Introduction for Users of this Manual

I. Key Issues in Developing Pollution Prevention Training Audience Analysis Agenda Development Resource Manual Development

II. Painting Manual Assumptions and Logic Audience Analysis Agenda Development Resource Manual Development

III. How to Use the Manual

As activity in pollution prevention accelerates, the need for a technically qualified, experienced corps of pollution prevention trainers has outstripped availability. To remedy this problem, the EPA Center for Environmental Research Information sponsored a pilot program to test the efficacy of building training capacity in pollution prevention training -- i.e., training pollution prevention trainers. Two goals were emphasized: 1) develop the necessary portfolio of skills and abilities among public agency personnel enabling them to be proficient pollution prevention trainers; and 2) supplement these skills with the necessary tools and resources to deliver targeted txaining agendas for various industry audiences.

This particular manual and resource guide has been developed to assist present and future trainers in the development and delivery of a training program which targets metal painting and coating operations. The majority of this manual discusses the delivery of an actual training agenda developed in conjunction with this pilot program. However this preface has been included to provide some important background information on training development and delivery and help users understand why the "model" agenda is structured the way it is.

I. KEY ISSUES IN DEVELOPING POLLUTION PREVENTION TRAINING

Much has been written about developing and delivering good training seminars, and a comprehensive review of training issues and literature is beyond the scope of this manual. However, activity in pollution prevention is quite recent which is reflected by the scant body of experience to draw upon. Training has tended to be reactive, opportunistic, and conducted with little needs analysis or evaluation. In addition, there is little organized evidence concerning the needs of training audiences. Therefore, a review of some fundamental concepts is appropriate.

A. Audience Analysis

Whv is audience analvs is needed ?

As in any training or education, knowing the audience is important in the delivery and eventual successof a pollution prevention training effort. Some basic issues to consider about attendees are:

d Function J Position .\I Experience 4 Motivation J Needs

Each has implication for training development and delivery.

An attendee’s function can influence selection of specific agenda items and give clues to the approach needed For example, in the case of a painting facility, an operator by definition will be more familiar with application techniques and less with new painting systems and their performance characteristics. Less time could then be spent becoming familiar with painting system (which they will never work with) and more on examining good operating and maintenance practices.

The position an attendee holds is important for broad agenda decisions. The type of information and style of presentation is Meren t for an audience of managers than that best suited for an audience of staff or operators. At the management level, the concem is that managers understand the commitment required of the organization, and the employees of that organization, in order to participate in pollutior? prevention. For private sector managers, recognition of environmental concerns is a key component of training, along with stressing the need to include all levels of the curporation in change (much along the lines of quality/quality improvement training). A distinction can also be made between senior management and middle management in many organizations, a distinction that especially affects the length of the training and the level of detail.

Experience of the attendees in pollution prevention, or even sometimes in environmental issues or industrial processes, will drive the choice of technical content areas, the amount of time devoted to communications, and perhaps the amount of time required for the training to be effective.

What the attendees bring to the training as motivation affects the delivery of the material, and the amount of time spent developing the course. Agenda time will need to reflect this motivation. For example, a trainer in a state with facility planning requirements may find more interest in a session on conducting a pollution prevention assessment than a miner which doesn’t have this context.

Recently, at a pollution prevention workshop in metal painting operations, a sample of attendees was asked what was their primary reason for coming. Following are some of the reasons given for attending:

-- find an answer to a particular environmental problem at their plant -- clarification of existing state regulations -- information on upcoming regulations and interpretation for their painting operations -- get information on new painting technologiedequipment -- serve as a checkpint or benchmark-- make sure what currently exists in their

operations reflect best thinking and practice -- network -- the boss said to go

This diversity suggests some of the challenges for delivering an all-encompassing agenda. Appealing to a common motivational denominator may be a difficult, if not impossible, challenge

and there is no formula for juggling among competing interests. A point to remember, however, is that attendees who are told to be there, or who feel forced to attend, will not be "good" attendees, in the sense of being willing to engage fully in discussions and entertain creative solutions -- key elements in pollution prevention training.

Finally, all these factors are analyzed to determine the training needs of particular group of attendees. h i m ?

but especially hue for training in pollution prevention. It may be helpful to think of information gathered directly from attendees not as needs but as "wants", subject to revision and expansion.

A particular problem with all kinds of training is that nearly always the attendees will be a mixed audience, containing members with different functions, motivations and needs, and very possibly also some observers who will stop in and out just to "see what's going on." There is no way to serve all members of a mixed audience. All that can be done is to choose a "core" audience and make decisions related to the needs of that group.

pow do vou Analvze Audiences?

Getting information on these audience characteristics is not difficult, but it wil l take some time and effort. The benefit is that the "training" is actually beginning when you conduct an audience analysis -- you are establishing a rapport, sharing information, and demonstrating a willingness io go the extra distance to meet their needs.

There are two basic methods of gathering this information -- conducting an attendees survey or questioning audience members at the training-site.

1 . Pre-training survey

A pre-training survey can be done formally or informally, by telephone or by mail. An informal assessment may simply be three to five phone calls to randomly selected representatives of the group, asking if they know about pollution prevention and what they would like to know, with a total time commitment of less than two hours. Done more formally, the assessment could require professional expertise in survey design and analysis and require several weeks to complete. One shortcut is to locate instances of similar training and "borrow" whatever assessment information seems applicable.

The goal is to get a snapshot of your audience beforehand--their attitudes, experience, needs, and expectations. You may also want to test their awareness of the definition of pollution prevention. Although it may seem tempting not to get bogged down in semantics, if definitions need to be discussed and are not, much of the training could be lost in confusion or disagreement If definitions are clear to the attendees, but too much time is devoted to their discussion, resentment is a likely result.

After completing your survey you should have a working knowledge of the following:

t to remember is that the n e e d s t a muu of This is hue of any training focused mostly on change,

--Special needs --Expectations that require management --Attendee skillsbackground that can be incorporated --"Believers" among audience members who can be called on at opportune moments

Results can be used to tailor the agenda included in this manual. You may find areas needing to be supplemented with specific information.

2.On-site audience survey

Perhaps time and resources prohibit you from conducting a pre-training audience analysis. An altemative approach is to begin the training session by asking a few questions of your audience.

Even though you will have little time to digest the results, the information may be invaluable in fine-tuning the training presentations. Find out how the audience breaks down by industry, operaton vs. managers, etc. Ask who in the audience has established pollution prevention or quality management programs. A particularly powerful strategy is to begin by asking your audience what particularly they would l i e leave with at the end of the day. List everythmg on an easel up front and as the training progresses, cross out the items as they have been addressed. Again, the relationship you are establishing with the audience and the investment you are demonstrating is as important as the information itself.

What are the Results of Audience Analvsis?

The information gained from this analysis can be used to refine an enhance a draft training agenda and gain answers to several critical questions:

Should the mining seek to lay a long-term commitment of working with your audience in pollution prevention or is a targeted "one-shot'' W i g more appropriate?

What is the optimal length for the training program?

What are the primary barriers for the training program?

prevention training?

What should the training goals be?

What are the primary opportunities for selling pollution prevention and pollution

--Build awareness and knowledge? --Build planning competence? --Build assessment skills? --Behavior modification? --Culture change in the company?

In short, any up-front investigation you are able to conduct to get to know your audience characteristics and needs is likely to improve the quality, focus and delivery of your training.

B. Agenda Development

The previous section discussed the value of gathering information on your audience prior to training delivery. The purpose of this section is to discuss how that information can be used to customize your training agenda.

How lone should the agenda be?

While it h a y seem s m g e to consider length before other content matters, the reaIity is that constraints exist on how much time certain groups of attendees will spend in training, and this information will determine other content decisions. This first decision on length while considering the attendees' position can then be adjusted when the content becomes more clear, increasing or decreasing the time allotted within these rough boundaries. Some very rough rules of thumb for pollution prevention training:

Senior management--two hours

Managers without direct supervisory responsibility for "line" staff--two to four hours,

Managers charged with day-today direction of field or production staff--four to eight

Field staff, production staff, managers charged with pollution prcventiori!environmental

depending on motivation

hours, depending on motivation and direction from top management

management--one to two days for any one training; a series of trainings may be necessary

What T-uld be Lhd? . .

There are two general training methodologies: lecture-based and interactive. Lecture-based is the format and approach with which most attendees are familiar, and probably most comfortable. Reliant on highly s t ructud and scripted presentations, lecture based training often incorporates question and answer periods to establish a touchstone with audience needs. Interactive (or c o o p t i v e , or leamer-centered, or hands-on) W i g emphasizes the need to develop a "process" or "tools" that each attendee will later customize to fit their personal situation. In addition, this approach to training involves attendees themselves, and their interactions, as much as possible. Attendees experience the concepts, rather than having them presented. The interactive approach is almost always supplemented with some material delivered by lecture, as well as overheaddslides, hand-outs and resource packets.

A natural tendency is to rely too heavily on presentation and lecture based formats. Although it creates a higher comfort zone and reduces risk, the quality of the training m a y suffer because of two characteristics in adult leaming:

1. Adults want to and should participate in a learning process. Your audience members are givers as well as receivers of infurmation. They each have unique experiences which need to be shared and discussed. This process of participatay learning encourages discussion, and discovery is not "hammered in." Resistance is likely to be lessened if their own experience is tapped and used as part of the training.

2. Adults have opinions and will evaluate statements as part of learning. Your audience members have extensive industry experiences and will question you as part of their leaming process. Trainers who rely too heavily on presenting material as "facts" can expect to be challenged by audience members who have attempted suggestions or have different perspectives. Trainers should acknowledge and work with audience input rather than be threatened by it.

In delivering this training agenda, the most important principle to remember is to act like a peer, not an emperor.

How should the w n d a be we iehted?

Another important consideration is the weighting of agenda components. Some basic agenda components are:

Intmduction . Background/Historical Review/Current Events . Communications

. Technical Content . Applicatiofitegration . ResourcesDText Steps - Again, depending on the objectives of the training and Ce audience analysis, different components will have different amounts of time devoted to their development and delivery. Management might receive mostly background and integration information, but very little technical material; other managers a fairly even mix of all components, with a slight emphasis on communications; Implementation staff may need a heavy emphasis on technical content and application, with only a brief background section. The decisions will be made using the audience analysis completed initially, and by use of a good development team, with both in-house and external members.

This is also a good point at which to discuss other resource needs and the training "load" that they will cany. For example, if technical content is deemed to be a very important training component, one or two case histories can be presented during the training, with the remainder of the content presented in a resource packet for use at the attendees' convenience. Or for another group of attendees, a substantial amount of time devoted to lecture on technical content might be a better choice. Deciding the relative roles of printed and presented materials now rather than later will help clarify the budget (printing can be expensive, and takes time) and direct the search for information and presenters.

What too 1s should be used, 7

The trainer has a portfolio of tools and strategies to use in developing and presenting ideas as illustrated in the accompanying chart

Lecture

Group Interaction

Guest speakers

Problem-Solving Exercises

Site Visits

ToolIStrategy Advantages Disadvantages

Trainer control Can quickly become Concise delivery of monotonous information Lower retention rate

Participative learning Generate discussion and interaction requirements increase

credibility Potential perceived lack of Reinvigorates training delivery objectivity

Can be difficult to manage Planning and time

Potential lack of training and message control

May not seem applicable

Can derail presentation flow bj raising detracting issues

Put theory into practice Test learning Greater risk

Visualize concepts in Time consuming application "Doesn't apply to me" Credible, practical

Videos

Case Histories

Game tools

There are no "right" strategies for delivery; rather, training is more about choosing the right tool for the right occasion. A trainer will probably want to employ most if not all these options at different occasions in the training agenda, Often, a mix of tools for a particular presentation topic may be the best strategy. For example, a lecture-based introduction to a topic, followed by a group problem-solving exercise to test comprehension and learning and concluding with a guest speaker to demonstrate concepts in application may be a powerful combination.

A special comment needs to be made here about guest speakers and industry presenters. In public agency-sponsored uaining, it is likely you will want to tap into the local industry base for case examples and technical content presentations. This is highly recommended since it serves the dual purpose of demonstrating principles and concepts in application as well as improve overall credibility of the training. There is significant risk is attempting to present technical content without having background in its application. Your audience's perception of training quality is likely to be shaped largely by how this portion of the training agenda is managed.

Popular Overreliance can result in Visual understanding Professional delivery

Leaming in application "Doesn't apply to me" Company validates practicality Problems often more valuable

to study than successes

Learning through doing Often inappropriate for Visualize precess relationships industry audiences who Demonstrate abstract concepts understand processes and

process relationships. May seem "below" audience

disjointed and "lazy" training

C. Developing a Resource Manuals

Resource manuals are the "carry-aways" of pollution prevention training -- the materials taken back by the attendees to their facility and (hopefully) used for purposes of pollution prevention planning and implementation.

Neither trainers not their audiences should consider resource manuals as a substitute or surrogate for direct training. In all types of training (and especially in pollution prevention training), the value-added is found in the discussion and analysis rather than the printed word. Resource manuals need to be marketed for what they are: supplemental readings and materials to help attendees recall key ideas and serve as an information resource at the plant. Resource manuals by themselves will not result in the mation of the skill base or leadership needed for implementation within the plant.

As with presentation strategies, there is no formula for a good resource manual structure. However, there are several items which have proven to be helpful.

of key resources in the region or state. These would include any appropriate regulatory agencies, technical assistance programs, manufacturing assistance centers, equipment vendors, funding assistance organizations, trade associations, and professional associations.

Contacts and Resource list -- No manual should be without the telephone numbers and addresses

Registrants list -- It is frequently noted that breaks and lunches prove to be some of the most fruitful time for training participants. A way to reestablish contact with others met at the seminar will be appmiated

Overhead reprints and room for notes -- Reprinting overheads in their entirety mil pmviding room for personal notes with each overhead will save trainees time and effort, allow them to listen more attentively, and provide easy reference.

Detailed agenda with times and brief ovemiew

Supplemental readings and bibliography of appropriate readings preferably cross-referenced with the agenda topic.

Examples of key concepts (model policy statement, pollution prevention plan)

Not everything should be placed in the manual at the outset. Materials needing specific attention should be held aside and distributed as handouts at the appropriate point in the agenda. Sufficient room needs to be saved in the manual for attendees to include these materials.

11. Painting Manual Assumptions and Logic

In order to develop this training resource manual, the project managers needed to make several assumptions about the issues discussed in the previous sections. It is important to understand the role of these assumptions to understand the logic of the resource manual and agenda.

A. Audience Issues

Several critical assumptions were made about the audience receiving this "prepackaged" training:

1) industry attendees would be from small businesses, or representatives from larger companies

2) industry attendees would have painting experience and understand painting as a process very

3) capital available for process modifications would be limited 4) the audience would be comprised of a mix of production managers, environmental managers,

The agenda contained in this manual reflects these three critical assumptions in the foIlowing ways:

1. The agenda addresses low-cost, operator oriented pollutwn prevention opportunities in more detail than hrger system-oriented changes. This resmctim was neither unnatural nor difticult, since there is a large gap between low-cost and high-cost pollution prevention opportunities in metal parts painting and small painting operations arc ovenvhelmingly likely to be interested in low-cost options.

2. The agenda emphasizes the costs and regulationr associated with metal pans painting. These were considered to be the prime motivators for small business audience attendance.

3. The agenda emphasizes a process of investigation &u&gpollution prevention oppomuaities) as well as answers (solving pollution problems). Building skills as well as knowledge among audience members was considered to be critical if an ethic of continuous environmental improvement was to be instilled.

with small painting operations.

well.

and operators

Upon review, users of this manual may feel that portions of the modules or perhaps entire modules themselves are not suited for their particular audience. This should not be surprising given the diversity of industries, needs, motivations, and regulatory frameworks which comprise the context of delivering this material. In the manual, the need to "tailor" presentation methods is frequently mentioned. As discussed previously, users are encouraged to use their professional judgement and their own information resources to accomplish this.

