CHAPTER 2 of U.S. EPA Facility Pollution Prevention Guide, EPA/600/R-92/088 DEVELOPING A POLLUTION PREVENTION PROGRAM Pollution prevention planning is a comprehensive and continual evaluation of how you do business, and the resulting program will affect many functional areas within your company. Therefore, it has much in common with the planning you already do for other aspects of your business operations. Figure 3 illustrates the major steps in the pollution prevention program. These steps are described in this chapter and in Chapters 3 through 5. This chapter considers the elements of pollution prevention program design as they might be addressed by a small- or medium- sized company. These elements include building support for pollution prevention throughout the company, organizing the program, setting goals and objectives, performing a preliminary assessment of pollution prevention opportunities, and identifying potential problems and their solutions. Pollution prevention should be integrated into your overall business plan. ESTABLISH THE POLLUTION PREVENTION PROGRAM Executive Level Decision In some companies, the initiative to investigate setting up a pollution prevention program will be taken at the executive level. In others, lower-level managers or employees will be the catalysts. In either case, it may be necessary to gather information to demonstrate that pollution prevention opportunities exist and should be explored. This information will be used by company executives as they weigh the potential value of pollution prevention and decide whether to commit the resources necessary to develop and implement the program. One way to gather this information is to perform a preliminary assessment. A pre-assessment is part of the formal program design effort and is, therefore, described later in this chapter. However, a high-level pre-assessment of only one or two areas of the facility can be done to gather information and, perhaps, even identify several low-cost, quick-payoff pollution prevention techniques that can be implemented readily. Once senior managers have decided to establish a pollution prevention program, they should convey this commitment to all employees through a formal policy statement. This will establish a framework for communicating the formal commitment throughout the organization. Establish the Pollution Prevention Program -Executive Level Decision -Policy Statement -Consensus Building Organize Program -Name Task Force -State Goals Do Preliminary Assessment -Collect Data -Review Sites -Establish Priorities -Look again at Establishing a Pollution Prevention Program Write Program Plan -Consider External Groups -Define Objectives -Identify Potential Obstacles -Develop Schedule Do Detailed Assessment -Name Assessment Team(s) -Review Data and Site(s) -Organize and Document information Define Pollution Prevention Options -Propose Options -Screen Options Do Feasibility Analyses -Technical -Environmental -Economic Write Assessment Report Implement the Plan -Select Projects -Obtain Funding -Install Measure Progress -Acquire Data -Analyze Results -Start Again at Detailed Assessment Maintain Pollution Prevention Program Figure 3. Pollution Prevention Program Overview Policy Statement As with other policy statements your company develops, your pollution prevention policy statement should state why a program is being established, what is to be accomplished in qualitative terms, and who will do it. Two example policy statements are given in Box 6. They differ in level of detail, but both answer these key questions: Why are we implementing pollution prevention? We want to protect the environment. What will be done to implement pollution prevention? We will reduce or eliminate the amounts of all types of waste, and we will improve energy efficiency. Who will implement pollution prevention? Everyone will be involved. The policy statement is the foundation of the pollution prevention program. Consensus Building After you have developed your pollution prevention policy statement, consider how it should be presented to your employees so that they will see it as an ongoing, company-wide commitment. It is essential that employees understand and support the pollution prevention program. Everyone in your facility will be involved in some way.  POLICY STATEMENT EXAMPLE 1 - "(Your Company Name) is committed to excellence and leadership in protecting the environment. In keeping with this policy, our objective is to reduce waste and emissions. We strive to minimize adverse impact on the air, water, and land through pollution prevention and energy conservation. By successfully preventing pollution at its source, we can achieve cost savings, increase operational efficiencies, improve the quality of our products and services, maintain a safe and healthy workplace for our employees, and improve the environment. (Your Company Name)'s envi- ronmental guidelines include the following: - Environmental protection is everyone's responsibility. It is valued and displays commitment to (Your Company Name). - We will commit to including pollution prevention and energy conservation in the design of all new products and services. - Preventing pollution by reducing and eliminating the generation of waste and emissions at the source is a prime consideration in research, process design, and plant operations. (Your Company Name) is committed to identifying and implementing pollution prevention opportunities through encouraging and involving all employees. - Technologies and methods which substitute nonhazardous materials and utilize other source reduction approaches will be given top priority in addressing all environmental issues. - (Your Company Name) seeks to demonstrate its responsible corporate citizenship by adhering to all environmental regulations. We promote cooperation and coordination between industry, government, and the public toward the shared goal of preventing pollution at its source."  