Transcript POLLUTION PREVETNION INTRODUCTION

POLLUTION PREVENTION
The EPA 33/50 Program
 1960’S to 1980’s - increasing environmental awareness
Approaches:
 1) Regulations - Command and Control
 2) Control of waste materials through chemical, mechanical,
physical, even electrical treatment and collection (for disposal),
transformation, and/or destruction of pollutants after they
were generated.
 1990’s - Growing awareness of pollution prevention
Approaches
 Prevent the generation of waste itself.
 Reduce the need to control wastes because they are not
produced to begin with.
Source: OPPT - Pollution Prevention Success stories
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POLLUTION PREVENTION: Definition
Prevention takes many forms:
Buying correct amount so no excess materials
need to discarded.
Producing less wastewater by better controlling
the amount of water used in cleaning or
manufacturing.
Substituting non-toxic chemicals for hazardous or
toxic materials currently used in processes.
Re-engineering and redesigning manufacturing
processing lines to take advantage of newer, clear
process equipment.
Source: OPPT - Pollution Prevention Success stories
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Pollution Prevention Act of 1990
National Policy of the US
 Pollution should be prevented or reduced at source
whenever feasible
 Pollution that can not be prevented should be recycled in an
environmentally safe manner where feasible
 If pollution cannot be recycled or prevented it should be
handled in an environmentally friendly way
 Disposal or release to the environment should be employed
as a last resort and should be conducted in an
environmentally friendly manner.
42 USC §§13101-13109
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Voluntary Overcompliance
Voluntary Overcompliance is a recent
phenomenon.
If the law requires toxic emissions
reductions of 50% some firms pledge
to reduce more
A firm overcomplies when they go
beyond a stated law or regulation
voluntarily.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Voluntary Overcompliance
Factors leading to Overcompliance
Dynamic nature of game between firms
and enforcement agency
Violators are threatened with perpetual
surveillance so, even though the penalty
is less than the cost of compliance, firms
comply and often go beyond
compliance.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Voluntary Overcompliance
 Preference for environmental quality by consumers may
combine with competition and induce some firms to
overcomply
 Increased public scrutiny has led some firms to self-impose
stringent emissions standards.
 Information about a firm’s environmental record is now
available as part of Toxic Release Inventory.
 Growth in overcompliance coupled with consumer desire for
environmental quality.
 Evidence is showing that those companies that make the
investment to change early are much better off.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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EPA’s Partners for the Environment
Examples of Voluntary Programs
33/50
Climate Wise
Energy Star
Environmental
Accounting
Stewardship
Program
Project XL
Pesticide
Environmental
Stewardship
Program
WasteWise
Water Alliances
for Voluntary
Efficiency
Source:http://www.epa.gov/ooaujeag/partners/metrics.html
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EPA’s Partners for the Environment
Voluntary Programs
1997 - Partners grew from 6,882 to 8,030
Members from every sector of the economy
Fortune 500 companies as well as small
companies
Collectively these business saved $1.6 billion
Achieved measurable environmental results with
lower costs
Source:http://www.epa.gov/ooaujeag/partners/metrics.html
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EPA’s Partners for the Environment
Voluntary Programs in Action
1997 Success Highlights
Reduced greenhouse gas emissions by preventing
79 million metric tons of CO2 per year (tripled
results from 1996)
Saved 5.8 million gallons of clean water
Prevented 7.6 million tons of solid waste from
entering landfills
Saved 1,020 trillion BTU’s - enough to light 56
million households for a year
Source:http://www.epa.gov/ooaujeag/partners/metrics.html
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Toxic Release Inventory
(TRI)
 TRI data collected focuses on source reduction
activities
 TRI is voluntary based, rather than risked based
measure of pollution (exposure levels are not
considered)
 Facilities which manufacture or process more than
25,000 pounds or use more than 10,000 pounds of
any reportable chemical must submit a TRI report for
each chemical
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Toxic Release Inventory
(TRI)
 Data collected includes information on release into all
media: air, land, (on-site land, underground injection
wells and off-site transfers) and water.
 Due to the public nature of the data collected and
reported, the TRI may be the most significant
measure of industry’s overall progress in reducing
wastes and releases.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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TRI Data
TRI data show aggregate year to year
decreases in releases and transfers of more
than 320 chemicals
Decreases in Releases/Transfers
1988 - 1991
-31% / -34%
1990 - 1991
-9% / -19%
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Toxic Release Inventory
(TRI)
Limitations
TRI data set is self-reported, therefore there exists
an incentive to under-report the releases.