B. Agenda Issues

The agenda is comprised of five sections or "modules." They are organized in this manual as they would appear in a training agenda

Module I : Introduction to Pollution Prevention -- an overview of the definitions and regulatory background of pollution prevention and a discussion of the motivations for employing this strategy.

Module 2: Environmental Issues in Painting Processes -- an introduction to environmental management concerns typically arising in painting operations and their sources.

Module 3: Finding Pollution Prevention Opportunities in Painting Operations -- an introduction to conducting pollution prevention assessments.

Module 4: Waste Reduction Techniques and Technologies -- an overview of altemative painting systems, methods, and good operating and housekeeping practices which prevent pollution.

Module 5: Evaluating and Implementing Waste Reduction Opportunities -- an introduction to economic considerations and other site factors in implementing changes.

The agenda purposely has been designed to serve broad training goals. Each of the modules provides a thorough overview of the relevant issues, but any of the modules could be explored in mOre depth if desired Users of this manual are again encouraged to use the modules as templates --adding or subtracting time given the willingness of your audience to invest in training and the information gained in audience analysis.

The agenda contained in this manual lasts from approximately 6 hours. It is a short period of time from the standpoint of potential issues to discuss, but may be an uncomfortably long period of time for people with parts to produce and businesses to run. Developers determined that a three-quarter day agenda was the best compromise.

The manual recommends the use of a variety of presentation approaches and strategies. Users are encouraged to generate ways to turn lecture sessions into more interactive formats. In several places, sample discussion questions have been included to assist in this effort.

In. How to Use This Manual

This manual is designed to be used in conjunction with an accompanying "train the trainer" seminar. Program developers f d y believe that although information in this manual can help individuals deliver training, additional training skill development and delivery practice is essential for new trainers. The scope of issues involved in k i n g development and

delivery can only be touched upon in this manual. In no wav does t his preface serve as- fpr "train the trainer" proerams.

Each presentation module is divided into two color coded sections -- yellow pages and white pages.

The yellow pages are materials and readings meant fpr trainers use Q& in developing and planning presentations These should be handed out to training attendees. Materials you will find in the yellow pages are :

*A description of the goals and objectives of the module -A description of each module topic and a time estimate for completion *A background note for the trainer describing key concepts and ideas to be conveyed in the

-

d u l e

questions to stimulate discussion *Presentation notes for all accompanying support materials such as overheads, exercises, etc. and

Flexibility is important in training, and the estimated times for each agenda topic are meant to be used as general guidelines. The background note is designed to provide an overview of the module, additional information on primary concepts, and suggestions and recommendations for delivering the material to an industry audience. In the presentation notes, space has been provided to let the trainer make personal presentation notes to supplement those provided for a particular overhead. Trainers are strongly encouraged to read through the yellow pages to gain a better understanding of the logic and flow of the module.

Materials you will find in the white pages are

Summary overheads and overhead masters for reproduction Exercises Handouts Supplementary readings.

These materials can be reproduced and handed out to audience members. These materials are not meant to exhaustive; trainers are encouraged to add to or replace with other handouts which they believe wiIl better meet their training needs.

..

Module 1:

Introduction to Pollution Prevention

Module Goals

1. Generate an understanding among attendees of the principles of pollution prevention

2. h v i d e an understanding of the difference between source reduction, waste reduction, pollution prevention, and waste “ i z a t i o n .

3. Provide an overview of pemnent federal, state, and local pollution prevention initiatives and their likely influence on painting operations.

Agenda Summary and Time

Lectlmx What is Pollution Prevention Lectlmx Lectlmx Benefits of Pollution Prevention

Total Module Time

Federal, State and Local Requirements 10 minutes 25 minutes 5 minutes

40 minutes

Background Note for Trainer

In this brief module, your attendees will be introduced to the concepts of pollution prevention,the regulatory history and requirements shaping this movement, and the business rationale for embarking on this strategy.

The module begins with a series of overheads on defintions which smves to distinguish pollution prevention from other terminology which the audience is likely to be familiar with. Trainers define the relevant terms that are used in discussing pollution prevention-- how they are used, why they are different, and the significance of these differences. Additional information to introduce the concept of pollution prevention in an historical context can be found in the supplementq reading section.

Definitional issues may seem cumbersome (and they often are) however this foundation is important so the training can proceed with everyone working under the same context.

The lecture then proceeds to an overview of federal, state, and local pollution prevention legislation addressing pollution prevention. The accompanying overheads look specifically at the U.S. Pollution Prevention Act of 1990. It is anticipated that trainers will be intimately familar with the issues and implications of the act, so a further discussion in this background note is not warranted.

Instead of discussing the f e d d context and history, it may be much preferrable to spend this limited time speaking directly to state and regional requirements affecting your uainiing audience. Trainers should develop accompanying materials, overheads, and handouts for state and local intiatives pertaining to the state or locality. In this supplementary readings and handouts section of this module, materials are provided which provide a summary of state and regional initiatives f“ around the country. While these may be of interest to the miner

PRESENTATION NOTES

Overhead 1: Defintions

The accom~anvin~ visuals demonstrate how the same overhead is used five b e s to convey the differencesin ie&tions.

WASTE REDUCTION

'WDsIe Reducllon~nlon lo all sclfvllin In Iho shaded h X .

WAST

WASTE REDUCllON

- Reclamallon

WASTE REDUCTION i

I

!DUCTION

Trainers notes:

WASTE REDUCTION

I W

Overhead #2: U.S. Pollution Prevention Act

Passed October 27,1990, this act formalizes the prevention approach to environmental issues and makes prevention the federally preferred means of dealing with waste generation and disposal. The Act established a waste management hierarchy comprised of the following:

attempts should first be made to prevent pollution at the source pollution that cannot be prevented should be recycled in an environmentally safe

pollution that cannot be prevented or recycled should be mated in an environmentally safe manner

disposal or release to the environment should be used only as a last resort

manner

Trainers notes:

Overhead #3: U.S. Pollution Prevention Act (cont.)

The Act directed the USEPA to set up an office independent of the single media program to implement the Act Among its activities, this office

reviews regulations before and after proposal to determine their effect on s o m e reduction,

coordinates source reduction activities in each USEPA office and promote the practice of source reduction in other Federal agencies,

facilitates the adoption of source reduction techniques by business, identify measurable goals that reflect the policy of the Act, tasks to meet these goals,

dates, required resources, organizational responsibilities, and means for measuring progress

establishes training programs on waste reduction opportunities, make " m e n d a t i o n s to Congress to eliminate barriers to source reduction, - develops, tests and disseminates model source reduction auditing procedures, established an annual awards program.

The grant program is designed to assist state programs to promote source reduction by businesses

The Pollution Prevention Information Clearinghouse collects and maintains information on management, technical, and operational approaches to source reduction. It is accessible in hardcopy or by modem. PPIC also provides access to an electronic bulletin board

The Act also adds a pollution prevention and recycling component to the TRI reporting requirements (the new Form R). TRI reprten are required to report the following on a facility wide basis for each chemical on the TRI list:

'percentage change in the amount of chemical entering their waste streams, -the quanities of chemical recycled, percentage change f" the previous year, and

*source reduction practices used with respect to the chemical, -e.xpected percentage change in the amount of chemical used or recycled for the

*a ratio of production in the reporting year to production in the previous year, -the techniques used to identify some reduction oppntmities, *the amount of any toxic chemical released as a result of a catastrophic event,

*the amount of chemical from the facility that is mated.

the process of recycling used,

subsequent two years,

remedial action, or other one-time event and is not associated with production processes,

Trainers notes

Overhead #4

Although there are many tangible and intangible benefits to pollution prevention, this list is probably the most common.

Benefits of Pollution Prevention

Trainers should point out the hidden but substantial administrative costs to the company assoictaed with regulatory compliance. The audience should be encouraged to think beyond fees and fmes and consider the amount of time (and money) assoicated with Nling out paperwork, monitoring, etc.

Trainers notes:

c

, WRITAR

Solid Waste - Source Reduction

Techniques al

in-Process Recycling

WASTE REDUCTION

- Recycling

Reclamation Reuse

Recovery

WRlTA R

The U.S. Pollution Prevention Act of 1990

Establishes a waste management hierarchy

1. Prevention at the source

2. Recycling in an environmentally safe manner

3. Treatment in an environmentally safe manner

4. Disposal or Release to the environment

WRlTA R

The US. Pollution Prevention Act of 1990

Oset up an independent office for pollution prevention

*establish a grant program for state efforts in po I I u t ion prevent ion

*establish a pollution prevention clearinghouse

-adds a pollution prevention and recycling component to TRI reporting

BENEFITS OF POLLUTION PREVENTION

AVOIDED COSTS OF TRANSPORTAION, TREATMENT, AND DISPOSAL

REDUCED OR AVOIDED COSTS OF COMPLIANCE

MATERIALS SAVINGS

AVOIDED LITIGATION AND INSURANCE COSTS

AVOIDED ADMINISTRATIVE AND MANAGEMENT COSTS

IMPROVED WORKER HEALTH AND SAFETY

Module 3:

Painting Operations Finding - Pollution Prevention Applications for your

Module Goals:

1. Introduce process flow analysis as a p r e f d strategy for conducting a pollution prevention assessment

2. Familiarize attendees with how existing facility information and quality tools can be used to identify and priorhe pollution prevention opportunities

Agenda Summary and Times:

Lecm and Group Discussion: Process Flow Analysis Review Lecture and Group Discussion: Gathering Information Lecm: Targeting Oppomnities Exercise: Identifying Pollution Prevention Options

Total Module Time

Background Note on Training Module

15 minutes 40 minutes 20 minutes 30 minutes

1 hour, 45 minutes

Before exploring specific pollution prevention techniques, a firm needs to investigate its particular process to determine where environmental problems and process inefficiencies arise. and the reason for their existence. Only then can sound, cost-effective decision-making be made on specific pollution prevention options. The purpose. of this module is to provide attendees a methcd of analysis which enables them to answer two important questions: 1) what aspects of my painting operations are especially appropriate for pollution prevention investigation and 2) where to focus resources and attention.

The method of analysis prescribed in this module is designed to help companies pinpoint issues and pollution prevention opportunities pertaining to their particular operations. After completing this module, attendees should have the necessary skills to investigate their own operations, think strategically about their own unique environmental management problems, and make choices about pollution prevention which best satisfy their own production and operations needs.

The module is divided into three sections: introduction to process flow analysis, gathering information, and targeting operations

Process Flow Analysis

Process flow diagrams are extremely useful tools in assisting industry to come to a greater understanding of their waste generating processes. The flow diagram allows the generator to analyze the generating activity by uacking all inputs into the system (including energy) as well as tracking outputs to the final disposition. Undertaking this exercise allows generators to visualize kd

(--

Cause and effect analysis is advocated in this manual as a useful smtegy for uncovering "root causes" of inefficient materials flows and process losses. Commonly used in total quality management programs, it is a simple but effective method for identifying specific opportunities for improvement.

Cause and effect analysis assumes a problem has been identified--either through process flow investigation,or more informally through meetings, or by simply seeing the effects on the production line. A "fishbone diagram" is assembled to provide a visual representation of "why things happen" in the process. The diagram helps pollution prevention assessors to systematically review the sources of the problem and all contributing factors. A complete description and sample of cause and effect analysis is found in the presentation notes.

analvs is is recomme nded for training

Audience members are problem-oriented -- The industry practitioners comprising your audience arc likely to attend because they have specific environmental problem in mind and are seeking a solution. This basis for this analysis is an existing problem, not a procedure. It allows them to focus directly on the topic of concern to their facility.

Audience members have limited it$omation gathering and analysis capacity --Although a preferred strategy for conducting an assessment, full process flow analysis with its associated data gathering and analysis can be quite time-consuming. Many audience members may realize the value of this type of investigation, but may feel they do not have the time or resources.

Cause and effect analysis can also be done independently of process flow investigation. While data gathering and verification will still be required, the overall time and resource investment will be lessened.

e

PRESENTATION NOTES

Part 1: Lecture "Process Flow Analysis 'I

Mini-lecture on the basics ofprocess flow analysis and the reason for using it in pollution prevention assessments

Overhead #1

Trainees can be encouraged to think of pollution prevention as having three parts-making the most of all process inputs, avoiding toxics use, and eliminating process losses. This can only be done by having an in-depth knowledge of the production system. A saategy for acquiring this knowledge makes up the content of this module.

Attendees are likely to be familiar with flow diagrams, however their application in pollution prevention planning may not be as readily understood or appreciated. Attendees may feel is it is a simplistic exercise of little substance when larger technology issues need to be addressed. As a result, there is some risk of losing audience attention if the nainer does not communicate the potential complexity and significance of aprocess flow analysis.

Audience members may asked to brainstom the full range of inputs and outputs associated with each operation within a "typical" painting process.

Trainers notes:

(15 minutes)

Introductory slide-overview of module

Overhead #2

Trainers should emphasize the superiority of beginning an analysis with a flow diagram:

Creating a Process Flow Diagram

-- flow diagrams allows an identification of sources of wastes -- where waste comes from -- provides some insights into the interrelationships among process elements--& waste and

-- provides visual understanding of all opportunities for increasing efficiency and process losses exist.

optimizing resources

Trainers should familiarize the audience with the basic elements of a process flow analysis using the simplified painting line as an example. Output disposition should be discussed as well since information on these flows is derived from information found in manifests, permits, TRI, etc.

The role and usefulness of t eam in pollution prevention planning has been well documented. Some discursion may also be given to who else in a typical facility is likely to be helpful in putting together a process diagram.

Trainers notes:

Overhead 3: Building Your Process Flow Diagram

Several-refinements can be made to improve the quality of the process flow analysis. Attendees should be encouraged to further break down unit operations as necessary to better identify materials uses and outputs. Process support activities such as equipment cleaning, maintenance, and paint mixing also use chemicals and should be accounted for in the analysis. On-site recycling and other resourcs recovery loops should be included with any inputs and outputs from their reprocessing noted. Finally, individuals may want to further refine the measurements of inputs and outputs to reflect materials flows in time as well as volume to get a better understanding of the relationship various product lines/production factors may have on waste and release rates.

Trainers notes:

Audience discussion questions:

What are the audience experiences in putting together a process flow diagram for their own facility? How has it been used? What did it reveal?

Part 2: Lecture and Discussion "Gathering Information" (40 minutes)

Mini-lecture and discussion on finding and using existing sources of information on faciliv operations for pollurion prevention planning

Overhead 4: Gathering Information--Overview

Now that the paths for all materials flows have been identified, the next step is to get quantitative data for materials inputs, uses, and outputs in the painting process. This information allows the pollution prevention investigator to identify trouble operations, sources of manufacturing inefficiencies, and primary areas of process losses and wastes. Some of this information can be found in existing facility records, some will need to be gathered by a process review. The information gathered will be used to conduct a materials accounting and ultimately assign numbers to each of input and output lines identified in the process flow diagram.

Trainers notes:

Overhead 5: Facility Regulatory Records

Existingpaperwork found in the facility can be used to help track materials flows:

TRI reum --important information on volumes of materials released through various media

-Q -- Information about the generation rates, storage times, composition, and volumes of solid waste generated. Since mixed wastes are likely, a TSDF can be asked sample waste to verify assumptions about compositions. As a sidebar, the administrative time and expense associated with this recordkeeping should be recognized as a potentially strong pollution prevention motivator

=-- allows reviewers to investigate product substitution issues and their feasibility in the painting process

Permits -- sampling information can provide insights into process losses and inefficiencies

Regulatory information is only a starting point, it is very unlikely to provide the detail needed for good process flow analysis.