POLICY STATEMENT EXAMPLE 2 - "At (Your Company Name), protecting the environment is a high priority. We are pledged to eliminate or reduce our use of toxic substances and to minimize our use of energy and generation of all wastes, whenever possible. Prevention of pollution at the source is the preferred alternative. When waste cannot be avoided, we are committed to recycling, treatment, and disposal in ways that minimize undesirable effects on air, water, and land." (Adapted from: Waste Reduction Institute for Training and Applications Research, Inc. [WRITAR], Survey and Summaries, 1991, and Minnesota Office of Waste Management, Feb. 1991, Minnesota Guide to Pollution Prevention Planning) Box 6 While executives and managers will assign priorities and set the tone for the pollution prevention program, the attitude of production-level employees will have a significant effect on its success. Since it is their daily activities that generate waste, their support of the program is essential. How you publicize the policy depends on the size and the culture of your company. You may decide to call a general meeting or to hold several meetings with smaller groups. There may be other types of publicity that you have found effective. You might offer bonuses or other awards to employees who suggest ways to prevent pollution. Announcing awards in newslet- ters or on bulletin boards provides additional incentive to employees and further publicizes the program. Pollution preven- tion might be included in job objectives and performance evaluations for managers and other appropriate employees. In any case, it is important to emphasize your company's commitment to pollution prevention and encourage employee participation. This will help to establish a positive atmosphere and reassure employees who might be concerned about the changes that will result. This approach will also elicit worthwhile pollution prevention suggestions. Encourage employee participation. A positive atmosphere produces best results. Employees feel committed to pollution prevention when they are encouraged to:  Help define company goals and objectives.  Review processes and operations to determine where and how toxic substances are used and hazardous wastes are generated.  Recommend ways to eliminate or reduce waste production at the source.  Design or modify forms and records to monitor materials used and waste.  Find ways to involve suppliers and customers.  Think of ways to acknowledge and reward employee contributions to the pollution prevention effort. Box 7 ORGANIZE THE POLLUTION PREVENTION PROGRAM The program will be directed by the Pollution Prevention Task Force. Their first task will be to delineate program goals. Name the Pollution Prevention Task Force The people who will direct the pollution prevention program should be selected carefully. They will have overall responsibility for developing the plan and directing its implementation. Their capabilities and their attitudes toward the effort will be major determinants of how successful it is. As with other areas of your operation, successful program execution will require integration and continuity of the planning, implementation, modification, and maintenance stages. Therefore, all individuals named to this task force should have substantial technical, business, and communication skills as well as thorough knowledge of the company. The responsibility and authority of each individual should be established during this organizational stage. The program leader should be named from the highest level practical. The leader must have the authority and the influence necessary to keep the program on track and to ensure that pollution prevention becomes an integral part of the overall corporate plan. The role of the leader is to facilitate the flow of information among all levels in the company. Therefore, the leader should possess the personal qualities necessary to elicit broad-based support from the company's employees. The task force works together during planning and preassessment. One or more pollution prevention champions should be desig- nated. The task of a "champion" is to overcome possible resistance to proposed changes in operations. In a medium-sized company, several champions may be assigned, perhaps according to production area. In a very small company, the champion may also be the program leader. Champions will be the team members who are the most visible within the production areas and should be respected and trusted at all levels in order to perform this liaison role well. Other team members might be selected for their specific technical or business expertise. Environmental and plant process engineers, production supervisors, and experienced line-workers are good candidates. Other potential sources include purchasing and quality-assurance staff. In some cases, outside consultants may be retained to work with the in-house team. Once the task force has been established, they will be a valuable resource within the company. When plans are being made to expand the facility or to design or redesign products, they can review the plans to determine whether waste generation has been evaluated thoroughly. The task force will direct the development