CHAPTER 5, U.S. EPA Facility Pollution Prevention Guide, EPA/600/R-92/088 MAINTAINING THE POLLUTION PREVENTION PROGRAM The task of maintaining a viable pollution prevention program will made easier with the establishment of a pollution prevention awareness program. Such a program is intended to promote employee involvement in the prevention effort. The objectives of the pollution prevention awareness program are to:  raise awareness of environment-related activities at the facility  inform employees of specific environmental issues  train employees in their pollution prevention responsibilities  recognize employees for pollution prevention efforts  encourage employees to participate in pollution preven- tion  publicize success stories A summary of methods for accomplishing this appears in Box 18 on the next page. Pollution prevention is an ongoing effort that will be best maintained by personnel in the production area. INTEGRATE POLLUTION PREVENTION INTO CORPORATE PLAN Assign Accountability for Wastes Operating units that generate wastes could be charged with the full costs of controlling and disposing of the wastes they generate. Cost accountability should also take into account indirect costs such as potential liability, compliance reporting, and oversight. Burying waste management costs in general over- head can lead to the illusion that disposal is "free." Allocating the costs of waste handling to the operating units that generate the waste reminds unit managers that waste control and disposal are increasingly large factors in the cost of doing business and motivates them to find ways to cease generating the waste. Chapter 6 describes several cost allocation methods. Tracking and Reporting Your information system should track and retain the data necessary to measure pollution prevention program results. You will need to ensure that these data are reviewed and reports pre- pared at meaningful intervals. Key ways to maintain and improve the pollution prevention program:  Integrate pollution prevention into corporate planning: - Assign pollution prevention accountability to the operating units where waste is generated - Track and report program status - Conduct an annual program evaluation at the corporate level  Provide ongoing staff education programs: - Make pollution prevention awareness program a part of new employee orientation - Provide advanced training - Retrain supervisors and employees  Maintain internal communication: - Encourage two-way communication between employees and management - Solicit employees' pollution prevention suggestions - Follow-up on suggestions  Reward personnel for their success in pollution prevention: - Cite accomplishments in performance reviews - Recognize individual and group contributions - Grant material rewards - Consider pollution prevention a job responsibility subject to review  Provide public outreach and education about pollution prevention efforts: - Submit press releases on innovations to local media and to industry journals read by prospective clients. - Arrange for employees to speak publicly about pollution prevention measures in schools and civic organizations. Box 18 Reports should be prepared frequently enough to enable unit managers to monitor and adjust their operations to adhere to the schedule that was established during the planning stage. (See Chapter 2.) In addition, they need this information to provide feedback to their staff, as discussed below. Annual Program Evaluation Top management can demonstrate continuing commitment to the program by conducting annual reviews of the program. The results of these annual reviews should be communicated to all employees through written announcements and meetings. Program successes should be recognized and any changes in objectives or policies announced and explained. If these company-level reviews demonstrate chronic schedule slippage, company executives and the pollution program task force should meet to reevaluate the program. Some objectives or the approach to achieving them may need to be adjusted. The purpose is to maintain the same high profile the pollution prevention program had initially. STAFF EDUCATION One of the most important elements of the waste minimization and pollution prevention awareness program is training. The training program should include all levels of personnel within the company. The goal is to make each employee aware of waste generation, its impact on the site and the environment, and ways waste can be reduced and pollution prevented. New Employee Orientation A pollution prevention awareness orientation can be incorporated in the general orientation program given to all new employees. The orientation program would include the elements illustrated in Box 19. More detailed pollution prevention training should be provided to new employees after they have been on the job for a few weeks. This training will provide them with the skills they need to participate in pollution prevention. It also emphasizes the company's commitment to prevention. At many plants, employees in certain jobs must be trained and examined on their knowledge of standard operating procedures specific to the site prior to working there. Pollution prevention training can be incorporated into this. It can also be incorporated in the QA procedures qualification process. Make sure new employees are aware of the program. Make pollution prevention part of the QA process. Advanced Training Specialized training sessions on pollution prevention policy, procedures, and techniques should be provided to staff when their job scope is expanded or when they transfer to other areas in the company. These sessions should be considered part of the regular training program, and managers should have funds allocated to cover the costs. If the progress of the pollution prevention program slows, review the amount and type of pollution prevention training pro- vided and consider increasing its frequency and audience. Keep long-term employees' knowledge current. Example Pollution Prevention Employee Orientation Course: "Pollution Prevention Description, Motivation, and Practice" Description: This training course emphasizes your company's commitment to pollution prevention. It gives instruction and practice in techniques for promotion, persuasion, and encouragement of pollution prevention. Goal: The goal of the training program is to explain:  What is pollution prevention?  What leads to successful implementation of pollution prevention?  