Trainers notes:

Overhead 6: Operations Records

A variety of m o d s found within the facility regrading to production can supplement the regulatory records:

Purchasing and Inventow Records -- materials uses (and their associated costs)

Mmntenance and Ouerato r L ~ g s -- support process materials flows

-s -- materials losses through out-of-spec work

Trainers notes:

Overhead 7: Uses and Limitations of Facility Records

Facility-records can provide a "big picture" look at how environmental performance changes with production peaks, seasonal cycles, etc. Cost figures can be generated to determine what areas nee special priority. Rough materials balances can be may be relatively easily developed. (For instance, to calculate VOC emissions: subtract totals within all hazardous waste shipments from total of VOCs in paint material used.) But perhaps it is most useful in helping to identify what other information needs to be gathered to complete your analysis.

Facility records are only a starting point for pollution prevention investigation. As the limitations list demonsmtes, there are inherent problems in relying on existing paperwork for all your planning. The most significant disadvantage is this, you may discover what is happening but the -for these materials flows may still be largely unknown.

To fill information holes and gain insights in the causes of problems, a process review with direct observation will be needed to get a complete and accurate snapshot of materials flows in the process. Process review have the added value of verifying the accuracy of your existing facility information.

Trainers notes:

Overhead 8: Using Information: Materials Balance

After all the relevant information has been gathered, a materials balance can be very useful in identify quantities of ambient or fugitive process releases.

Trainers notes:

Time pehining, a discussion among attendees on information gathering and use can be initiated. Have any attendees undertaken this analysis? What were their experiences? What information was particularly useful? How do they manage information? Any sofrware packages proven to be particularly usefil? How much time does information gathering and conducting a materials balance take? (Authors' estimate for a full process jlow analysis with verified and quantified materials jlows--100 hours)

Part 3: Lecture "Targeting Opportunities through Cause and Effect Analysis" (20 minutes)

Although pollution prevention opportunities may be identified based on the process jlow analysis, oddirional help in organizing thoughu and generating i&us may be usefir]. This mini-lecture iwoduces ''jishbone diagrams" -- a simple quality management tool-- as an aid in targeting areas of opportunity for pollution prevention

Overhead 9:

Cause and effect analysis is a simple exercise used to help trace problems to their source and target opportunities for change. Commonly used in quality circles to solve process problems, it provides a visual representation "why things happen", helps groups to organize their thoughts, and focuses attention on concrete activities. It also encourages everyone to see and interpret problems in a more consistent manner.

Introduction to Cause and Effect Analysis

Trainers Notes:

Overhead 10 Fishbone Diagram

Beginning with an undesirable "effect", the investigator identifies and backaacks through primary and secondary causes to find the origin of the problem. The problem selected for investigation is placed in a box to the right which constitutes the "head" of the fish. To the left are the "bones" of the fish on which all the causes are organized, displayed, and analyzed.

Trainers notes:

i

Overhead 11

-:-The "problem" will be something which has been identified as an issue of concem based on the process flow analysis (for example "wasted paint in application"). The more specific you are in defining your problem, the better the analysis will be.

m: Best accomplished in a brainstorming session, a team of people intimately familiar with the process should generate a list of all contributing factors to why this problem occurs.

u: The brainstormed list of causes should be grouped by generic categories such as "paint material issues" or "personnel issues."

u: The fishbone diagram can now be constructed. Categories of causes should be drawn as "major bones." Individual causes should be drawn as "minor bones" under the appropriate cause category.

u: For each cause, ask why the condition exists. Continue to ask why until the mot cause is identified.

Steps in Conducting Cause and Effect Analysis

Example: Poor gun performance WHY: Spray pattern is poor WHY Gun clogs frequently WHY: Maintenance done inconsistently WHY. No standard operating procedures for maintenance

w: Identify priority areas and activities for improvement based on this analysis.

The usefulness of this method of analysis is that it ensures thoroughness in examining all possible causes and areas for improvement. It also encourages everyone to see and interpret problems in a more consistent manner.

Trainers notes:

Overhead 12:

This diagram illustrates what a fishbone analysis might look like for wasted paint in application. The categories in this case are materials, people, equipment, and process. Causes have been generated as offshoots and contributing factors to those causes have also been identified. The series of "why" questions can create many layers of "bones on bones":

poor aun oerformance

Sample Fishbone Diagram for Painting Operation

spray pattern problems

maintenance done irregularly

no SOPS for maintenance

After doing a similar analysis for a l l identified causes, the team is poised to take corrective action in any number of areas

Trainers notes:

Part 4: Exercise and Discussion Identifying Opportunities (30 minutes)

The Great Dane Trailer case study (included for reproduction following the module overheads) is designed as an exercise to stimulate discussion on several of the issues presented in this module.

Trainers should draw out audience comments on information gathering and its importance. How important is it to estimate contributions from each source before brainstorming waste reduction options? Is it worth the supervisors time and effort to investigate the reasons for the swings in hazardous waste generation from year to year? Who should be involved on a review team? Audience members are likely to comment that several critical pieces of information were missing. Trainers may want to generate a discussion on what information pieces are missing, why they are important, and how they would go about getting itif they worked for Great Dane. The process of investigation is an important lesson for audience mambers.

Trainers may want to split the training audience such that half of the groups work on information gathering strategies and reduction ideas for VOC emissions and half work on RCRA hazardous

waste reduction. Groups are charged with coming up with with pollution prevention strategies for Great Dane in each of these areas. If information is missing or absent, assumptions can be made by the groups.

Groups may want to hy using fishbone analysis, however this will be challenging since the case study does not provide the detailed information and the perspective of people involved in the process.

After completing their analysis, audience members should be asked to share their recommendations on the assessment process. Keep track of all the ideas on an easel or overhead where everyone can see it. Most groups may miss the use of reformulated paint wastes as an undercoat. What questions need to be asked so that these less-obvious options come to light?

Several other questions can be raised to serve as a segue to the remaining agenda. What barriers are likely to arise for the Great Dane manager reviewing the process and wanting to implement change?

The case study on Great Dane found in Module 4 describes some of the "headline" waste reduction activities implemented at Great Dane. In addition to these activities, Great Dane also moved the paint kitchen closer to the booths to reduce the amount of solvent needed to clean lines. Two activities which were not pursued were gun change and production scheduling. Great Dane did some testing of HVLP guns, but performance in terms of final coat gloss was not up to Great Dane standards. It was the opinion of a consultant that HVLP could achieve the same quality finish, but it would take more disciplined and consistent operator practice, a variable which Great Dane management did not feel they could remedy easily. Production scheduling changes to minimize color changes, while conceptually feasible, was practically not an option because of Great Danes service and delivery commitments.

wrm WRIR W T M

Facilitv Redatore Facilitv ODe rating Records

Step 2: Gathering Information Records

TRI Reports

- Hazardous Waste Mnaifests

Permits and Monitoring Records

Purchasing and Inventory Records

Production Records

- Maintenance and Operator Logs

Uslnp Inf-lbn: CondurUnP 8M.trd.li

Quality Control Records * MSDS Bdmw

. .

Cause and Effec? Analysis

Visual representation of process problems and their causes

Use of "fuhbone" diagram -- common quality management tool

Helps ensures that your "detective work" is complete and thorough

u i n g the Information;

Balana

Cause and Effect or "Fishbone" Diagram Steps for Conducting a Cause and

Effect Analysis:

Finding Pollution Prevention Op-portunities in Your Company

The Goal: Identify all opportunities to optimize resource usage, avoid toxics use, and eliminate process losses

The Steps:

1. Review and understand your process operations

2. Gather and examine facility information

3. Target opportunities -

Step 1: Understanding Your Process Creating a Process Flow Diagram

Process flow diagram -- visual respresentation of how individual operations are related in the production process

Each operation has an individual set of inputs and outputs

INPUTS

P a r t s Cleaning \ Chemical T rea tmen t I

Applicat ion

OUTPUTS -

Curing 1111).

Things to Remember in Building your Process Flow Diagram

Operations may need to be broken down into sub-operations

e.g. Chemical treatment:

Recognize process support such as equipment cleaning, maintenance

Account for recycling and resource recovery flows

Track material flow rates (e.g. air emi s sions/hour)

Step 2: Gathering Information

Goal: Obtain quantitative information on process materials flows and process losses

-- Facility regulatory records

-- Operations records

Filling Information "Holes" Through Direct Observation and Process Review

Using Information: Conducting a Materials Balance

Facilitv Regulatorv Records

TRI Reports

Hazardous Waste Mnaifests

Permits and Monitoring Records

MSDS

Facilitv Operating Records

Purchasing and Inventory Records

Production Records

Maintenance and Operator Logs

Quality Control Records

Uses and Limitations of Facilitv Records

Uses:

Illustrate general trends when compared with production volumes

Generate cost figures

Conduct rough materials balances

Yardstick for measuring progress

Identify information "holes" -

Uses and Limitations of Facilitv Records

Limit ations : Facility aggregate figures provide little insight into waste sources

May not be accurate

Lack of specific information on waste composition

Many process losses not accounted for in records

Tells you "what"; doesn't tell you

Moral: Conduct a process review "why"

Using the Information: Conducting a Materials

Balance

Raw materials and Reuse

MINUS

Products and By-products

MINUS

Documented Release and Wastes

Fugitive Releases

Step 3: Target Opportunities

Cause and Effect Analysis

Visual representation of process problems and their causes

Use of "fishbone" diagram -- common quality management tool

Helps ensures that your "detective work" is complete and thorough

Cause and Effect or "Fishbone" Diagram

b

Acause category \cause category

Description of Effect

Steps for Conducting a Cause and Effect Analysis:

Step 1: State the problem

Step 2: Identify and target problem sources

Step 3: Identify causes and draw diagram

Step 4: Ask series of "why" questions

Step 5: Verify your causes

Step 6: Generate pollution prevention strategies

Sample Diagram for Painting Operation

Personnel factors

Equipment Factors

Application

Process Factors Materials Factors

GREAT DANE TRAILERS

Great Dane Trailers is an original equipment manufacturer of over-the-road platform truck trailers, curtainside trailers and converter dollies. Trailers are assembled from steel parts fabricated in the plant When a trailer reaches the end of the assembly line, it is prepared for painting. Items such as wheels, tires, and air and electrical connectors are covered with plastic or masked off. The trailer is then moved into a large paint booth where it is washed down with 1.1.1 trichloroethane by workers with scrub brushes and buckets prior to painting . The washdown cleans and degreases steel surfaces of the trailer which are to be painted.

A combination of four different coatings may be applied to each trailer:

- A color matching rust preventative coating on visible portions of the structural members

- A thick block undercoat material on the underside of the decking between the beams not visible - A two-part epoxy primer coat on all exposed metal parts on front, rear, sides, and top. A finish coat of either enamel or polyurethane, of whatever color the customer wants, over the

undemeath.

primer coat.

Actual trailer painting may involve all four different types of coatings in various colors for a single trailer. Paints and flush solvents received from supplier are mixed in the paint kitchen located approximately 100 feet from the spray booths. Air assisted airless guns are used for application. All trucks are painted to order of the customer in any color or colors desired. A high gloss finish is determined to be a critical quality factor for the final product. Two custom-built dry filter spray booths serve as the staging area for cleaning and application. Following application, trailers are then moved and allowed to dry in ambient air. Any unused paints from the painting cycle are recycled to the original paint containers in the kitchen. Flush solvents mixed with paint from lines become hazardous waste and is placed in storage until shipment on manifest to a waste recovery facility. Final preparation is completed by attaching serial plates, name plates, mud flaps and lights. The trailer is then moved to a storage yard for pick-up or delivery to customers.

Management has become concemed over the regulatory trends and rising environmental costs. To particular areas of concem are identified.

1. VOC emissions -- An annual average of 224,000 pounds of 1.1.1 trichloroethane vapor was emitted to the atmosphere annual in the period 1987-1990 according to facility TRI reports. These emissions were the result of its use as a thinner in the paints and also as a ckaning/degredsing solvent for the unpainted trailers to promote adhesion. There is no readily available information to determine how the emission volumes are split between these two sources.

2. Hazardous Waste -- The only RCRA hazardous waste stream generated in the entire facility is waste-paint related materials. These materials are generated when a flush solvent is used to flush paint lines when cleaning or changing colors. Additionally, leftover and unusable paint which must be disposed of is combined with the solvent waste. Since wastes contain xylene, toulene, and 1.1.1. they are disposed of through a transportation, storage, and disposal facility holding the necessary permits. Average annual shipments were 135,500 Ibs per year for the period 1987- 1990, ranging from a high of 180,849 Ibs in 1988 to a low of 101,640 lbs in 1987. Again, more specific information on sources of wastes is currently unavailable.

You are the paint line supervisor and have been asked to look into these two problems.

What would you do first? What information would you seek out? How would you go about getting this information? What aspects of the process would you focus on? What oppportunities can you identify?

Module 4:

Waste Reduction Techniques and Technologies

Module Goals: 1. Provide an overview of pollution prevention opportunities and activities pertaining to painting operations

2. Contrast and compare the environmental performance of various paint technologies and equipment

Agenda Summary and Times:

Interactive Discussion w/ Overheads and Demonsmtions: Pollution Prevention Opportunities 45 minutes

45 minutes Guest Speaker: Overview of Paint Technologies and Systems

Total Module Time 1 hour, 30 minutes

Background Note on Training Module

The portfolio of opportunities for pollution prevention in painting operations ranges from simple, no-cost operator practice changes to a full scale implementation of a new painting and coating technology which can run into the hundreds of thousands of dollars. Given this diversity, and the context-specific conditions in which various strategies are applicable, trainers should be respectful of the inherent limitations of attempting a comprehensive overview of technologies and practices-- the content of this module.

Pollution Prevention Opportunities

A series of overheads and accompanying lecture comprises the f i i t half of this session. Pollution prevention opportunities have been grouped into 5 categories: operation and maintenance, inventory management, chemical conservation, process modification, and on-site recovery & reuse. Trainers should immediately realize the categories and subcategories are not independent from each other--an equipment change may very well demand both a change in the coatings used and changes in operator practice as well. This type of systems-thinking was emphasized in Module 3 and should be reemphasized in this module. Evaluating and selecting pollution prevention options should not be done in isolation from other aspects of the manufacturing process.

Some context has been provided for evaluating and selecting activities. Each option also includes the types of environmental issues which may benefit from its implementation. Again, however, these inevitably will be company and process specific.

PRESENTATION NOTES

Overhead #1:

Techniques have not been listed in any particular order or progression. Again, trainees should understand these techniques are not mutually exclusive; in fact many rely on changes in other areas, e.g. a change in coatings may require new equipment and new operator practices.

Overhead #2: Introduction to Operation and Maintenance

The three components comprising the first technique. Pollution prevention experts consider operation and maintenance to be one of the more fertile areas for pollution prevention investigation.

Overhead #3:

The viscosity of the coating material is often lowered to improve paint transfer (create a finer atomization) and reduce potential clogging problems. Commonly, solvents (diluents) are used to thin the paint. Heated paint accomplishes the same task but reduces or eliminates the need for solvent thereby reducing VOC emissions and toxics concerns.

Heated spray requires a lower air pressure the propel the paint . Lower pressures result in less overspray and higher transfer efficiencies and a reduction in paint wastes and VOCs needed for clean up.

Heating is used for high solids coatings. Diluting a high solids coating defeats the purpose of why the coating has been created.

The air and fluid pressure needed to apply a coating depends on the viscosity of the material. Painters should attempt to minimize the system pressures needed to obtain the necessary atomization and thereby minimize overspray and blowback.

The shaoe and size of sprav uattem is related to transfer efficiency and the amount of paint used for a particular workpiece. Operators should smve to obtain oval shaped paint atomization through proper adjustments of air and fluid pressures. Controlling pattern size allows the operator to apply the right coating thickness for the workpiece and avoid using extra paint.

Positioning and racking of work can help improve transfer efficiency and reduce the amount of paint used. Operators should strive to maximize the density of the parts i n front of the gun at all times. Small parts can be racked together to ensure more paint is applied to workpieces during application.