and implementation of the pollution prevention program and help integrate its principles into all phases of corporate planning. State Goals The program leaders will need to establish goals that state the long-term direction for the pollution prevention program. Well-defined goals will help to focus effort and build consensus. Goals should be consistent with your company's pollution preven- tion policy and, in fact, may have been stated in general terms in the policy statement. Now, they need to be stated more specifically. The goal-setting process will involve the program team and company management. The size of the group needed to develop the goals depends on the size and complexity of your facility. For a small company, the group might be only two or three people. Since success in pollution prevention may require basic changes in the corporate culture, goals should be useful and meaningful for every employee. Goals need to be challenging enough to motivate but not unreasonable or impractical. When beginning the goal-setting process, consider starting from the zero-discharge perspective. This ideal situation would involve 100% utilization of resources, eliminating disposal costs and regulatory compliance needs. This is probably not a com- pletely achievable goal in any industry, given current technology. However, like zero-defect production goals, zero- discharge goals encourage an attitude of continually striving for improvement. Pollution prevention goals can be qualitative, such as, "achieve a significant reduction of toxic substance emissions to the environment." Quantitative goals are more difficult to develop but are worth the extra effort. They spell out your pollution prevention commitment and give all participants and observers a yardstick for measuring progress. Finally, goals should be flexible and adaptable. Conditions change in actual practice. As your pollution prevention program becomes more focused and the pollution-specific aspects of the operation become better known, the goals can be refined. They can be adjusted up or down as the program matures and lessons are learned. Periodic goal-achievement review and adjustment will keep your program active and visible within the company. Your corporate pollution prevention policy and goals should be integrated in a formal planning document. Goals should be: -well-defined -meaningful to all employees -challenging yet achievable -flexible -part of a program planning document. Polaroid's Toxic Use and Waste Reduction program...aims to reduce toxic use at source and waste per unit of production by 10% per year.... -From an interview with Bill Schwalm, a senior manager at Polaroid, Environmental Business Journal, December, 1991. DO THE PRELIMINARY ASSESSMENT Even though you may have completed some aspects of the pre- liminary assessment as input to the executive decision to develop a pollution prevention program, a deeper examination will be needed at this point. The data collection that is a part of this pre-assessment will help the team review the data that are already available and begin defining ways to process that data. These data and the site visits will enable the Task Force to establish priorities and procedures for detailed assessments. Chapter 3 describes the detailed assessment phase and the more in-depth data collection and analyses that will be done at that stage. Collect Data The extent and complexity of the system for collecting pollution prevention data should be consistent with the needs of your company. Keep in mind that the goal of the program is to prevent pollution, not to collect data - the simplest system that fits your needs is the best. Depending on the nature and size of your firm, much of the data needed for a pollution prevention program may be collected as a normal part of plant operations or in response to existing regulatory requirements. (See Box 8.) The worksheets in Appendix A can be used for the pre-assessment; you may decide to modify them to fit your particular industry. An all-media approach, which deals with all air, water, and solid waste emissions and releases, will be the most effective. This involves considering all waste streams, identifying their sources and quantifying the true costs of pollution control, treatment, and waste disposal. There are a number of information sources to consider. Regulatory reports - National Pollutant Discharge Elimina- tion System (NPDES) and SARA Title III reports document the volume, composition, and degree of toxicity of wastewater dis- charged. The toxic substance release inventories required by SARA Title III, Section 313 may provide information on emissions into all environmental media. Engineering and operating data - Shipping manifests will provide quantities of hazardous waste shipped during a given period, but may lack chemical analysis, specific source, and the time period during which the waste was generated. The plant design documents and equipment operating manuals and procedures may yield specific data for streams inside of the plant. Plant business records - Records available from inventory control, purchasing, records management, accounting, marketing, and training can provide data needed for the pre-assessment and may themselves present opportunities for pollution prevention. For example, improved inventory control and judicious purchasing can significantly reduce the volume of raw materials that must be disposed of because they become outdated. In reviewing existing data, you may find that current accounting practices are not appropriate for placing the burden of