May also be an incentive to over-report if firms
expect to be rewarded for improvements to a
baseline emission level.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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TRI
Critics of TRI suggest that changing
database, different reporting requirements,
and production volume decreases, rather
than real pollution prevention, are the
primary reasons that decreases are being
seen in releases.
Source: July 26, 1993 C&EN
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TRI, Pollution Prevention Act and 33/50 Program
Connections:
There was anecdotal evidence that the publication
of the TRI data in 1988 “shamed” several top
polluting firms to voluntarily reduce toxic releases.
The 33/50 program was developed in part to take
advantage of this “voluntary sentiment” and its
design was influenced by the Pollution Prevention
Act 1990.
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Chemical Industry
Leads all the other industries in releases
@1.5 billion pounds in 1991
90% of chemical manufacturing
belongs to Chemical Manufacturers
Association (CMA)
Source: July 26, 1993 C&EN
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CMA
CMA adopted Responsible Care Program
(1988)
 Companies should strive for annual reduction, recognizing
that production rates, new operations, and other factors may
result in increases. Despite these fluctuations, the goal is to
establish a long-term, downward trend in the amounts of
waste generated and contaminants and pollutants released.
 Uses the TRI to measure progress
 Adherence to Responsible Care is a condition of membership
in CMA
Source: July 26, 1993 C&EN
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33/50 and CMA
 EPA’s 33/50 program, which CMA supports as
consistent with Responsible Care, is an example of a
program where the focus has shifted from volume to
environmental impact.
 It may be better in the overall scope of things to
spend $ to reduce smaller volumes of highly toxic
chemicals rather that focusing on those produced
merely by highest volume.

Source July 26, 1993 C&EN
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Overview of the 33/50 Program
EPA initiated 33/50 program in Feb. 1991
Designed to reduce releases and transfers of 17 high
priority chemicals by 33% at end of 1992 and by 50%
at the end of 1995.
It encouraged firms to use less toxic substitutes and
to reformulate products.
Encouraged firms to redesign production processes to
achieve source reduction, rather than resort to endof-pipe clean-up.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Overview of the 33/50 Program
33/50 focused on 17 chemicals because
The Chemicals selected for 33/50 program
accounted for one-quarter of releases produced
by industry
Toxicity
Volume in which they are produced by industry
Pollution prevention mechanisms exist for
these chemicals
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Chemicals Targeted by 33/50 Program
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Cadmium and cadmium
compounds
 Chromium and chromium
compounds
 Cyanide compounds
 Lead and lead compounds
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 Mercury and mercury
compounds
 Nickel and nickel compounds
 Tetrachloroethylene
 Toluene
 1,1,1-Trichloroethane
 Trichloroethylene
 Xylenes
[Source: EPA-745-R-99-004]
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Overview of the 33/50 Program
33/50 was a unique regulatory
experiment which:
Stressed cooperation between regulators and
industry
Was non-adversarial
Provided positive feedback to participants
Awarded participating firms
Participants’ commitments to achieve pollution
prevention goals were not enforceable by law;
thus firms could renege on their commitment.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Overview of the 33/50 Program
Incentives offered by the program
include:
 Public recognition by EPA(newsletters, PSA, trade journal
articles)
 Awards for innovators and firms with outstanding pollution
prevention achievements
 Flexibility to undertake the most cost-effective emission
reductions
 Firms benefit form Pollution Prevention Information
Exchange System (PIES) - technical information is available
to both participating and non-participating firms
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33/50 and EPA’s Enforcement Duty Caveat
The voluntary nature of the program meant
that a company’s decision to participate did
not change its responsibilities for complying
with all other laws and regulations.
Participation in the program was enforcement
neutral
a company would receive no special scrutiny if it
elected not to participate
received no relief from normal enforcement
attention if it did elect to participate.
Source: USEPA Reducing Risks Through Voluntary Action. Aurora and Carson
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Company Participation
EPA Outreach
Focused on facilities reporting to TRI on any of the
17 targeted chemicals from 1988 - 1994. This pool
of Companies numbered almost 20,000.
Initial communications were to CEO or parent
companies.
EPA Invited 5,000 companies to participate in 1991.
Subsequently invited 2,500 more over next three
years.
Targeted outreach to the 600 companies with
greatest amount of releases and transfers to the
environment.