Trainers notes:

Introductory Slide-overview of techniques

Equipment Set-Up and Adjustment

Overhead #4: Operator Training

Operator training has a significant influence on paint consumption rates and paint waste problems. Indirectly, operator raining will then also affect the amount of solvents used for cleaning.

The gun position should be perpendicular to the surface whenever possible to reduce the chance of uneven paint coverage and paint bouncing off the workpiece surface.. Both tilting the gun (up or down) or arcing the gun (holding gun at an angle to the workpiece) is likely to result in these problems. The gun should be kept vertical and be moved parallel to the parts.

As a general rule, the distance betwe en the eun and work should be between 6-12 inches. Too close results in runs and sags and inefficient application. Too great a distance results in overspray problems and uneven coverage.

Timing the trieeering of the gun is a key to reducing overspray, conserving paint, and preventing excess material buildup. The gun movement should be started before triggering, and the trigger should be released before the stroke ends.

If the first stroke is begun on the left side of the workpiece, the gun is moved down at the end of that stroke and the second stroke should begin on the right side. Painters should strive for a 50%

on the retum stroke for optimal efficiency.

Spray techniques should be matched as much as possible to the -e. Banding is the application of a vertical stroke at each end of a flat surface or outside comers so that edges do not have to be covered with horizontal strokes and overspray can be reduced. Vertical applications, especially useful in painting slender workpieces, need faster gun movement to prevent sags and runs.

Trainers notes:

!DC?mnQmStraRiQD IEXeXfSC?.' 7rC?Sting O,j!WbOlQS TrkaiDiDg

Trainers may want t o test operator practice techniques by arranging a mock application line. Materials needed include some sample paint guns a variety of different shaped metal parts to serve as "workpieces." Individual audience members can be asked to come forward to demonstrate how they would cwat the workpieces.

Overhead #5: Equipment Maintenance

Spray g b s are precision finishing tools. Failure to keep equipment properly maintained can lead to a variety of application problems resulting in wasted paint, increased overspray and poor finishes.

Guns should be lubricated daily per manufacturers instructions. Guns should be cleaned before shifts and line color changes as well as before lunches, breaks, and any other times when there is a risk of paint solidification. Guns should not be immersed in solvent since scale deposits and other foreign material can clog passages. Air and fluid filters and air caps should be kept as clean as possible.

Gun should be cleaned frequently to prevent material buildup and clogging. Tips will also erode over time because of the abrasives in the paint leading to changing shapes and difficult atomization. Tips should be replaced when these problems occur. Experts note that tip replacement is frequently neglected among paint operators.

Trainers notes:

Overhead #6: Inventory Management

Waste paint can be significantly reduced through proper inventory management. Shelf life problems can be reduced by employing a "first in, first out" or FIFO inventory strategy. Good procurement policies and production scheduling can help minimize the disposal of expired or unused paints.

Trainers notes:

Overhead #I: Chemical Conservation

Chemical conservation applies to both paint and solvent use. Waste paint can be avoided by computing and preparing onlv the amount needed for the run. Paints can be recycled although the number of times paint runs through a heater should be minimized because of possible degradation.

By using the shortest hoses and smallest DOtS feasible for a given production needs, solvent use can be minimized.

"Pigs" are comprised of absorbent materials with a carbide tip which are used to clean as much excess paint f?om the hose lines prior to washout thus minimizing solvent use. Although a relatively recent cleaning method, it is an excellent way to clean hoses.

Trainers notes:

Overhead #X: Production Process Modification

The two general strategies for modifying a production production process are chemical substitution (changing the type of paints or coatings used) and equipment substitution (changing the application technology). They are not mutually exclusive-changes in paints may require equipment modifications and vice versa.

The product-specific nature of the applicability of different paint systems makes a comprehensive overview of technology application very di'cult. Although a basic review of pollution prevention advantages and disadvantages is possible, trainers should encourage audience participation in reviewing these overheads. Trainers should promote technology transfer among audience members--soliciting their experiences in using the variour systems and gaining their input on pollution prevention advantages and disadvantages.

Trainers notes:

Overhead #9: Chemical Substitution

For discussion7 on chemical substitution and equipment substitution, further information can be gained by reviewing the summary matrices located on page and by reviewing the supplementary readings accompanying this module.

High solids coatings have the advantage of needing to use less paint than conventional coatings for covering a given area. However the use of high solids usually entails some mechanical changes in the painting system including heated lines and curing ovens. The capital investment and equipment changes are disadvantages for employing this system.

Low VOC coatings employ less reactive solvents, such as glycol ethers, than those typically found i n paints, . Although the percentage is the same, the solvent themselves are less volatile. Low VOC coating often have the added advantage of avoiding the need for oven curing.

Water-bome coatings use water as the transfer medium but still employ some VOCs, typically 5% or less. Water-born features less solids per gallon. thereby requiring more gallons to get the same coating power. When used ion conjunction with electrodeposition, transfer efficiencies of 98% are possible.

Powder coatines are actually not paints at all--they are 100% solids. Although completely eliminating VOC problems, they are also the most expensive painting system to install due to equipment needs and curing ovens. They are most frequently employed in conjunction with electrostatic guns.

Trainers notes:

Overhead #lo: Equipment Modification

Many equipment modifications can be done quickly and relatively inexpensively. Hieh Volume Low Pressure (HVLP) guns increase transfer efficiency significantly by reducing the air pressure needed to atomize the paint thus creating less overspray and blowback. A common production concem about HVLP is that you do not get the same quality high gloss as you might with a conventional gun

Airless sprav and Air-assisted airless spray guns use air pressure rather than compressed air to atomize the paint. Airless can require pressures of 2500 psi while air assisted airless (air is used to adjust the spray pattem) typically require 500 psi. Transfer efficiencies are better than conventional spray although there is a significantly higher health and safety risk factor since paint can be injected directly into body parts if not careful.

Surav booths serve to confine overspray, capture slovent-laden air, and eliminate air-bome dirt contamination. Dry booths use disposable filters to capture overspray while wash water booths employ chemically rreated water to accomplish the same task. Paint residues and overspray can, in some applications, be recovered and recycled

Elecuostat ic svste ms apply a charge to the coating material being emitted from the gun which is then attracted to an opposite charge on the workpiece. Transfer efficiencies are. much higher with electrosfatic applications than with conventional guns. The cost of an electrostatic systems may be prohibitive ranging from $75,000 to $250,000. A gun alone can typically cost $2,000 - $3,000. A worker safety risk exists from the possibility of having an electric arc cause the VOCs in the paint to explode. The new Triboelectric system minimizes this risk by blocking the voltage.

solvents. At pressures of 1000 psi and temperatures of 400 - 500 degrees, carbon dioxide becomes a liquid and is a "super solvent". The supercritical C 0 2 is mixed with the paint. A potential problem is that this technology requires changes in the paint chemistry.

Trainers notes:

. . is a new system developed to eliminate the need for VOC containing

Overhead #I1 Equipment Modification (continued)

Kotarv disk and bell armlicarors atomize paint though a combination of electrostatic and centrifugal forces. Major advantages include the ability to atomize paint into fine particles, use for applying high solidshigh viscosity paints and the high gloss results. Parts painted by rotary methods are frequcntly done on a conveyorized system.

Elecuocoating is essentially a dipping methtd providing one of the highest nansfcr coating efficiencies of any method. Pans are given a positive or negative charge and placed in a tank of 5%-20'70 solids dispersed in a water medium having an opposite charge. The major advantage (if this method is excellent uniform coatings. Major disadvantages are equipment and coatings cost and lack of a high gloss finish. It is primarily used to apply primer coats.

Dio coating is a fast and efficient method in which parts are immersed in tanks with coating material. Excess is drained off in a solvent laden atmosphere. Typically this method is used when appearance is not critical.

Flow coating involves the pumping of coating material from a reservoir onto the upper surfaces of the workpiece where it flows down and over the sides finally into a reservoir to be recycled. Although it has the advantage over dip coating in that the amount of material in the system is lower, it also has high solvent demand.

methods create aidpowder slurry in an open top container. The powder is "fluidized"--suspended and surrounded by air --so that the mixture resembles boiling liquids. The workpiece is preheated to a temperature above the melting point of the powder and dipped into the tank where the coating melts and fuses onto the workpiece. Transfer efficiencies are very high and it is safer than electrostatic gun applications.

Autouhoretic coatings is a relatively new system in which a water-born material is deposited in an electrocoating-like system onto a workpiece by chemical reaction. Advantages include: no preuealment required, 30 % less capital investment, and 30% less floor space required than elecuocoating. Disadvantages include limited number of colors in which this patented paint system is available and the need for fairly sophisticated process controls.

Trainers notes:

Overhead #12: Equipment (Related)

Robots are increasingly being employed for their operating consistency and cost savings for high volume facilities. Many find a switch to robot applications cost-prohibitve--robots can cost $100,000 each.

Equipment changes in other operations of the painting process may also be considered. A variety of equipment related options exist in choosing cleaning and degreasing systems, chemical pretreatment, and curing systems. Again some equipment changes (such as infrared or IR curing ovens) require other changes elsewhere in the process (use of IR curable coatings).

Trainers notes:

Overhead #13: Recovery & RecyclelReuse

Recycling and resource recovery opportunities may be found in painting processes. These five are relatively common examples which may be explored. Some capital equipment may need to be purchased for a few of these options, but the payback is often short and many companies feel the added benefit for company environmental management is worth their investment.

Trainers notes:

IMPROVE OPERATION C MAINTENANCE

W INVENTORYMANAGEMEW

W CHEMICAL CONSERVATION

W PRODUCTION PROCPSS MODIFICATION

W RECOVERY C REUSElRECYCLE (ONSITE OR OPPsrrR

... . .... - W Glm POSmON

DISTANCE BETWEEN GUN AND WORK

W WGGERING

W OVERLAP

B MATCHING SPRAY TECHNlQlia TO WORK PIECE CONFIURATION

P

W PROPER SETUP AND ADJUSTMENT

W OPeRATORTE4I”G

W EQUWMENTMNUTENANCE

W MATERuLvlsCOsr rY (HEATING VS DILUTING) ,

W hIWPLUIDPRESSURE

SHAPE c SUE OF SPRAY PAITERN

W POSITIONING AND RACKING OR WORK

P

W USE FIFO FOR PAINT M A T E R I M

w BUY omy AS NEEDED

w SCHEDULE COWRS m MINTMIZE CHANGES

W T M - W MIX AS NEEDED

W MINIMIZE COLOR CHANGEIGUN

W SHORTEST HOSES, SMALLEST POTS

USE "PIGS" TO RECOVER PAINT FROM HOSES PRIOR TO SOLVENT WASHOUT

I IRITM W l T A R

P

HIGH SOLIDS COATINGS

LOW VOC COATINGS CHEMICAL SUBSTITUTION

' EQUIPMENT SUBSTITUTION W WATER-BASED COATINGS

POWDER COATING

HIGH VOLUME LOW PRESSURE SPRAY W L P )

W AIRLESS SPRAY & A I R ASSISTED AIRLESS SPRAY

SPRAY BOOTHS FOR OVER SPRAY CAPTURE

ELECTROSTATIC SYSTEMS (NEW ~

TRIBOELECTRIC)

W SUPERCRITICAL CARBON DIOXIDE (UMCARB)

W POWDER COATING

P fG!x"

W ROTARY. DISK & BELL APPLICATIONS

ELECTROCOATING (ELECTRODEmTIONl

W DIP COAl"4G

8 FLOW COATING

POWDSRSLURRY

AUTOPHORETIC COATING (AUTODEPOSITION COATING)

PRECLEANING

W PRECOATING - IRON PHOSPHATE/ ZINC PHOSPHATE

I CURING - IWUVEB

W ROBOTS

m REUSISG CLEANiNO SOLVENT AS REDUCER FOR XL7T BATCH OF S A M OR DARKER COLOR

SOLVENT DWllLUTlON

MLVM v A m x RECOVERY

m RECYCLING PAINT BOOTH WATER

RECYCLING CLSANEW F'H0SPHAl"GI C H R O h U m G BATHS AND RINSEWATER

POLLUTION PREVENTION TECHNIOUES

IMPROVE OPERATION & MAINTENANCE

INVENTORY MANAGEMENT

CHEMICAL CONSERVATION

PRODUCTION PROCESS MODIFICATION

4 RECOVERY & REUSE/RECYCLE (ONSITE OR OFFSITE)

OPERATION & MAINTENANCE

PROPER SETUP AND ADJUSTMENT

E OPERATOR TRAINING

E EQUIPMENT MAINTENANCE

EOUIPMENT SETUP & ADJUSTMENT

MATERIAL VISCOSITY (HEATING VS DILUTING)

AIR/FLUID PRESSURE

SHAPE & SIZE OF SPRAY PATTERN

POSITIONING AND RACKING OR WORK

OPERATOR TRAINING

GUN POSITION

1 DISTANCE BETWEEN GUN AND WORK

TRIGGERING

OVERLAP

MATCHING SPRAY TECHNIQUE TO WORK PIECE CONFIURATIQN

EOUIPMENT MAINTENANCE

GUN CLEANING & LUBRICATION

TIP CLEANING & REPLACEMENT

INVENTORY MANAGEMENT

USE FIFO FOR PAINT MATERIAL§

w BUY ONLY AS NEEDED

SCHEDULE COLORS TO MINIMIZE CHANGES

CHEMICAL CONVERSION

MIX AS NEEDED

MINIMIZE COLOR CHANGE/GUN

SHORTEST HOSES, SMALLEST POTS

USE "PIGS" TO RECQVER PAINT FROM HOSES PRIOR TO SOLVENT WASHOUT ~

PRODUCTION PROCESS MODIFICATION

CHEMICAL SUBSTITUTION

EQUIPMENT SUBSTITUTION

CHEMICAL ,SUBSTITUTION

HIGH SOLIDS COATINGS

LOW VOC COATINGS

WATER-BASED COATINGS

POWDER COATING

EOUIPMENT MODIFICATION

H

H ,

H

HIGH VOLUME LOW PRESSURE SPRAY (HVLP)

AIRLESS SPRAY & AIR ASSISTED AIRLESS SPRAY

SPRAY BOOTHS FOR OVER SPRAY CAPTURE

ELECTRQSTATIC SYSTEMS (NEW - TRIBOELECTRIC)

SUPERCRITICAL CARBON DIOXIDE (UNICARB)

POWDER COATING -

EOUIPMENT MODIFICATION (CONTINUED)

ROTARY - DISK & BELL APPLICATIONS

ELECTROCOATING (ELECTRODEPOSTION)

DIP COATING

FLOW CQATING

POWDER SLURRY

AUTOPHORETIC COATING (AUTODEPOSITION COATING)

EQUIPMENT (RELATED)

w PRECLEANING

w PRECOATING - IRON PHOSPHATE/ ZINC PHOSPHATE

CURING - IR/UV/EB

ROBOTS

RECOVERY & RECYCLE/REUSE

REUSING CLEANING SOLVENT AS REDUCER FOR NEXT BATCH OF SAME OR DARKER COLOR

SOLVENT DISTILLATION

SOLVENT VAPOR RECOVERY

RECYCLING PAINT BOOTH WATER

RECYCLING CLEANER/ PHOSPHATING/ CHROMATING BATHS AND RINSEWATER -

Module 5: I Evaluating and Implementing Waste Reduction

Opportunities

Module Goals:

1. Leam how to calculate materials savings and emissions reductions for a potential pollution prevention project

2. Develop understanding of the full environmental costs associated with painting operitions and learn how to

3. Demonstrate the real-world applicability of the principles and method of analysis advocated in this seminar through a paint industry case study.

