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1 POLLUTION PREVENTION The EPA 33/50 Program z1960’S to 1980’s - increasing environmental awareness zApproaches: z1) Regulations - Command and Control.

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Presentation on theme: "1 POLLUTION PREVENTION The EPA 33/50 Program z1960’S to 1980’s - increasing environmental awareness zApproaches: z1) Regulations - Command and Control."— Presentation transcript:

1 1 POLLUTION PREVENTION The EPA 33/50 Program z1960’S to 1980’s - increasing environmental awareness zApproaches: z1) Regulations - Command and Control z2) 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. z1990’s - Growing awareness of pollution prevention zApproaches zPrevent the generation of waste itself. zReduce the need to control wastes because they are not produced to begin with. Source: OPPT - Pollution Prevention Success stories

2 2 POLLUTION PREVENTION: Definition zPrevention takes many forms: zBuying correct amount so no excess materials need to discarded. zProducing less wastewater by better controlling the amount of water used in cleaning or manufacturing. zSubstituting non-toxic chemicals for hazardous or toxic materials currently used in processes. zRe-engineering and redesigning manufacturing processing lines to take advantage of newer, clear process equipment. Source: OPPT - Pollution Prevention Success stories

3 3 Pollution Prevention Act of 1990 zNational Policy of the US zPollution should be prevented or reduced at source whenever feasible zPollution that can not be prevented should be recycled in an environmentally safe manner where feasible zIf pollution cannot be recycled or prevented it should be handled in an environmentally friendly way zDisposal or release to the environment should be employed as a last resort and should be conducted in an environmentally friendly manner. 42 USC §§

4 4 Voluntary Overcompliance zVoluntary Overcompliance is a recent phenomenon. zIf the law requires toxic emissions reductions of 50% some firms pledge to reduce more zA firm overcomplies when they go beyond a stated law or regulation voluntarily. Source: Journal of Environmental Economics and Management 28, (1995)

5 5 Voluntary Overcompliance zFactors leading to Overcompliance zDynamic nature of game between firms and enforcement agency zViolators 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, (1995)

6 6 Voluntary Overcompliance zPreference for environmental quality by consumers may combine with competition and induce some firms to overcomply zIncreased public scrutiny has led some firms to self-impose stringent emissions standards. zInformation about a firm’s environmental record is now available as part of Toxic Release Inventory. zGrowth in overcompliance coupled with consumer desire for environmental quality. zEvidence is showing that those companies that make the investment to change early are much better off. Source: Journal of Environmental Economics and Management 28, (1995)

7 7 EPA’s Partners for the Environment Examples of Voluntary Programs z33/50 zClimate Wise zEnergy Star zEnvironmental Accounting Stewardship Program zProject XL zPesticide Environmental Stewardship Program zWasteWise zWater Alliances for Voluntary Efficiency Source:http://www.epa.gov/ooaujeag/partners/metrics.html

8 8 EPA’s Partners for the Environment Voluntary Programs z Partners grew from 6,882 to 8,030 zMembers from every sector of the economy zFortune 500 companies as well as small companies zCollectively these business saved $1.6 billion zAchieved measurable environmental results with lower costs Source:http://www.epa.gov/ooaujeag/partners/metrics.html

9 9 EPA’s Partners for the Environment Voluntary Programs in Action z1997 Success Highlights zReduced greenhouse gas emissions by preventing 79 million metric tons of CO 2 per year (tripled results from 1996) zSaved 5.8 million gallons of clean water zPrevented 7.6 million tons of solid waste from entering landfills zSaved 1,020 trillion BTU’s - enough to light 56 million households for a year Source:http://www.epa.gov/ooaujeag/partners/metrics.html

10 10 Toxic Release Inventory (TRI) zTRI data collected focuses on source reduction activities zTRI is voluntary based, rather than risked based measure of pollution (exposure levels are not considered) zFacilities 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, (1995)

11 11 Toxic Release Inventory (TRI) zData collected includes information on release into all media: air, land, (on-site land, underground injection wells and off-site transfers) and water. zDue 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, (1995)

12 12 TRI Data TRI data show aggregate year to year decreases in releases and transfers of more than 320 chemicals Decreases in Releases/Transfers %/ -34% %/ -19%

13 13 Toxic Release Inventory (TRI) Limitations zTRI data set is self-reported, therefore there exists an incentive to under-report the releases. zMay 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, (1995)

14 14 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

15 15 TRI, Pollution Prevention Act and 33/50 Program zConnections: zThere was anecdotal evidence that the publication of the TRI data in 1988 “shamed” several top polluting firms to voluntarily reduce toxic releases. zThe 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.

16 16 Chemical Industry zLeads all the other industries in billion pounds in 1991 z90% of chemical manufacturing belongs to Chemical Manufacturers Association (CMA) Source: July 26, 1993 C&EN

17 17 CMA zCMA adopted Responsible Care Program (1988) zCompanies 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. zUses the TRI to measure progress zAdherence to Responsible Care is a condition of membership in CMA Source: July 26, 1993 C&EN

18 18 33/50 and CMA zEPA’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. zIt 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. zSource July 26, 1993 C&EN

19 19 Overview of the 33/50 Program zEPA initiated 33/50 program in Feb zDesigned to reduce releases and transfers of 17 high priority chemicals by 33% at end of 1992 and by 50% at the end of zIt encouraged firms to use less toxic substitutes and to reformulate products. zEncouraged firms to redesign production processes to achieve source reduction, rather than resort to end- of-pipe clean-up. Source: Journal of Environmental Economics and Management 28, (1995)