33/50 Program: The Final record [Source: EPA-745-R-99-004]
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Company Participation
 Approximately 1,300 signed agreements to
participate (13% of all those targeted)
 These 1,300 companies were responsible for 60% of
releases and transfers of the 17 TRI chemicals
targeted by 33/50.
 1,066 companies set measurable goals for reducing
their releases and transfers of the 17 targeted
chemicals against the 1988 baselines.
 These pledges totaled 370 million pounds,
representing a little less than 1/2 of their total 1988
release and transfers of 778 million pounds.
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Flexibility in Goal Setting
Other companies developed goals:
 Tied to changes in their production levels
 By choosing alternative baseline years
 By setting reduction goals for all of their TRI reporting
without specific goals for the 33/50 chemicals.
 Choose pollution prevention to reduce their targeted
chemicals.
As a result:
 370 million pounds of pledged reductions represent a lower
bound that companies attempted under 33/50 program.
33/50 Program: The Final record
[Source: EPA-745-R-99-004]
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EPA Program Evaluation33/50 Program
Data is presented for three time periods
1988 - 1990 : Captures information before
program began
1990 - 1995 : Measures progress during
program tenure
1995 -1996 : tracks development in first
year after program ended
Source: http://www.epa.gov/opptintr/3350/33finb1.htm
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33/50 Program Results
General Results:
 Pre-33/50
 1988 - 1990: Releases and transfers of 33/50 program
chemicals decreased by 16% while releases and transfers of
non-33/50 chemicals decreased by 24%.
 During 33/50
 1990 - 1991: Releases and transfers of 33/50 chemicals
decreased by 21%, while the releases and transfers of all
TRI chemicals fell by 8 %.
 One year after 33/50, reduction trend continues
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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33/50 Program Results
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[Source: EPA-745-R-99-004]
33/50 Program Results
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33/50 Program Results
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33/50 Program Results
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33/50 Program: Key Findings
The program achieved its goal in 1994, one year
ahead of schedule
Largest reductions in 33/50 Program chemical
emissions were driven by U.S. action to phase out
ozone-depleting chemicals under the Montreal
Protocol.
Facilities also reduced releases and transfers of
the other 33/50 chemicals (excluding ozone
depleters) by 50% from 1988 to 1995.
There is some indication that there have been
shifts toward on-site treatment and releases to
land and water away from air.
[Source: EPA-745-R-99-004]
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33/50 Program: Key Findings
Facilities reported more source reduction
activity for 33/50 chemicals than for other
TRI chemicals.
Activity covered a greater percentage of
production-related waste for 33/50
chemicals than for other TRI chemicals.
Reductions continued at a higher rate for
33/50 chemicals than for other TRI
chemicals in the year after the 33/50
Program ended
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Methods Used to Meet P2 Goals
Materials substitution is a very common
method to reduce wastes and emissions
Olin has eliminated use of 1,1,1
trichloroethane (TCA) and dichloromethane
used as degreasers by using an alkaline
and hot water rinsing system.
DuPont is now using high pressure water
for cleaning equipment in its fluroelastomer
production facility.
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Methods Used to Meet P2 Goals
Recycling has become a frequently
used means for managing waste
Allied signal installed a sulfuric acid
purification system and reduced waste by
250,000 lb/yr.
American Cyanamid designed a facility to
recover sulfuric acid and other chemicals
that they previously disposed of through
deep-well injection.
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Another Look at Results
 Of total reduction in releases of these 17 chemicals during 1988
- 1993, 40 % took place between 1988 and 1990 - before the
program started.
 Between 1991 and 1993 releases by participants fell by 41%
and non-participants by 18%.
 It is inappropriate to attribute all the reductions that occurred
since 1991 to the 33/50 Program, according to the GAO,
because some was achieved by non-participants.
 Toxic Watch reports that 31 % of participants had achieved
some reduction in release before 33/50 program. Firms that
had already demonstrated reductions relative to 1988 baseline
would be more likely to join.
Source: EPA’s 33/5- Program: Impact on Toxic Releases and Economic Performance of Firms Khanna/Damon
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Overview of the 33/50 Program
Conclusion
Companies emitting largest amounts of toxic
releases are most likely to take part in the
program.
Voluntary programs may work because they target
the companies with the greatest reduction
potential.
Public awareness plays a key role and can
increase participation by encouraging competition
in environmental quality.
EPA should provide substantial public recognition
and awards to firms achieving real reductions.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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