Agenda Summary and Times:

E x e r c ~ m : Calculating Cost Savings/Emissions Reductions Lecture/Discussion: Conducting a Full Economic Evaluation Guest Presentation: Implementing Pollution Prevention

,Total Module Time 1 hour

them into a feasibility evaluation

10 minutes 20 minutes 30 minutes

Background Note on Training Module

Implementation of pollution prevention activities ultimately depends on the value-added to the business as well as the technical feasibility. Waste reduction measures are not likely to be incorporated without a full understanding of the costs and benefits associated with the option. For industry practitioners, the ability to do an accuate and comprehensive costbenefit analysis is the comerstone of sound pollution prevention decision-making.

Most audience members will have had some practical experience in preparing financial summaries and cost/benefit analyses for proposed projects. The training should build on these existing skills. The new learning to be gained by the trainees is likely to center on the identification and computation of the "hidden" costs associated with environmental management and how they can be incorporated into a project evaluation.

Calculating cost savings and emissions reductions is the focus of the fust part of this module. Trainees will be introduced to several basic equations which can be used for comparing and evaluating pollution prevention options, and will test their new skills in a problem solving exercise. The concepts of "full environmental costing" will then be expanded. Training audience members will be introduced to other environmentally related costs with recommendations on how to incorporate them into project analysis -

Training program developers recommend that the seminar conclude with an industry case study demonstrating how all the issues and activities discussed during the fmining program come together to result in effective pollution prevention decision-making. Program developers should identify a local company which has put in practice the steps and methods of analysis recommended during the training workshop, The practical experiences of the guest speaker can energize the training audience and provide proof that the suggested methods really work in industry practice.

Calculating Cost SavingslEmissions Reductions

A primary issue in evaluating the ecopnomic feasibility of an alternative painting method is to calculate the amount and cost of paint which wouId be needed to accomplish the same task under the new system. Three important production factors determine whether paint usage will increase, decrease, or remain the same.

Transfer efficiency is affected by a variety of issues. Although the type of spray equipment is a Primary factor, the efficiency of the equipment will be affected by a number of production related conditions-such as operator practice, spray distance, part geometry and arrangement, and fluid pressure to name some of the more important ones. These production-relafed variables can cause significant ranges in the transfer efficiency of various types of equipment.

,Dried film thickness is a second key variable needeed to compare paint usage under merent application methods. Film thickness must be controlled to a minimum mil level to make sure the coating provides the type of surface finish required Applications methods will vary on the dried film thickness or mil level at which complete coverage can be assured Moreover any exm paint applied beyond what specification require is in effect waste paint--even if it is all applied to the Part.

Finally, the solids content of the coating determines how covering power the paint has. Moving to a higher solids content enables an operator to cover a greater amount of surface area per quantity of paint (assuming the same dried fdm thickness).

When values can be assigned to these three variables, a simple equation can be used to compute the difference in paint volumes used in the different applications method The formula for calculating paint coverage is:.

x %V Dry Film Thickness

Assuming the surface to be covered is the same for both production scenarios, then:

or

where:

G1 = amount of coating currently used for a given application G2 = amount of coating used in new method for the same application %VS 1 = % volume solids of the original coating % VSz = % volume solids of coating used in new applications method

.

% TEl= % transfer efficiency of existing applications method % TE2 = % transfer efficiency of new applications method FT1 = film thickness achieved in existing applications method FT2 = film thickness achieved in new applications method

Knowing the gallons of paint needed for the new applications method, calculating emissions and materials costs are very simple:

E (Ibs) = G2 (gals) x VOC (Ibslgal) *

where VOC = VOC content of altemative coating in lbdgal E = emissions of VOCs

and TMC ($) = Gz (gals) x C ($/gal)

where

Emission reductions and cost savings arising from the new application method are easily computed by subtracting the results from existing production figures.

While the equations are rather simple computations, a greater challenge may lie in obtaining values for the variables. VOC content and percent solids volumes may be gathered from product labels (although thinning a coating may require some additional calculations). Cost of coatings should be easily reaieved f" purchasing records. Transfer efficiency and film thickness, however, are likely to be more problematic. Calculating transfer efficiency can be a more involved process requiring a in-house trial with established production parameters such as flow rates, air pressures, application viscosity as well as a knowledge of the solids content and canful weighing procedures If conducting a transfer efficency test is necessary, it is important to establish as many of these non-equipment parameters as possible prior to the test to identify the m s t accurate transfer efficiency value. Film thickness may also require a similar type of in-depth analysis. However, reasonable estimates might be employed for both factors without jeopardizing the results of the analysis.

A practice problem is included in this module (handouts are found with the overhead masters) and can be used as a trainees exercise. Additional information on delivering this exercise is found in the presentation notes to this module.

C =cost per gallon of altemative coating TMC = total paint materials cost of new application method

Full Economic Analysis

Although materials savings and emissions reductions are important pieces of information in evaluating a pollution prevention activity, many other issues which have tangible cost/benefit implications must be considered before implementing a project. The best analyses fully identify and incorporate all related costs, expenses, and returns associated with project implementation-. both in the present and in the future--to determine economic vialbility.

The EPA Pollution Prevention Benefits Manual breaks down an economic analysis into four cost "tiers." Tier 0 addresses usual capital, operating, and maintenance costs associated implementing and operating a new production method Tier 1 costs include "hidden I' costs associated with pollution practices. Tier 2 considers potential liability costs. Tier 3 includes less tangible benefits a company may achieve as a result of implementing the new technology. Table 1 highlights the

cost components found in each tier. As expected, the higher the tier, the m m subjective the costbenefit figures become.

All relevant Tier 0 factors should be quantified in evaluating a pollution prevention option a s they would be in evaluating any production system change. To the extent feasible, higher tier cost factors should be quantified and included in the assessment Frequently, managers will neither identify nor attempt to quantify many of the "hidden" costs associated with environmental management and will not include their impacts in the evaluation of a pollution prevention project

A full scale discussion of economic evaluation and payback calculation methods is beyond the scope of this introductory overview and the training delivery itself. The point of this short discussion in the seminar agenda is to draw attention to costs and issues which may otherwise not be considered and encourage participants to examine these issues as well when reviewing pollution prevention options. Those desiring additional information on the specifics of economic analysis and review are encourage to obtain the EPA Benefits Manual listed in this module's bibliography section.

A final consideration on pollution prevention implementation is that product performance and quality are prima facie i ssues4 these are substantively and negatively affected, a production change is not justified. Similarly, a number of other site conditions such as corporate priorities and goals, availability of capital, organizational structure and behavior" availability of human resources must also be recognized as legitmate and powerful implementation issues.

Implementing Pollution Prevention

In concluding the seminar, efforts should be given to demonstrating the real-life practicality of the issues and actions discussed to this point in the agenda. The module developers recommend that this message come through the experiences of a credible company in a pollution prevention case study.

Efforts should be made to find a company whose experiences touch on all the key elements discussed in the agenda--the driving force of environmental regulations, the importance of understanding process relationships, the sources and uses and information, and the economic analysis. An indusay case study can visually demonstrate how the theory and activities promoted in this seminar do translate into operations practice and result in cost savings.

I\

I

h

EVALUATING POLLUTION PREVENTION OPPORTUNITIES

CALCULATING MATERIALS SAVINGS AND EMISSIONS REDUCTIONS

CONDUCTING A FULL ECONOMIC ANALYSIS OF POLLUTION PREVENTION OPPORTUNITIES

' .

CONDUCTING A FULL COST ANALYSIS OF POLLUTION PREVENTION OPTIONS

USING THE 4 TIER COST PROTOCOL

W TIER 0 COST FACTORS -- PRODUCTION PROCESS COSTS

W TIER 1 COST FACTORS -- REGULATORY COSTS

TIER 2 COST FACTORS -- LIABILITY COSTS

W TIER 3 COST FACTORS -- INTANGIBLE COSTS

,

TIER 0 COSTS 1. DEPRECIABLE CAPITAL EXPENDITURES

J Equipment J Materials

4 Utility Connections

J Engineering Procurement J Installation

4 Site Preparation

2. EXPENSES

J Start-up J Permitting

J Other Operating Costs

J Other Chemicals J Paints

4 Other Operating Costs

J Maintenance and Support J Disposal Costs Materials -

J Training

J Utilities

TIER 1 COSTS 1. DEPRECIABLE CAPITAL EXPENDITURES

J Monitoring Equipment

J Preparedness/Protective Equipment

Treatment Technology

2. EXPENSES

J Notification Reporting

J Monitoring/Testing 4 Recordkeeping

J Planning 4 Inspections

J Manifesting 4 Labeling

J Medical Surveilance 4 Insurance

TIER 2 COSTS 1. PENALTIES & FINES

J Clean water Act JRCRA

\(Clean Air Act JTRI

J Safe Drinking Water Act

2. FUTURE LIABILITIES

J Soil and Waste Removal JSurface Sealing

J Groundwater Remediation r / Personal Injury

J Property Damage J Economic Loss

J Natural Resource Damage

TIER 3 COSTS

I/ ConsurmerAcceptance

I/ Employee/Union Relations

I/ Corporate Image

The Pollution Prevention Course

ANALYZING THE RESULTS: WHAT ARE THE ECONOMIC CONSIDERATIONS AND -REAL cosr BENEFITS?

James E Clemmer, PhD.. P.E M, Inc

Greenville. South Carolina

1. INTRODUCTION

One measurement of the success of a waste minim'kation project is the economic effect that it has on the faciiity where il is installed. In comparing waste minimization aitematives. the cost of imtalling the project must be compared against several factors Including: ,

0 Improved efficiency and profitabilky 0 Time value of money 0 AVailabilii of disposal faciikies e Unpredictable escalation of d'ispasal casts

The COR of constructing mcdiications to a process can be reasonably estimated. The time value of money is less predictable. However. the least predictable of the costs for hplementing a waste minimization project is the availability and cost of future waste dsposal. Therefore, the ultimate cost or cost savings for a waste minimization project is rarely predictable from historical cost information at the outset of a project A regulatory change such as the RCRA landban can change disposal wsts drastically.

Selecting an acceptable payback period. rate of retum on the investment, or present value is dKwk Setting an economic seledon criterion involves judgement as to the value of other selection criteria. such as community reaction or reduced future liability. what is It worth to reduce the quantity of emissions published in the local newspaper from your SARA repon? In the 60s what was the rate of mum for burying those drums of waste on site rather than doing something else to dispose of them?

Often one assumes an acceptable seleciion criterion and computes the Mure waste disposal costs for several cases The facilii must then decide whether the assumed Mure waste disposal costs are reasonable m companson to historical trends and other, Sometimes intangible, indicators of trends in wane disposal cuss.

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The POllUti0I.I Prevention Course

2

Themajormstsforinstailing a n y p r o c e s s m o d i a r e d ~ h v a r i o u s ~ -. The

COSTS AND BENEFITS FOR I N S T U N G A WASTE HlNlMaATlON PROJECT

- - following summarizes the major dired and hdirect ccsts (1).

Purchased equipment installation - Siiepreparation ' - Insfallation of equipment

- Engineering fees - ConstNction supelvirion - Conaarxoh fees

Indirect costs

- c~nst~ctbn expenses. e.g., c o m d i o n , opeation and maintenance d temporary facilities. offices. mads, W n g lots, electrical service. etc - Storage of purchased equipment

- security

Manufacturing cces - Raw marerials - Operating labor and supelvision

- Maintenance and repain - Operating supplies - Disposal cosr5 - Laboratocy charges

- Interest - Depreciation . TaXeS lmuranoe Rent

- Power and utilities, e.g.. seam, electticity, fuel, water, refrigeration, etc

Fixed coas

Overhead cods - Medical - Health and safely - Training - - Support labor. e.g., accounting, purchasing, payma shipping, receiving, etc Process laboratory

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The Pollution Prevention Course

0 General Expenses - Adminiarative Cosrs Engineering CORS _ . Legal - - - - - Diaributionandmarketingexpenses - Research and Development

F m benefits that one may gah horn &stalling a waste minimtation proied indude the following:

0 Reduced manufachlring costs - Savings on raw materials by recyding of beneficial muse Lower power and utilities

Lower disposal costs due to redudngthevdume ortoxicity ofthe waste

Reduced interest rates may be possible if kndefs c ~ ~ c e m ~ aver

- e.&. steam, electricity. fuel water. refrigeration. ac. due to increased efficiency or geneation of em?fgy from by" -

0 FKed - environmental issues are addressed lnsuiance costs may decrease if waste generation is decreased.

0 Purchased equipment costs - Land requirements may be lowered if oksite disposal is used. Some equipment costs may be reduced if the quantity of waste dassiied as - hazardous in RCRA Is reduced

The dsplacement of purchased raw materials alone is often not a significant economic incentive. There are three potentia benefns that stand out in cettain situations.

1. For industries that generate wastes with fuel value, e.g.. the petroleum industry. the petrochemical industry. etc.. the potential for energy savings from recovering the fuel value of the waste has been recognized since the 19705. Would fewer Superfund sites exist if the relative cost of energy in the 1960s and 1970s had been as high as it is now?

2 For industries, such as paper miils and foundries. which generate large volumes Of solid waste for oksite disposal, avalable land for construction. at an affordable cost. is often a significant concern

Of the potential benefis of waste minimhation. saving disposal costs by reducing the volume or toxicity of a waste has. by far, the most important cost benefh Wth the NIMBY reaction of communities. new waste disposal capacity is more and mocB dficut to constiuct. Some consider the ccst of waste disposal to be high now. However, as siting. permitting. and constructing new waste disposal faciliiies becomes more dficok many industries believe that the disposal costs will continue to rise at a rate higher than the rate of inflation

3.

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The Pollution Prevention Course,. .

We cannot include some economiC bendits of waste minimizawn . h a dassical engineering economic anaJysis.

1. - - One diffiwlt-toqquantify benetit is the image and podwill in the commun& that is built by reducing waste quantrry and toxicity. Many companies are mncemed abcut their image when the kcal newspaper p u M i the waste quantities from SARA 313 reports.

The reduction in long term G a b i l i i is also difficult to quantify, but wwld a Company today send i?=i waste to a ChemDyne? If the manager of 25 years ago knew the potential economic r i i , would he make the dedsion to bury drums of waste on site? Would a manager of today decide to build a landrm that is not fined?

2

3. ECONOMIC COMPARISON OF ALTERNATIVES

Waste minimization decisions almost always invdve choosing between alternatives. e.g.. continuing with the operation as it exists of installing a m o d i A number d methods are available for mmpan'ng altematives (1).

The simplest and most commonly publiihed method is pavwt ~ e n 'od, which is the amount of time theoretically neceSfary to recover the original capital invesrmem

or

(Re depredable fed-capital rirvement Payoutpedcn years - average protit - average operahg and

mahtenance axt per year Per Yew

The time value of money is generally neglected

A simple comparison of alternatives with diierent cosls and Twes is the method Caoitaliued- In this method, the amwnt of capital that must initially be available to purchase

equipment and generate funds to replace the equipment at the end of its lite is compared for various altematives. The following example from Peters and l i m m e m (1) illustrates thii method.

X I V - 4

The Pollution Prevention Course

Example:

Assume:

A sted teaaorcom S5.m and lasts 3 years A stainless steel reactwcmts Si$wO and km 8 yean. N0inflation;moneycosrsl~peryear;no~gevalue.

Which is less expemiw?

- $32600 S15.wO STAINLESS STEEL: $lS.wO + (1 0.08))' - 1

The Discounted Cash Flow method takes into account the time value of money. The procedure allows one to estabIii (or calculate) a m e of retum which can be applied to the annual cash flow of the company so that the original Investment is reduced to zero over the l ie of the project.

The rate of mum Is the maximum interest rate at which "y can be bomMed to pay all principal and Interest accumulated over the Iife of the ptuject. However. the m e of re" used alone does show the magnitude of a project

A similar method is Present Worth or Present Value, which substiiutes an interest rate or cost of capital for the discounted cash flow rate of return. The present worth is the value above the principal and cost of capital This results from this method depend on base year for calculations.