pollution and pollution control at the point of generation. These findings should be taken into account when costs of pollution control measures are analyzed. (See Chapter 6.) Review existing information resources. Data sources for facility information include: Regulatory Information:  Waste shipment manifests  Emission inventories  Biennial hazardous waste reports  Waste, wastewater, and air emissions analyses, including intermediate streams  Environmental audit reports  Permits and/or permit applications  Form R for SARA Title III Section 313 Process Information:  Process flow diagrams  Design and actual material and heat balances for: - production processes - pollution control processes  Operating manuals and process descriptions  Equipment lists  Equipment specifications and data sheets  Piping and instrument diagrams  Plot and elevation plans  Equipment layouts and logistics Raw Material/Production Information:  Product composition and batch sheets  Material application diagrams  Material safety data sheets  Product and raw material inventory records  Operator data logs  Operating procedures  Production schedules Accounting Information:  Waste handling, treatment, and disposal costs  Water and sewer costs, including surcharges  Costs for nonhazardous waste disposal, such as trash and scrap metal  Product, energy, and raw material costs  Operating and maintenance costs  Department cost accounting reports Other Information:  Environmental policy statements  Standard procedures  Organization charts Box 8 Visit Sites In order to utilize resources of time, staff, and money wisely, the task force will need to prioritize the processes, operations, and wastes that will be addressed during the subsequent detailed assessment phase. During that phase, they will target the most important waste problems, moving on to lower-priority problems as resources permit. The pre-assessment site visits will provide the information needed to accomplish this prioritization and to designate the detailed assessment teams, who will be selected for their expertise in particular areas. Site visits make it possible to:  prioritize areas  select detailed assessment teams Typical considerations for prioritizing waste streams for further study include:  compliance with current and anticipated regulations  costs of waste management (pollution control, treatment, and disposal)  potential environmental and safety liability  quantity of waste  hazardous properties of the waste (including toxicity, flammability, corrosivity, and reactivity)  other safety hazards to employees  potential for pollution prevention  potential for removing bottlenecks in production or waste treatment  potential recovery of valuable by- products  available budget for the pollution prevention assessment program and projects  minimizing waste water discharges  reducing energy use Box 9 Establish Priorities Assigning priorities (Box 9) to processes, operations, and materials will focus the remainder of the pollution prevention plan development effort. The priorities set in this stage will guide the selection of areas for the detailed assessments. Areas may also be targeted based on the volume of waste produced or the cost of waste disposal. Regulatory concerns such as the RCRA land disposal restrictions or SARA Title 313 chemicals may also guide prioritization. The Option Rating Weighted Sum Method, which is illustrated in Appendix E, can be used during the pre- assessment phase as well as during detailed assessment. The priorities established at this point will guide subsequent effort. PREPARE THE PROGRAM PLAN With the information collected during the pre-assessment, the Task Force can develop a detailed program plan. This plan will address the extent to which external organizations will be involved, define pollution prevention program objectives, identify potential obstacles and solutions, and define the data collection and analysis procedures that will be used. A summary of the points that should be addressed in a program plan appears in Box 10. Contacting External Groups At this point, the Task Force should consider soliciting input from outside the company. Including the surrounding community in the pollution prevention planning process can create a new forum for communication. Valuable technical information can also be exchanged with some organizations. Consider working with government officials, community leaders, and other businesses to achieve best results. The formal written pollution prevention plan will include the following elements:  Corporate policy statement of support for pollution prevention  Description of your pollution prevention planning team(s) makeup, authority, and responsibility  Description of how all of the groups (production, laboratory, maintenance, shipping, marketing, engineering, and others) will work together to reduce waste production and energy consumption  Plan for publicizing and gaining company-wide support for the pollution prevention program  Plan for communicating the successes and failures of pollution prevention programs within your company  Description of the processes that produce, use, or release hazardous or toxic materials, including clear definition of the amounts and types of substances, materials, and products under consideration  List of treatment, disposal, and recycling facilities and transporters currently used  Preliminary review of the cost of pollution control and waste disposal  Description of current and past pollution prevention activities at your facility  Evaluation of the effectiveness of past and ongoing pollution