20 20 Overview of the 33/50 Program z33/50 focused on 17 chemicals because zThe Chemicals selected for 33/50 program accounted for one-quarter of releases produced by industry zToxicity zVolume in which they are produced by industry zPollution prevention mechanisms exist for these chemicals

21 21 Chemicals Targeted by 33/50 Program zBenzene zCarbon tetrachloride zChloroform zDichloromethane zMethyl ethyl ketone zMethyl isobutyl ketone zCadmium and cadmium compounds zChromium and chromium compounds zCyanide compounds zLead and lead compounds [Source: EPA-745-R ] zMercury and mercury compounds zNickel and nickel compounds zTetrachloroethylene zToluene z1,1,1-Trichloroethane zTrichloroethylene zXylenes

22 22 Overview of the 33/50 Program z33/50 was a unique regulatory experiment which: zStressed cooperation between regulators and industry zWas non-adversarial zProvided positive feedback to participants zAwarded participating firms zParticipants’ 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, (1995)

23 23 Overview of the 33/50 Program zIncentives offered by the program include: zPublic recognition by EPA(newsletters, PSA, trade journal articles) zAwards for innovators and firms with outstanding pollution prevention achievements zFlexibility to undertake the most cost-effective emission reductions zFirms benefit form Pollution Prevention Information Exchange System (PIES) - technical information is available to both participating and non-participating firms

24 24 33/50 and EPA’s Enforcement Duty Caveat zThe 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. zParticipation in the program was enforcement neutral za company would receive no special scrutiny if it elected not to participate zreceived no relief from normal enforcement attention if it did elect to participate. Source: USEPA Reducing Risks Through Voluntary Action. Aurora and Carson

25 25 Company Participation zEPA Outreach zFocused on facilities reporting to TRI on any of the 17 targeted chemicals from This pool of Companies numbered almost 20,000. zInitial communications were to CEO or parent companies. zEPA Invited 5,000 companies to participate in zSubsequently invited 2,500 more over next three years. zTargeted 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 ]

26 26 Company Participation zApproximately 1,300 signed agreements to participate (13% of all those targeted) zThese 1,300 companies were responsible for 60% of releases and transfers of the 17 TRI chemicals targeted by 33/50. z1,066 companies set measurable goals for reducing their releases and transfers of the 17 targeted chemicals against the 1988 baselines. zThese pledges totaled 370 million pounds, representing a little less than 1/2 of their total 1988 release and transfers of 778 million pounds.

27 27 Flexibility in Goal Setting zOther companies developed goals: zTied to changes in their production levels zBy choosing alternative baseline years zBy setting reduction goals for all of their TRI reporting without specific goals for the 33/50 chemicals. zChoose pollution prevention to reduce their targeted chemicals. zAs a result: z370 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 ]

28 28 EPA Program Evaluation33/50 Program zData is presented for three time periods z : Captures information before program began z : Measures progress during program tenure z : tracks development in first year after program ended Source:

29 29 33/50 Program Results General Results: zPre-33/50 z : Releases and transfers of 33/50 program chemicals decreased by 16% while releases and transfers of non-33/50 chemicals decreased by 24%. zDuring 33/50 z : Releases and transfers of 33/50 chemicals decreased by 21%, while the releases and transfers of all TRI chemicals fell by 8 %. zOne year after 33/50, reduction trend continues Source: Journal of Environmental Economics and Management 28, (1995)

30 30 [Source: EPA-745-R ] 33/50 Program Results

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33 33 33/50 Program Results

34 34 33/50 Program Results

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38 38 33/50 Program Results

39 39 33/50 Program: Key Findings zThe program achieved its goal in 1994, one year ahead of schedule zLargest reductions in 33/50 Program chemical emissions were driven by U.S. action to phase out ozone-depleting chemicals under the Montreal Protocol. zFacilities also reduced releases and transfers of the other 33/50 chemicals (excluding ozone depleters) by 50% from 1988 to zThere 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 ]

40 40 33/50 Program: Key Findings zFacilities reported more source reduction activity for 33/50 chemicals than for other TRI chemicals. zActivity covered a greater percentage of production-related waste for 33/50 chemicals than for other TRI chemicals. zReductions continued at a higher rate for 33/50 chemicals than for other TRI chemicals in the year after the 33/50 Program ended

41 41 Methods Used to Meet P2 Goals zMaterials substitution is a very common method to reduce wastes and emissions zOlin has eliminated use of 1,1,1 trichloroethane (TCA) and dichloromethane used as degreasers by using an alkaline and hot water rinsing system. zDuPont is now using high pressure water for cleaning equipment in its fluroelastomer production facility.

42 42 Methods Used to Meet P2 Goals zRecycling has become a frequently used means for managing waste zAllied signal installed a sulfuric acid purification system and reduced waste by 250,000 lb/yr. zAmerican Cyanamid designed a facility to recover sulfuric acid and other chemicals that they previously disposed of through deep-well injection.

43 43 Another Look at Results zOf total reduction in releases of these 17 chemicals during , 40 % took place between 1988 and before the program started. zBetween 1991 and 1993 releases by participants fell by 41% and non-participants by 18%. zIt 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. zToxic 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

44 44 Overview of the 33/50 Program Conclusion zCompanies emitting largest amounts of toxic releases are most likely to take part in the program. zVoluntary programs may work because they target the companies with the greatest reduction potential. zPublic awareness plays a key role and can increase participation by encouraging competition in environmental quality. zEPA should provide substantial public recognition and awards to firms achieving real reductions. Source: Journal of Environmental Economics and Management 28, (1995)


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