Another discounted cash flow method. the Uniform Annual Equivalent Cost, allows comparison of alternatives with dierent lives. The present worth in base year dollars for each case is converted to a series d equal annual payments over the l ie of the project.

Of course, inflation significantly affects investments and cash flow on environmental projects According to Peters and Timmerhaus (1). the Marshall and Swift All-Industry It~alled- Equipment Cost Indq which is p u b r i in Chemical Enaineerinq, doubled between 1968 and 1978 and increased by another 60 percent W e e n 1978 and 1988. The Chemical Engineering Plant Inds which is also published by Chemical Enaineerinq. is specific to the chemical process Industry. This *ndicator d rising projecI construction costs has increased by almost 350 percent since 1959. but the increase has only been about 8 pemnt since 1983.

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The Pollution Prevention Course

TABLE 1: EXAMPLE OF PRESEKT W O R M AND DISCOUNTED CASH FLOW

Example: lnitii FbtedCapital Investment - $1 w.Oo0 working-capi Investment 51o.ooo Project life - 5 years S&ge Value - S10,WO

Present Worth at 15% D-nted Cash Flow 20.7% Rate of

im - Present worth

$24,900

$21.200

$20.500

$18,800

The effect of inflation on discounted cash flow and present value can be estimated as fOllOwS (3):

(1 + Inflafion Rate) (1 + Cast of C@t@

- 1 (1 + Rare ot Re")

Annual Cash %w Annual Present Value - (1 + Inflagon Rate) (1 + Cos7 of Capital)"

4. CASE STUDY: SIMPLE MODIFICATION WITH SHORT PAYBACK (4)

A common success story is that of the facirty that discovers a very simple modification that can be made to a process, with economic benefts which rapidly offset the cost of installing the modification

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The Pollution Prevention Course

A radiator manufacturer was acrumulzting copper sulfate pentahydrate nynals in a hydrogen peroxide/sulfuric acid bright dip bah due to dissolution of mpper from the tubes in the sulfuric acid. he crystals were removed and sent to a hazardous WaRe landii~~ (reactive Snd OWrmNe).

The mmpany installed ion exchange system and recirculated the hydrogen peroxidehlfuric acid solution to remove the copper. When the ion exchange column K regf"ed, the piant plates the copper from the regenerajon solution and sells it to their copper supplier as high quality copper scrap.

0

0

Installed capital cast of the ion exchange system and plating $2ZooO (1984).

Disposal cost savings and in- from the sale of the remvBcBd copper paid forthe system in 14 months.

Wth increased hndml costs and landban treatment considerations. the retum on investment in 1990 is much greater than when the equipment was originalv installed.

CASE STUDY: IAFIGE PLANT MODIFICATION (5)

0

5.

A manufacturer of uranium hexafluoride and sulfur hexailuoride treats wastewater with Bme to precipitate the soluble fluoride. Wastewater treatment sludge, which was a hazardous waste, had the following composition:

7580% 10-15%

Other 10%

CS, Ca(OH),

The plant had a Stream of dilute hydrofluoric acid available, which was used to neutmliize the residual lime in the sludge. Neutralization of the excess lime with HF raises the percentage of CaF, about 95% and another of the company's facilities was able to use the neutralized sludge as a raw material for manufacluring HF.

0 Capital cost $4.3 Million 0

0

0

Increased operating costs %5OO.ooO per year Value of Raw Material S50,OOO per year Payout period (no inflation or interest)

dapreaiable fied-cap~W Investment average pvrit per year + avarage depredarlon par par

Payout period In years - $" Payour p a d In pars -

$@SO.ooO + $215.000

or

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The Po]lutiOn Prevention Course

p m pew h YlUuJ - 5 yrvvs

R e a l i i i y , inflation and the time value of money affect the payout on a project such as this and should be considered. Wm the following assumptiom Table 2 shows that considering the time value of money and inilatlon adds sut)srantially to the payout period for this project

0

0

0 lnllation me 5% 0

Assume 10 year project Me; SltaigM line depreciatiocr; zero sahrage Assume an annual .merest me of 10% @rime rate on lO/ ls lso)

All imrestment in tim year

The general Inflation rate is expected to be 5% and the cmt of capital is 10%.

TABLE 2 PAYOUT PERIOD FOR MAJOR CAPITAL EBENDFIURE INCLUDING THE TIME VALUE OF MONEY

Hundreds of Thousands of Dollars

- Table 3 illustrates the cost of the projea in constant dollars for the base year with an estimated inflation rate of 5 percent

XIV-8 @ 0 1991 C-t lNtlNtc3. Inc

The Pollution Prevention Course

Capital Annual Year and Environmental Disposal Income Total Discwnt Present

operating savings cost Savings Factor' Value cosr

Total Present Value

1 $1 ,003 $325

$1.003 1 $341'

3 I ($5511 I $1.003 1 s35a

$53 1 sa69 I 0.7496 I $651 I $1,409

$64 $&lo 0.4212 5354 $3.21 6

$67 sa32 0.3647 sa4 $3,519

$70 3824 0.31 58 $260 $3.779

$74 $81 5 0.2734 $223 $4,002

$78 5805 0.2367 $191 $4.193

6. CASE STUDY: EFFECT OF DISPOSAL COST OF PROCESS SELECTION (6)

Often, the escalation of disposal costs is an imponant and diicult-twstimate variable in a decision of whether or not to proceed with a waste minimization project The following hypothetical example was adapted from Higgins (6).

A manufacturer operates a process (Process A) that generates hazardous waste. The maintenance and operating CORS for Process A are expected to be S500,OOO next year and the waste disposal cos& are expeaed to be $1.2w,OOO per year.

An atternate process (Process 8) is available with the following parameters:

e e e

A capital investment of $14.000,000 is required for this pmcess. The maintenance and operating costs are $6.500 in the firs year. The waste disposal costs would be $1.WO.ooO nexI year.

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The Pollution Prevention Course

The Iate of SCZdatiOn of the hazardous m e d i p 0 4 CCU! was varied and the p e n t WOnh estimated for each process. Figures 1 shows the present worth of each process over a 10- ye? project life, and Figure 2 shows the incremental present worth between the two procwes. As the Figures indicate, Process A is more em" ica l if disposal CmtS

than 20 percent per year.

No one can project the rate at which waste disposal cmts will rise: therefore. the decision makers muR deal with regulatory situations !ha are difficult or impassible to predid Among these concerns are the following:

e Will future restrictions and disposal capacity drastically increa.% the ccst of hazardous waste disposal?

less . than 20 percent per year, and process 8 is more economical if the dn- costs rise m e

- The landban with a requirement for incineration as the Best Demonstrated Available Technology (BDAT) has caused a ten-fold hwease In the CMf of disposal of those wastes. The reluctance of states to build hazardous m e facilities suggests that Capacity will not increase rapidly. Some states. such as Alabama and South Carolina. are becoming reluctant to accept hazardous wastes from some other states, and they are increasing the d~pasal taxes.

in municipal landfills.

-

- Subtitle D will have a dramatic effect on the cost of disposing of solid wastes

e Are benefits Of community and employee attitudes toward reduced waste generation sufficient to just.@ installing a waste minimization project that u more wstly than the existing waste disposal practice?

7.

Foundries use 'green' sand to make molds for castings, which historically. has been discarded and sent to a landfill, typically, on site. Reclamation of this molding sand requires a combination thermal and dry scrubbing process. me following is a typical flow chaR for a sand reclamation process:

CASE STUDY: FOUNDRY SAND RECLAMATION SYSTEM (7)

used Sand 1

Conveyor wim M a g n e ~ Separation 1

Screen I

Fumaw I

Fluidized Bed and Mbraling coders 1

Secondaiy Processihg (Two Dp' Suvbbers) 1

Redalmed Sand

XIV-10 0 1991 Gwcrnmcnt Insatulcs. I n r (9

r 0 LD r

FIGURE. I : EFFECT OF DISPOSAL COST ON DISCOUNTED CASH FLOW

(45,000) I

n (50,000) bf) Y

5 0 (55,000) -I LL

5 (60,000) U 0

$ (70,000) 0 u)

(75,000)

.... ............ _” ............. ”.

.......................................................................................................... .. ............. _.. ...........................

..................................... .............. ................................................. _.

..................................................................................................................................................

......................................................................................................................................................................... ~ ....

(80,000) I I I I I I I 0 5 10 15 20 25 30

( RATE OF INCREASE OF DISPOSAL COSTS (77) .

PROCESS A PROCESS B __e_ A

The.Pohtion Prevention Course

Table 4 shows the present worth of the sand redamatlon ' system for this foundry o ~ e r the assumed lo-year life of the projea adjusted to 1982 dollan. mi assumes an M o n rate of 75% and an interest me of 15%.

TABLE 4: PRESENT WORTH FOR SAND RECLAMATlON SYSTEM

Hundreds of Thousands d 1982 Dollan

1 + Inflafh Rate)" (1 + lnterest Rare)"

'DiswunzF8uor - 1

F

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REFERENCES

Peters, M. and K TimemaUS. plant Desiqn and E m i c s fg Chemical Enoineen, Fwrth Ediiion. McGrawHiIL New York 1991.

U.S. €PA The EPA Manual fw Waste Minimization O~WftUrl itv Assessments, EPA 600/2-8en25.

Perry, R. D. Green, and J. Maloney. Penv's Chemical Enaineen' Handbook, Si Ediion. McGawHQ New Yo* 1984.

Huisingh D, L Martin, H Hlger. and N. Seldman Prwen Profits from Pollution

1. -

2

3.

4. Prevention: Case Studies h, Resource Consewation and Waste Reduction institute for ~ocal s e i f - m r i 1986 pp 171-174.

5. Huisingh D.. L Martin, H Hilger. and N. aidman Proven Profits trwn Pollution Prevention: Case Studies in Resource Conservation and Waste Reduction. Institute for ~ocal sefiaermce. 1986. pp 71-n

Higgins, T.E. Hazardous Wane Minimization Handbook, W Pubrshan, 1989, p. 6.

Stephens, W.. and R Zayko. intemal RMF Report. 1982

6.

7.

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,

SUPPLEMENTARY READINGS & HANDOUTS -

Background Information on Pollution Prevention

The following readings provide additional information on the history of pollution prevention and the defintions used.

1. "The Trend Toward Pollution Prevention" 2. "Definitions"

Waste Reduction Institute for Training and Applications Research Minneapolis, MN

Lepislative Info rmation

Two written summaries and a summary table have been included providing an overview of national, state, and local pollution prevention initiatives

3 . 4. 5. "Survey of State Legislation"

Waste Reduction Institute for Training and Applications Research Minneapolis, MN

"U.S. Pollution Prevention Act of 1990" "State and Local Pollution Prevention Initiatives"

Other Resources

Whar is Source Reduction Handout from Cam Metcalf, University of Tennessee Center for Industrial Services

US. Pollution Prevention Act of 1990

Terry Foecke,"Defining Pollution Prevention and Related Terms," Pollution Prevention Review, Winter 1991-92 pp.103-112

The Trend Toward Pollution Prevention

Evdution of the Pollution Control Approach

Awareness of Problems Throughout the 1960s and 70s. public awareness of environmental problems escalated, through milestones such as Rachel Carson's Silenr Spring, the burning Cuyahoga River, Love Canal, and Times Beach. These and many other events served to reveal the error of past actions and our overall ignorance of the effects of those actions on the environment. As awareness grew, Congress enacted legislation to address the pollution apparent in the environmental "media" of air, water, and land, as well as in the workplace.

Congressional Responses creation of U.S.EPA

legislation

Congress also created the U.S. Environmental Protection Agency in 1970, and charged it with regulating and enforcing compliance with emerging environmental protection legislation. As regulations increased in number and complexity, the task of enforcing them also became (and continues to be) increasingly unwieldy and experisive.

The legislative response to pollution had two main traits. The first general charactenstic of the legislation was that i t set out to conrrolpolliirion. The regulated community relied heavily on treatment and disposal to manage wastes, emissions or effluents afrer rhey /mi been generated.

Much of this legislation is mediaspecific in its approach. In other words, regulations governing pollution in water are separate from regulations governing pollution of land, which are separate from those regulating the workplace, and so on.

Milestone events due to past neglect, ignorance or accident, combined with rising public concem have spurred Congress to respond with new and tougher legislation. The Clean Water Act, Clean Air Act, Resource Conservation and Recovery Act (RCRA), which addressed solid and hazardous wastes, all established conaol and management practices to take care of present and future pollution.

Through implementation of environmental laws, great shides have been made in protecting and restoring the environment. However, by promoting reductions in use of toxic chemicals, further progress

can be made to address the problems in the ecosystem and human health.

The Superfund Amendments and Reauthorization Act of 1986 extended the regulatory reach of CERCLA. Included in this omnibus bill was EPCRA, the Emergency Planning and Community Right-to- Know Act, which requires industrial or manufacturing facilities to notify local authorities of the presence of hazardous materials, and to make plans for emergencies due to accidental releases.

EPCRA provides considerable impetus for pollution prevention through its requirement that certain facilities using or manufacturing listed toxic materials in large quantities must report emissions of those materials on an annual basis to state and local authorities.

These annual reports are compiled into the Toxics Release Inventory ('MU), which is widely publicized and readily available for public review. This powerful tool allows the public to examine information regarding these often-substantial legal releases on a facility-by-facility basis. In addition, the U.S. Pollution Prevention Act of 1990 requires that additional data be collected as part of TRI reponing.

The new "Form R", Section 8 of the TRI contains information on source reduction and recycling activities undertaken by reporting facilities, along with reductions achieved as a result of that activity. The form also requires reporting facilities to calculate a production ratio or activity index to normalize the rcponed quantities of chemicals to production rates. This will provide the public with a picture of where source reduction is taking place, and where it needs to be promoted and supported.

Source reduction is defined in the instructions for completing Form R as any practice which:

*Reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste smam or otherwise released into the environment (including fugitive emissions) prior to recycling, ueatment, or disposal; and *Reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants.

The term source reduction is further clarified to define what is and is not included. Source reduction includes equipment or technology modifications,

Communiry Right-to-Know

Toxics Release Inventory

(--

Implications releases continue

process or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control.

Despite the the capture of many contaminants with pollution control technology and procedures, it is evident from TRI figures that large quantities of toxic materials are discharged into air, water and land every year, with untold effect. And these figures do not include emissions from far greater numbers of small businesses who are not required to report their releases.

pollution control shortfall Certainly, the pollution control approach has reduced pollutant releases into the ecosystem. However, in order to achieve national environmental goals, it is necessary to complement the pollution control approach with prevention; reducing the use of toxic chemicals and the generation of hazardous waste at the source.

Drawbacks of the Pollution Control Approach

Examples of "Media Transfers" air to land Several classic examples illustrate how

transfers between environmental media happen with pollution control technologies. At a facility, smokestack scrubbers remove and collect potentially toxic particulates to bring air emissions within regulatory standards. But these collected toxins must then be disposed of as landfilled hazardous wastes. This hazardous waste may leach from the disposal facility into ground or surface water, evaporate into the air, or remain in the ground or surface water.

air ro water

groundwarer to air

Some booths for applying paints are equipped with water curtains, which capture solids and some solvents in overspray from paint guns. The water screen cuts down the number of spent air filters generated as hazardous waste, but it then requires treatment or recovery of metals and solvents from effluent water. A distinct possibility exists that treatment techniques will not be 100% successful, which means that some hazardous wastes will be discharged from the facility.

In remediating groundwater contaminated by volatile solvents, it was (and still is) commonplace to pump contaminated groundwater from barrier wells to a holding vessel, where the volatiles are "stripped" from the water. This is essentially just allowing the

volatile to transfer to the air through evaporation. The volatiles go from drinking water, where they may become oral carcinogens, to the air, where they

depleting substances or smog precursors.