What role can the individual play in promoting pollution prevention? Lesson Plan for One-Day Orientation Activities Objectives Get acquainted Outline activities Define terms and Begin definition of pollution prevention as a concept and an introduce objectives activity Group discussion Perform and discuss a pollution prevention assessment of a simple process Outline pollution prevention opportunities Analyze implementation, possible barriers, and how to overcome Hands-on exercise (1st half) Perform and discuss pollution prevention assessment of a complex process Form teams Experience pressures of business Individuals assigned roles Experience importance of communication Hands-on exercise (2nd half) Refine application Reassign roles Develop teamwork Repeat hands-on exercise Experience putting opportunities into priority list (1st half) Discuss implementation, possible barriers, and how to overcome Discussion Reinforce need for pollution prevention Explain significance of individual contribution to pollution prevention Box 19 Retraining Periodic retraining of employees may be necessary when your policies and procedures change. Retraining employees also will reiterate your commitment to pollution prevention. MAINTAIN INTERNAL COMMUNICATION Two-Way Communication Your goal is to keep employees motivated (see Box 20). They need to identify with and "buy in" to goals and objectives and continuously have the opportunity to contribute to its success. Employees will take their pollution prevention roles more seriously when their managers keep them informed and encourage them to submit pollution prevention ideas. Make sure employees receive regularly scheduled status reports that are clear and truthful. Objectives that are described in vague terms and have poorly quantified results and reports that are issued at odd intervals may give the impression of a reduced priority for pollution prevention. Explain to the staff any schedule slippage resulting from unexpected challenges and the need for greater staff involvement, if applicable. Employees will work more effectively when they know what management expects of them. Cessation of reports or failure to show ongoing activities gives employees the impression that little progress is being made and/or that the overall program no longer is a priority. Effective communication between managers and employees is a critical requirement for maintaining a successful program. Solicit and Follow up on Employees' Suggestions Employees' ideas for pollution prevention projects should be actively sought. Employees take their pollution prevention role more seriously when management keeps them informed and encourages them to submit pollution prevention ideas. Forums such as break- fasts or informal pollution prevention review meetings promote the exchange of information that will help generate new ideas. You could run a contest to get and reward employee input. For example, you could post a checklist of pollution prevention ideas and offer cash awards for the best way to implement an idea and for the best pollution prevention idea not included on the checklist. Suggestions should be evaluated promptly and put into prac- tice if they are found to be feasible. Similarly, if an employee submits an idea that is not implemented, explain why it was not used and work with the employee to develop a feasible idea. Prompt feedback is necessary to maintain employee interest. Show employees their ideas are welcome. To motivate employees, managers can:  Provide feedback and reinforcement of employees' pollution prevention performance.  Set an example by adhering to the pollution prevention program and actively considering employee ideas.  Convey enthusiasm about meeting pollution prevention objectives.  When new pollution prevention measures are implemented, explain how they fit in with the overall objectives.  Regularly reinforce the importance of each individual's contributions to pollution prevention and their value to the overall objectives.  Demonstrate personal commitment to the objectives and praise the commitment demonstrated by employees.  Announce pollution prevention innovations by calling a meeting for all individuals who will be affected to discuss the change. - Open meeting to questions and comments. - Pay attention to signs of animosity or resistance and address these immediately. - Gain cooperation by showing that you know and care how the employees feel.  Establish a "group identity" and work at building pride in adapting to the pollution prevention innovation.  "Go to bat" for employees who have good pollution prevention ideas that have been rejected or overlooked.  Establish quantifiable annual pollution prevention objectives: - On a monthly basis, have employees chart their personal and the company's progress against these objectives. - Incorporate pollution prevention goals, objectives, and accomplishments into annual job performance evaluations for people with direct process pollution prevention responsibilities. - Readjust objectives if they prove to be unattainable. Box 20 EMPLOYEE REWARD PROGRAM Performance Reviews Progress in pollution prevention can be stated as an objective on which annual job performance evaluations are based, particularly at the management level. This delineates their responsibility for maintaining and enhancing the pollution prevention program. Using the formal mechanism of the written annual report to recognize efforts in this area raises the visibility of pollution prevention as something that is important to the company. Good suggestions should be put into practice and recognized. Recognition Among Peers Employees who suggest pollution prevention measures that prove feasible and are slated for implementation should be publi- cized in the company newsletter or on bulletin boards. The esti- mated cost savings and/or other advantages that the company or unit will derive should be included in this announcement. Periodic group meetings may be a good forum for announcing individuals' efforts to control pollution in the company's daily operations. Material Rewards Cash or merchandise can be awarded to individuals. Establishing the award as a set percentage of the estimated annual savings to be realized by the company or production unit is one way to highlight the concrete value of pollution prevention. PUBLIC OUTREACH AND EDUCATION Employees can speak at meetings of community organizations and at schools to publicize the company's pollution prevention progress. Interviews with local media are another way to enhance corporate image and to further emphasize to employees the impor- tance of the program. Papers given at technical meetings and articles published in trade and professional journals are additional forms of positive publicity. These measures all help to demonstrate that the company's commitment to pollution prevention is real.