prevention activities  Criteria for prioritizing candidate facilities, processes, and streams for pollution prevention projects. Box 10 Legislative and executive officials can provide their perspectives on environmental protection issues and information on their planning processes. In return, they can gain informa- tion that will help them make decisions on future public issues related to the environment. Community involvement is a good way to build credibility and focus pollution prevention efforts on the discharge paths that most concern your neighbors. However, it may be wise to wait until the program is established before seeking to involve the community. Having a few pollution prevention projects underway will demonstrate your good faith. Positive community involvement can be encouraged through holding open meetings, granting interviews to the media, advertising, direct-mail surveys and opinion polls. Other businesses can be a source of information on technical issues and suppliers, either because they are in the same geographical area or because they have similar technical areas of interest. Local business groups are a good way of locating resources in the immediate area, while trade and professional associations can provide contacts in other parts of the country or the world. Of course, the companies with the most similar interests may be competitors, but it should be possible to interact without risking disclosure of business-sensitive information. Communication with government and community leaders yield mutual benefits. Other businesses will have useful information. Define Objectives During the preliminary assessment phase, the program team will have identified opportunities for pollution prevention and will have worked with the executive group to establish priorities. These will be the starting point for defining short- and long-range objectives. Objectives are the specific tasks that will be necessary to achieve goals. For example, in order to reach a goal of reducing waste, the objectives might be defined as reducing solvent, paper, and packaging wastes by specific amounts over a stated period of time. Objectives can be defined at the facility- or the department-level, depending on the size and diversity of your company. A small company could decide to develop a single set of objectives to cover all of its operations. A larger company with many facilities or products might develop an overall corporate plan describing goals and objectives, supplemented by facility- or product-specific goals. In any case, the management at each location must understand and support its objectives if the pollution prevention program is to be successful. Objectives should be stated in quantitative terms and should have target dates. These two attributes make objectives effective tools for directing effort and measuring progress. Clorox's environmental executives... want to integrate goals already established by plants into corporate-wide objectives that can be quantified and measured to assess progress. From an interview with Michael Riley, Director of Environmental Marketing at Clorox. Environmental Business Journal, December, 1991. Identify Potential Obstacles As the pollution prevention program team begins to develop and implement a pollution prevention program, they are likely to encounter a number of factors that will complicate the process. These need to be recognized, and the means for overcoming them need to be defined. Apparent obstacles will be less likely to impede the process if everyone understands that there is a mecha- nism for addressing them in a later stage. The mix of factors and the relative degree of difficulty each presents will vary from company to company. Those that are likely to be encountered by most businesses are discussed below. They fall into four broad categories: economic, technical, regulatory, and institutional. Anticipate obstacles and plan to overcome them. Economic Obstacles. The task force should recognize that some complex economic factors may need to be addressed later. Broadly defining procedures now for dealing with them will help prevent economic concerns from stifling the creative process of defining options. Cost-benefit analysis procedures should be defined. Many proposed pollution prevention options will have start-up costs. For example, additional or replacement equipment may need to be purchased, staff training may be required, or alternative raw materials may cost more. Some of these additional costs can be justified readily because they clearly will be cost-effective and will have short pay-back times. However, many will not be so clear-cut and will need more sophisticated analysis. Chapter 6 describes the "Total Cost Assessment" (TCA) approach as it applies to pollution prevention projects and discusses why it may be necessary to look at longer payback times for pollution prevention projects. Limited financial resources for capital improvements may also be a problem, even for options that will ultimately be profitable. The team should investigate the availability of and conditions for funding assistance or low-interest loans from state or local agencies. Appendix D provides information on whom to contact. Possible technical obstacles:  availability of information  disruption of production  product quality changes Technical Obstacles. Information will be needed on alternative procedures that should be considered, how to integrate them in the production process, and what side effects are possible. Information resources could be a problem. As a small or medium-sized