In response to media-specific regulation, pollution control solutions address air pollutants, water discharges and management of hazardous wasres separately. As in the examples above, this results in a shift of pollutants and risks from one environmental medium to another. When pollution is prevented at the source it cannot be transferred to other environmental media

- potentially become inhalation carcinogens, ozone

Problem: Media Transfers

Problem: Control After Generation Another drawback of treating or disposing of pollutants is that it deals with toxics after they have been used or generated.

risks of exposure

potential liabiliry

Addressing toxics after they have been used or generated leaves everyone vulnerable. Workers are susceptible to accidents and often unknown long- term exposure risks. Communities surrounding facilities may incur risks from long-term exposure to uncontrolled releases to air, surface water and ground water. Others in the path of supply routes or waste streams also may suffer if transportation accidents result in spills, or if waste treatment or containment facilities fail.

Control after generation may increase the potential for future liability under any or all of the regulations addressing hazardous wastes, air, water, or workplace pollutants should company activities result in any public or environmental harm.

Problem: Short-term Solution Controlling pollution after it has been generated is a short-term solution to a long-term problem. It may seem easiest to apply a technological control at the end of a process. In fact, some regulations may actually require installation of a specific device to bring the process into compliance.

long-term cosis The long-term costs of control of toxic releases- maintenance of control equipment, down time, insurance to cover worker health, hazardous waste, water effluent and air pollutant fees, potential liability for failures of treatment and disposal - are high and likely to continue to escalate. Toxic raw material inputs are similarly expensive, and indeed, future regulations may phase out their use entirely. From

Pollution Prevention

Going to the Source

The Process of Prevention

an accounting standpoint, applying a control fix after the production process also tends to make costs of environmental protection harder to internalize as a hue cost of production.

These factors make connol more of a short-term approach, since a onetime capital investment does little to control long-term costs, does not address the cause of those long-term costs, and may actually require eventual process modification if the regulatory landscape changes.

None of the pollution control options of treatment, incineration or disposal address long-term environmental problems as well as pollution prevention. Inevitably the environment will be overtaxed as emission and waste generation rates increase with economic activity. For these reasons, environmental agencies and others are attempting to promote the use of pollution prevention through regulatory programs in order to enhance environmental protection.

Pollution prevention can extend environmental protection beyond what is possible with end of the pipe, post-process, pollution control. By going "up the pipe" and reducing the source of pollution- the use of toxic chemicals- the associated toxic or hazardous products, byproducts or wastes may be reduced or avoided. This approach offers greater, long-term protection of all environmental media. Pollution prevention can address the shortcomings of pollution control- shortcomings which include media transfers, increasing costs, and potential liabilities and risks of exposure.

Pollution prevention is a perpetual examination of how toxic chemicals are used or produced. Understanding the reasons why, where and how they are used allows evaluation of opportunities for substitution or reduction of those uses. This represents a change in the approach to use and production and results from increased awareness of their total economic and environmental cost. Pollution prevention has potential for more effective and cost-efficient use of resources in business and industry, consumption of products and energy, ~

agriculture, transportation, educational institutions and all other sectors of our economy.

Pollution hevention Hierarchy Pollution prevention can be thought of as a hierarchy

of use, production or consumption of potentially toxic or hazardous materials. Prevention of wasted energy and water should also be considered in identifying opportunities in pollution prevention. The intent in applying this hierarchy is to always start at the top, looking for opportunities for prevention with the greatest potential impact on pollution.

Pollution prevention is best achieved through source reduction - reducing or eliminating the use of toxic or hazardous materials (including reductions of energy and water use)nt the source of use, by

- of activities which are constantly applied to process

1. changing products; 2. substituting less hazardous materials; 3. using more efficient processes or equipment; 4. preventing inefficiencies due to lack of

maintenance or poor housekeeping; 5. capturing or recovering materials for

immediate reuse.

other oprions Recycling (collection and tmnsportation of materials for reprocessing) is a waste management option second only to pollution prevention. Recycling processes themselves have residual wastes that require disposal, and there are dangers associated with the transport and handling of the materials being recycled. And since recycling requires waste as a raw material, it can sometimes reduce incentives for source reduction of waste.

Recycling is not pollution prevention. A hierarchy of environmental management is described in EPA's Pollution Prevention Strategy of January 1991. At the top of this hierarchy is source reduction. Closed- loop recycling, which returns materials to the process directly without alteration, is preferable to out-of- process or off-site recycling. Closed-loop recycling is often included as part of pollution prevention.

When looking first to pollution prevention options, and implementing them, becomes protocol, pollution control technologies and procedures, incineration, treatment and disposal clearly become less preferable options.

If product and process modifications at the top of the source reduction hierarchy are not feasible, other options may have more immediate potential, primarily because they can more readily be applied

Prevention in Business & Industry implementation

to existing processes. Modification of process and procedures, such as improved scheduling of production, improved housekeeping, attention to maintenance, employee training, on- and off-site recycling, all can take place at relatively low cost as part of a reorientation towards top-to-bottom environmental awareness and stewardship. New products and processes can have this stewardship built in, right from the design stage.

Companies stand to derive both tangible and intangible benefits from implementing pollution prevention. Financial benefits may include:

- avoided costs of transportation, treatment and

- reduced or avoided costs of compliance (an disposal '

industry could remove itself entirely from certain regulatory requirements, and avoid associated fees, fines) - profit from sale of byproducts to others as raw materials - savings on amount and costs of raw materials through closed-loop recycling reduced or avoided costs of litigation - reduced or avoided insurance costs less down time due to occupational health problems avoided costs of addressing problems later, at inflated prices avoided costs of accidents and spills - less down time due to lax maintenance materials costs reduced through thorough

avoided costs of administration and management - reduced cost of rejects

.

maintenance

These are just some of the sav,ings available. It is worth noting that many of these may never show up directly on the books, and could be difficult to track. But they should at least be assigned a value and taken into account when making decisions on implementing pollution prevention options.

Another less direct benefit of pollution prevention is the development of "goodwill" with neighboring communities. Successful prevention efforts will allow industry to tum a traditional public relations liability into an asset. The indusmal generator, usually seen as the "black hat" relative to environmental issues, can through a pollution ' %

prevention approach show that it is not only controlling its negative impact on the environment, but taking positive steps to prevent such impacts

incentives for prevention

public relations benefits

from occurring in the first place. As the public's environmental awareness becomes more and more a pan of the consumer decision making process, an manufacturel's reputation as an environmentally sensitive corporate citizen will have a directly positive impact on market share.

Definitions

The following terms are commonly used in discussions of pollution prevention and related topics. It is important to remember that with few exceptions, there are no standard definitions for these terms. Waste reduction/pollution prevention/ waste minimization initiatives were fmt codified by state and local govemments while the debate over the defmitions of these terms was at its height. As a result, the functional definitions of the terms and the activities associated with them vary from jurisdiction tojurisdiction. For a more complete discussion of this issue, please see Terry Foecke's article "Defining Pollution Prevention and Related Terms" included in part E of this Chapter.

The definitions below are based on our judgement of the most accepted uses of the terms. We have used the accepted USEPA definition in cases where the Agency has established one.

Pollution Prevention: activities defined as "source reduction" under the U.S. Pollution Prevention Act of 1990 and other practices that reduce or eliminate the creation of pollutants through-

i) increased efficiency in the use of raw materials, energy, water or other resources, or ii) protection of natural resources by conservation.

Pollution prevention includes equipment or technology modifications, process or procedure modifications, the reformulation or redesign or products, substitution of raw materials, and improvements in housekeeping, maintenance, mining and inventory control,

Pollution prevenrion does not include recycling, energy recovery, treatment or disposal.

Some processes described as "in-process recycling" may qualify as pollution prevention.

(Taken from a memorandum dated May 28,1992 by F. Henry Habicht II, Deputy Administrator of the USEPA, to all USEPA personnel.)

Source Reduction includes any practice which- i) reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste smam or otherwise released into the

,

environment (including fugitive emissions) prior to recycling, treatment, or disposal; and ii) reduces the hazards t public health and the environment associated with the release of such substances, pollutants, or contaminants.

Source reduction includes equipment or technology modifications, pmess or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control.

Source reduction does not include any practice which alters the physical, chemical, or biological characteristics or the volume of a hazardous substance, pollutant, or contaminant through a process or activity which itself is not integral to and necessary for the production of a product or the providing of a service.

(Taken from the U.S. Pollution Prevention Act of 1990.)

Waste Minimization: activities that result in a reduction in waste volume as well as waste generation. Wmre minimization includes all types of recycling (on- and off-site) and waste concentration as well as source reduction activities. This term usually refers to hazardous and toxic wastes.

Recycling: the collection, separation, recovery and sale or reuse of material that would otherwise be disposed of or processed as waste.

Waste Reduction: any activity which results in a net reduction in the amount of material that must ultimately be mated or disposed of or otherwise handled as waste product. Waste reduction includes all activities considered waste minimization, pollution prevention, or recycling.

U.S. Pollution Prevention Act of 1990

On October 27, 1990, the United States Congress passed the Pollution Prevention Act of 1990.. This Act, signed bythe President, formally recognized the prevention approach to environmental issues as the federally preferred means of dealing with waste generation and disposal. The Act represents a significant policy shift by the federal govemment away from post generation treatment toward viewing waste generation as part of, rather than the result of, a manufacturing process.

Pollution Prevention Hierarchy The Act establishes a Pollution Prevention hierarchy as a national policy. This hierarchy states that it is U.S. policy that:

.pollution should be prevented of reduced at the

*pollution that cannot be prevented should be

*pollution that cannot be prevented or recycled

*disposal or release to the environment should be

source,

recycled in an environmentally safe manner,

should be treated in an environmentally safe manner,

used only as a last resort.

USEPA activities The USEPA is directed through this Act to set up an office, independent of the single medium programs, to implement the Act. Specifically, this new office is mandated to:

.establish standard methods of measurement for source reduction,

ereview regulations before and after proposal to determine their effect on source reduction,

wordinate source reduction activities in each USEPA office and promote sour reduction practice in other Federal agencies,

.develop improved methods for providing public access to data collected under Federal environmental statutes,

.facilitate the adoption of source reduction techniques by businesses,

*identify measurable goals that reflect the policy of the Act, tasks to meet these goals, dates, required resources, organizational responsibilities, and means for measuring progress,

.establish an advisory panel of technical experts to advise the Administrator on ways to improve the collection and dissemination of data,

grants

-establish a mining program on source reduction opportuni ties,

make recommendations to Congress to eliminate barriers to source reduction,

*identify opportunities to use Federal procurement to encourage source reduction,

*develop, test and disseminate model source reduction auditing procedures,

*establish an annual awards program.

The Act establishes a Federal grants program designed to assist state programs promote source reduction by businesses. The Federal share of any project in this grants program is to be no more than 50%. This program is now known as the Pollution Prevention Incentives to the States (PPIs) program.

source reduction clearinghouse The USEPA is directed through the Act to establish a Source Reduction clearinghouse containing information on management, technical and operational approaches to source reduction. This provision resulted in the establishment of the Pollution Prevention Information Clearinghouse (PPIC).

Form R A pollution prevention and recycling activities reporting component is added to the TRI reporting requirements through this Act. On a facility wide basis, TRI reporters are required to report on the percentage change in the amount of chemical entering the waste smams, the quantities of chemical recycled, the change in the amount of chemical recycled, and any predictions regarding the changes in these levels in the future. Included in this reporting requirement is a discussion of the type of pollution prevention efforts made by the facility, the techniques used to identify pollution prevention opportunities, and information regarding changes in production levels.

The new Form R addition to TRI is designed to comply with this requirement.

State and Local Pollution Prevention Initiatives

RCRA and SARA focus

fwo rypes of legislation

Since 1987 twenty seven states have enacted legislation designed to promote pollution prevention as the preferred method of waste management. These pieces of legislation, many of which preceded the U.S. Toxic Pollution Prevention Act into law, are meant to formalize the shift in state environmental priorities from post generation solutions to procedures aimed at reducing the generation of waste at the source. This legislation represents a deepening commitment on the part of the states to foster the adoption of pollution prevention options in their generating communities.

Most of these laws are directed at wastes defined under the U. S . Resource Conservation and Recovery Act (RCRA), or toxics defined in the U. S. Superfund Amendments and Reauthorization Act (SARA) and reported by facilities in accordance with SARA Title III, or both. Of the 27 states with legislation, all of them direct their activities at RCRA wastes while 17 of these acts extent the authority of the legislation to include SARA Title III releases and facilities. One state (Iowa) extends the list of included wastes to those govemed under the Clean Air Act.

Source reduction is mandated as the most favored method of waste management in 25 out of the 27 pieces of legislation. An expressed multi-media focus of activities is called for in 21 of the state acts. Toxic materials use reduction is emphasized in ten states

The action called for through this legislation varies greatly from state to state. Rather than going through all the various permutations, we have chosen two of the most recent bills that have been passed as examples. In many ways these acts represent the two most popular forms of this type of legislation.

Pollution Prevention Policy At it's most basic level, state pollution prevention legislation establishes a new waste management hierarchy with source reduction or pollution prevention at the top, and sets up an office in the state environmental or public health agency which is to direct the state's pollution prevention activities. Often this legislation calls for the establishment of a technical assistance and/or grant program designed to

help generators develop and adopt pollution prevention options appropriate to their process or industry.

The state of Colorado enacted a bill of this in the spring of 1992. The Colorado legislation mandates the establishment of a Pollution Prevention Advisory Board. The Advisory Board, appointed by the Govemor, is responsible for providing general policy guidance, developing reduction goals, and reviewing the regulatory smcture to identify pollution prevention incentives and disincentives. The Advisory Board will also srudy and make determinations regarding the placement and activities of a state pollution prevention technical assistance program. The types of activities undertaken by this technical assistance program are enumerated in the legislative language. The Colorado legislation also establishes a coordinating agency in the Department of Public Health and a Pollution Prevention Fund. The Pollution Prevention Fund is designed to provide funding for the Colorado's pollution prevention activities by imposing a limited fee on facilities required to report under SARA Title III.

Pollution Prevention Planning The other type of state pollution prevention legislation we will look at includes, in addition to mandates similar to those noted above, provisions that require certain generators to produce facility- wide pollution prevention plans. These plans are intended to assist waste generators analyze their waste streams with an eye toward isolating pollution prevention oppommities. Some states require that these plans include some son of facility wide reduction target. A number of states (ME, MA, MS, NJ, NY, TN, VT, WA) actualIy establish a numeric state-wide waste reduction goal. Of the 19 states that mention facility planning in their pollution prevention legislation, 15 require these plans from certain classes of generators while, 4 make the preparation of such plans voluntary.

Pollution prevention facility planning is an important aspect of the recently enacted Amendments to the Arizona Hazardous Waste Management Statutes. Arizona's facility planning requirements are directed at facilities responsible for reporting waste generation to the Toxic Release Inventory The facility-wide pollution prevention plan is to Include:

-identification of the facility (name and address), .the name of the senior official with management

responsibility,

.a certification by upper management as to the

-a statement of management policy, .specific pollution prevention goals for the

*statement of scope and objectives, *pollution prevention opportunity analysis, *statement of pollution prevention activities

*employee awareness and training programs, .provisions to incorporate the plan into

.description of options considered and

accuracy of the plan,

facility,

already in place,

management practices,

explanation for those not implemented.

This legislation also includes provisions that set up a technical assistance program. The provisions of this legislation are to be implemented with funds taken from the Hazardous Waste Management Fund which is also established as part of this act. Facilities that dispose of, store, or ship off site any hazardous wastes will be assessed fees that will conmbute to the fund.

Again, legislatively mandated pollution prevention efforts vary widely from state to state. In order to fully understand the requirements of and the resources available through your state's pollution prevention legislation, it is important to review the appropriate legislation and seek any assistance you may need from the policy branch uf your state's regulatory agency.

