and Green Lights, are additional options.
"P2" - It's Everyone's Responsibility
How much progress is made in pollution prevention will depend on the way we think, and how we go about our daily business. This extends to people in industry, all levels of government, environmental and public interest groups and society as a whole.
Business, engineers and managers should follow the national hierarchy for managing waste, understanding that the best method of reducing pollution is source reduction. Businesses that are willing to share their success stories with others can demonstrate that pollution prevention works. The cooperation and ideas of all employees are necessary for a fully implemented pollution prevention program to be successful.
The single-medium focus (air, water, waste) needs to be expanded to a multimedia approach to prevent transfer of waste from one medium to another. Educators must include pollution prevention in their curricula in order to improve P2 implementation in both the business and government sectors.
Regulatory agencies, educators, business and the communications media must all take responsibility for promoting pollution prevention. As a society, we can accomplish the most in preventing pollution by educating ourselves and working cooperatively. Together we can achieve consensus and build commitment to extend pollution prevention activities to all levels of society.
Additional Information:
Ohio EPA, Office of Pollution PreventionP.O. Box 1049
Columbus, OH 43216-1049
(614) 644-3469
U.S. EPA Pollution Prevention Division, 401 M Street, S.W. Washington, D.C. 20460 (202) 245-4164
U.S. EPA. 1992. Risk Reduction Engineering Laboratory. Facility Pollution Prevention Guide, EPA/600/R-92/088.
Ohio EPA Office of Pollution Prevention. 1993. Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual.
Sources:
Carol M. Browner, EPA Administrator. 1993. EPA Pollution Prevention Policy Statement.
F. Henry Habicht II. 1992. U.S. EPA, memo EPA Definition of Pollution Prevention. May 28, 1992. Washington, D.C.
Ohio EPA Office of Pollution Prevention. 1993. Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual.
This is an updated version of the first in a series of fact sheets Ohio EPA has prepared on pollution prevention.