business, you may not have ready access to a central source of information on pollution prevention techniques. There are several ways to deal with this problem. Contact appropriate agencies listed in Appendix D for assistance. Encourage employ- ees to watch for information in the technical journals and news- letters they read and to pass it on to the task force. Those who belong to professional societies may get ideas from other members. Metropolitan or university library reference departments can provide assistance in locating sources of published information as well as names of people who might be able to provide information in specific areas. If the scope of the technical problem and resources permits, it may be appropriate to retain a consultant. Limited flexibility in the manufacturing process may pose another technical barrier. A proposed pollution prevention option may involve modifying the work flow or the product or installing new equipment; implementation could require a produc- tion shutdown, with loss of production time. You might be con- cerned that the new operation will not work as expected or might create a bottleneck that slows production. In addition, the production facility might not have space for pollution prevention equipment. These technical barriers can be overcome by having design and production personnel take part in the planning process and by using tested technology or setting up pilot operations. Product quality or customer acceptance concerns might cause resistance to change. For example, in some printing and publishing operations it is possible to minimize waste by substi- tuting a water-based ink for a solvent-based ink. But for some products, quality suffers when water-based ink is used. You should plan to avoid potential product quality degradation by verifying customer needs, testing the new process or product, and increasing quality control during manufacture. There are a number of sources of technical assistance:  Trade associations generally provide assistance and information about environmental regulations and various available techniques for complying with these regulations. Their information is especially valuable because it is tailored to the specific industry.  Published literature can be a valuable resource. Articles in technical magazines, trade journals, government reports, and research briefs describe pollution prevention technologies and applications.  Federal, state, and local environmental agencies are expanding their pollution prevention technical assistance programs. These programs make available information on industry- specific pollution prevention tech- niques. (See Appendix D for addresses and phone numbers of such resources.)  Equipment vendors and sales literature are helpful in identifying and analyzing potential equipment-oriented options.  Consultants - Consultants with experience in pollution prevention in the specific industry can usually be located.  Other Companies. Box 11 Regulatory Obstacles. Regulations may be a barrier to some pollution prevention options. For example, changing to another feed material may require changing the existing permits. In addition, it may be necessary to learn what regulations might apply to proposed alternative input materials. Working with the appropriate regulatory bodies early in the planning process will help overcome this barrier. The U.S. EPA and the state environmental agencies have developed a number of documents to facilitate pollution prevention efforts by industry; some are listed in Appendix G. Points of contact at the appro- priate agencies will be helpful; many are listed in Appendix D. Your local health department and city and county waste dis- posal and treatment offices can also provide assistance. Industry task forces and consultants might also be contacted. Working with regulatory bodies will help resolve questions as to requirements that pertain to proposed changes. Institutional Obstacles. As with any other new program, general resistance to change and friction among elements within the orga- nization may arise. These can result from many factors, such as lack of awareness of corporate goals and objectives, individual or organizational resistance to change, lack of commitment, poor internal communication, requirements of existing labor contracts, or an inflexible organizational structure. Analyze these barriers from different perspectives in order to understand the concerns. Management is concerned with produc- tion costs, efficiency, productivity, return on investment, and present and future liability. Workers are concerned about job security, pay, and workplace health and safety. The extent to which these issues are addressed in the pollution prevention pro- gram will affect the success of the program. Institutional barriers can be overcome with education and outreach programs. As was pointed out earlier, it is vital to gain the support of staff at all levels very early in the pollution prevention effort. Resistance to change and friction among organizational elements can be reduced by effective communication. Develop Schedule The final aspect of planning your pollution prevention program is to list the milestones within each of the stages from detailed assessment through implementation and assign realistic target dates. The execution of these stages (described in Chapter 3) should follow this schedule closely. Significant deviations may cause the program to falter because certain steps are not completed. Adherence to the schedule will also help control the startup or implementation costs of the program.