The following table will give you an idea of the pollution prevention legislation that has been enacted at the state level.

Municioalities - A significant number of city and county governments are experimenting with the inclusion of pollution prevention or waste reduction principles into local ordinances. Although not nearly as pervasive as pollution prevention efforts at the state level, many of these local efforts leverage the state efforts by bringing the message of pollution prevention to smaller generators and other sectors of the generating community not addressed by the larger state programs.

City and County Programs Locally based pollution prevention efforts began in a handful of localities in the state of Califomia. Communities ranging in size from the City of Los Angeles to the County of Nevada (a small mountain county on the eastem edge of the state) began becoming involved in promoting pollution prevention in the late 1980s. The local pollution prevention movement has now spread to other areas of the country, being most popular in larger states, the west, and Great Lakes States.

program components

material bans

These local pollution prevention efforts, like state efforts, vary greatly from jurisdiction to jurisdiction. The types of services mandated by these local initiatives include:

.the establishment of interagency coordinating teams to reduce barriers to and facilitate the promotion of pollution prevention as the preferred method of waste management,

.providing information and technical assistance through on-site contact with industrial generators,

.waste assessments to be performed on city or county facilities,

.the establishment of a clearinghouse for pollution prevention information,

.the establishment of a newsletter with pollution prevention as its focus, and

.the sponsorship of workshops aimed at helping the generating community identify and implement pollution prevention options.

Some municipalities have taken their pollution prevention a step further by banning or phasing out the use of certain material within their jurisdiction. The major focus of these efforts have been the group of chemicals that contribute to the depletion of the earth’s ozone layer. Some of these efforts will be

further encouraged by certain provisions of the new U.S. Clean Air Act which requires cities and states to maintain their aggregate air quality below a certain level. By banning or resmcting the use of some of these chemicals that substantially conmbute to the level of air pollution present in their jurisdiction, many municipalities hope to comply with these new restrictions.

Ciry of Irvine experience The City of Irvine (CA), for example, passed an ordinance in August of 1989 that prohibits most uses of CFCs in manufacturing and cleaning operations as well as building insulation and foam packaging. The ordinance also requires the recovery and recycling of CFCs during the servicing of air conditioning and refrigeration equipment and halons in the servicing of fire suppression equipment. The use of CFCs in refrigeration equipment is not outlawed by this ordinance but its use is severely conuolled.

The city estimates that there were between 150-200 facilities using CFCs in manufacturing and cleaning at the rime the ordinance was passed. The city made substantial efforts to educate the public regarding the requirements of the ordinance. Much of this effort has revolved around educating concemed manufacturers about possible altematives to the use of such chemicals.

Publicly Owned Treatment Works A primary driving force behind many of these local efforts is the need for Publicly Owned Treatment Works (F'OTWs) to enforce federal and local waste discharge limits. The POTWs are facing mounting pressure that could seriously effect their ability to operate treatment plants efficiently and effectively in the near future, including:

.higher disposal costs necessitated by higher concentrations of toxic compounds in the sludges the P O W generates,

sincreased illegal dumping of hazardous waste into waste smams headed for the POTW driven by the increasing regulation and expense involved in the disposal of such wastes,

hazardous pollutants in POTW pass-through effluent, air emissions, and sludge, and

waste loads.

.additional regulations further limiting the

.future growth which will increase hazardous

POTWs see pollution prevention efforts as a means to proactively address this situation.

For more information

Many efforts on the pan of POTWs involve providing basic pollution prevention information to their client indusnies. F'OTws may also provlde technical assistance to local industry to help them identify and evaluate site-specific pollution prevention opportunities. Some POTWs have even attempted to develop regulatory requirements intended to promote pollution prevention.

Any effort by a POW could have substantial benefit and/or impact hazardous waste generators in its vicinity. Individual interested in suppomng an industrial generator's efforts in pollution prevention, particularly as those efforts relate to water use, should be sure to contact the POTW in their area to take advantage of any efforts they may be making in helping their clients reduce waste.

To find more information on local pollution prevention initiatives, contact the Department of Health in the city or county in which you are interested. It may also be necessary to contact the local Emergency Response Team, inspectors responsible for hazardous waste issues, or Fire D e p m e n t to get a complete picture of the pollution prevention initiatives being taken in a particular municipality.

LEGISLATION SURVEY OF STATE

State/status Definitions

Zlaska

enacted '90

Arizona

enacted '91

California

enatled '89

Colorado

enacted '92

Connect- icut

enacted '91

Delaware

enacted '90

Florida

?nacted '91

Georgia

nacted '90

WRITAR

Management: -solid &

hazardous waste

No statewide numeric goals Pollution

Prevention -toxic use

-source

No

reduction

reduction

numeric goals Reduction: -source -waste '-release

No &Wy& numeric goals Pollution

Prevention -any practice

that reduces use or generation

Pollution Prevention:

generation -hazardous 8

toxic waste -multimedia No statewide numeric goals Minimization: -hazardous & solid waste

mult imedia reduction

No statewide numeric goals Pollution

Prevention: -at the source

No statewide numeric goals Reduction: -haz. waste

No &twt& numeric goals

Materials

Hazardous 8 Toxic Wast

California hazardous 8 extremely hazardous wastes ,

SARA Title 111 8 CERCLA

Hazardous 8 Toxic Waste

(not specified)

Delaware Cod1 -solid/liquid/

haz./refuse .air pollutants sewage

Toxics (not specified

Seorgia hazardous & acute hazardous waste

Priorities Includes -source reducuo -recycling -tieatmen1 -disposal Excludes -incineration -media transfer Includes: -toxic use

-source reduction

-input. process, product change

-'safe' lreatmenl

Includes: -input. process, product change

Excludes: -treatment -media transler -volume change Includes: -input. process, product change

Excludes: -recycling -treatment -disposal

Includes: -input. process, producl change

Excludes: -incineration -media transler -olf-site or out 01 process recycle

Includes: -wasle reduclion -reuse B recycle -sound treatmenl

reduction

a disposal

Includes -input substitutio and reduction (including energ

.product rolorm. -process change -procedure chant -environ. plannin! lor facility expanhsion

.on-site recycltns ncludes: -input. process, product change in-house recycle 5xcIudes. .treatmen! media translet .volume change .incineration

Coverage Not soecified

Includes: -SARA reporter! -large quantity

generators

Includes: -1aroe-auantiN g&erators '

Excludes: -those claiming infeasibility of options

All business anc government. Focuses on small and medium-sized businesses

Businesses wilt gross revenues of less lhan $25 Mor less man 150 employees

Industries B sites targeted a annual intervals Voluntary was% minimization pbnning

LOGS. SQGs and Ioxics users pay annual lee

Includes' -large-quantily generators

-out-of-stale LQ generators using Gwrgia TSOs

1313 5th SI. SE Suite 325 Minneapolis, MN SEPTEMBER 1992

-Technical

-Education -Grants -Inlormalion

referral

assistance

-Facility plans -Annual reports -Technical

Assistance Pqram

-Hazardous WaSk? MaMgernen

Fund -Facilitv Dians -Perfo&nce repons

-Pilot SIC d e s

-technical assistance

-Advisory Board -Pollulion Prevention Fun<

-technical assistance

-Technical assistance

-Grant program

-Technical assistance

-Inlormalion clearinghouse -Public educalio Statewide re- cycling program

-Technical assislance

Conlerences

Technical assislance Facility planning

Plans are confidential or request of owner.

Plans/repons available to public; trade secrets available only to state

Trade secrets are protected

Proprietary information obtained through on- site technical assistance is confidential.

Plans/reports available to public; trade secrets available only to state

Funding

Not based on fees

Based on fees

Based on fees m d penalties

3ased on fees

zeneral Fund

got based m fees

;enera1 Fund

401 based In fees

5541 4-4502 (612) 379-5995

SURVEY OF STATE LEGISLATION

State/status Definitions

-toxic pollution

I - No statewide

reduction of: -toxic material

-waste release use

No Statewide

Prevention: toxics pollution

-toxic waste generation I

I -haz. 8 solid waste

-toxics release -haz. waste

atewide goal- se reduction: -10% by 7/1/93

enacted '90 -20% by 7/1/95 -30% b 7/1/97

Massa- Reduction: chusetts -toxics use

and/or release + la ewide goal- aste reduction

enacted '90 -50yo

Michigan . possibh '92 I

Materials SARA toxic substances 8 Illinois lists

CERCIA hazardous substances 8 Indiana

"environmental wastes.

Iowa lists which include SARA, RCRA

RCRA, SARA

RCRA

SARA toxics. RCRA

SARA toxics. CERCIA

Priorities Includes: -input. process, product change in-house recycle Excludes: -treatment -media transfer -volume change -incineration Includes: -input, process, product change in-house recycle

Excludes: -off-site recycle media transter -incineration

Includes: .input. process, product changes integral recycle Excludes: .burning. transfer off-site recyde. exchange

Includes: -input. process, product change in-house recycle Excludes: -ofl-site recycle or lreatment

-volume change Includes: -in-plant practices

-in-process recycling

Excludes: -on-process or off-site recycle

-toxicity change Includes: -input. product or process changes -capture for reuse. recycling treatment

Includes: -input, product or process change Excludes: -incineration media transfer -1realmenl -olt-sile recycle

Coverage Provisions Voluntary 8 pilot (Cwperation

on permits) generators

Voluntary & oilot

Includes: -SARA reporter -LOGS

Voluntary: -RCRA and SARA report data mllected

Includes: -1argequantity generators

Includes: -largequantity generators -smallquantity generators -1oxics users Excludes: -some LOGS. P O l W S

Includes: -largequantity toxics users

-small-quantity toxics users Excludes: -facilities< 10 employees

WRITAR 1313 5th St. SE Suite 325 Minneapolis, MN SEPTEMBER 1992

-Technical assistance

-Innovation -Inspectors' manual

-Explore enforcement

-Research (HWRIC)

-Technical assistance

-Research -Grants -Generator planning manual

-Facility plans & summanes

(voluntary) -Technical

assistance -Information

-Technical assistance

-Information .Training -Grants -Set state goals

-Waste reduction

plans (done) -Technical assistance

-Fee SIrucIure promoting

reports 8

reduction -Facility plans and reports .Info program -Advisory mmmiuee

-Technical services

-Grants

-Facility plans and repom

-Toxics use planners

-Toxics use survey

-Technical assistance

-Technical assistance

Access Trade secrets protected

Trade secrets protected

Plans submined to the Waste Management Authority for review and approval

Trade secrets orotected

Public data laws apply

Plans available to state

Public petition for review of plan summary and report

-plans are public; trade secrets protected

Funding General fund and money raised by HWRIC activity

General fund

General lund

General fund

Based on fees 8 the general lund

Based on fees

Based on tees

5541 4-4502 (612) 379-5995

SURVEY OF STATE LEGISLATION

Statelstatus Definitions Materials Priorities

SARA 111 313 oxics

;ARA. 3CRA

m~ a donh Carolina

3CRA solid 8 lazardous uastes

Minnesota

reduction Reduction: -input. process, product changc in-house recycl

Includes: -input, process. product change in-house recycl Excludes: -ofk i te recycle or treatment

-incineration -increased poll. control

Includes: -input. process, product change in-house. closed-loop or off-site recycling

Includes: -minimization or reduction of quantity or toxicity of haz waste

Waste Reduction -source reduction (inputs. process,

procedures) -on-site recycling -off-site recycling -treatment

enacted '90 Mississippi

iARA. CRA

enacted '90 Missouri

Includes: -input, process,

proposed '91 (not passed)

N e w Jersey

snacted '91

New York

enacted '90 North

Carolina

enacted '89 Ohio

proposed '91 Oregon

enacted '90

WRITAR

Prevention: -toxic pollutants us& release generation No Statewide numerc goals M nimization: -haz. waste

jtatewide goal- vaste reductior -25% by 1 1 1 M Prevention: -source reduction

Reduction: -hazardous waste generation No &%ex& numeric goals

Prevention: -hazardous substance pollution

itatewide goal- jischarge ,eduction: -50% by 1996 Reduction: -ha. waste, toxic substance release 8 generation jtatewide goal- raste reduction .50% by 1999 Management a

Minimization: -haz. waste

No Statewide iumeric goals ?eduction: haz. waste

tatewide goals I be stablished 3eduction: toxics use haz: waste generation

\lo statewide iumeric goals

-input. product or process change

-reduclion in releases

Hierarchy: €PA-listed 1. Source haz. waste reduction

2. Waste reduc 3. Recycling 4. Treatment 5. Disposal

result in a

product change in-house. dosed-loop or otl-siie recycling

Coverage includes: -SARA reporters

4arge-quantily generators (fees only)

Includes: -largequantity generators -smallquantity toxics users

-SARA reporters

Includes: -large-quantity generators wnall-quantity toxics usars SARA reporters

"rionty lacilities n salcctad SIC wdes m 3 tears

3merr may be eqL.re4 oy OEP

ncludes: current permit holders generators of 25 tons and ip

ncludes: all NC fee- paying generators

ncludes: RCRA generators out-of-state generators are subject to fees

icludes SARA reporters generators: conditionally ?xempt lully-regulated smallquantity

1313 5th St. SE Suite 325 Minneapolis. MN SEPTEMBER 1992

Provisions -Facility plans and reports

-Guidance manua

-Technical assistance

-Grants

-Facility plans and reports

-Technical assistance .Training .Research .Explore new StaNteS Facility plans and reports Information Conterences Waste Audits .Low-interest loans Waste exchange Training

Faolity-wide permitung Facility plans 8 summanes Training

Facility plans 8 repons Guidance manual

Evaluation

Facility plans Technical assistance Grants Information

Technical assistance Enforcement Facility plans. noliftcattons 8 annual reports

Facility plans, eports 8 iummares rechnical assistance rraining nlormation

Access Public petitioi tor review of progress reports

-plans are protected

Plans may be made available lo public; trade secrets are protected

Plans and reports are available to the public; trade secrets are protected

Trade secrets available to state, but not to public

'ublic data ules apply

qeviewed by 3HEPA log 01 reviews done IS public .rade secrets confidential

iummaries are 3ublic record axcept trade secrets: plans 4 reports stay m-site

Funding Based on fee:

Based on fees

Based on fees

Based on fines 8 general fund

Based on fines & general lund

3ased on fees

:ees based on generation of hazardous 8 solid waste (may not pass) -ines

3ased on fees

5541 4-4502 (612) 379-5995

SURVEY OF STATE LEGISLATION

Statekfafus D e f i n i t i o n s Materials Priorities Coverage Provisions RCRA, Rhode Island lists of "hard- to-dispose' materials

island -haz. waste lacilities

Includes: -Technical assistance -all users of

har. waste -Education -Research facilities -Grants

South

-toxics

SARA, CERCLA. SC lists

RCRA

generation

goal-

Includes: Includes: -Facility plans,

product change, users in summariis in-house or selected -Technical

assistance dosed-loop SIC d e s . recycling small or -Outreach 8

Excludes: large training -incineration -Polws -Classify units

Excludes: of production -treatment -off-site recycle under 10 FOE -media transfer Includes; Includes: -Facility plans, -in-process recyding or generators summaries changes in -large-quantity -Technical process or generators inputs -Civil fines

-input. process, -toxics reports &

-smallquantity reports 8

assistance

-haz. waste

SARA 111 313 RCRA

SARA, RCRA

SARA, WA lists, Montreal Protocol (ozone-

depleters)

SARA, RCRA

-source bf atewide goal- aste reductior

Includes: Includes: -Facility plans, -input. process, -SARA reporters reports & product change -Large-quantity summaries Excludes: generators -Governor's -any process not Award integral to the -Permit variance

-Information product that alters the -Conferences waste -Training

-Waste Audits Includes: Includes: -Facility plans -input. process, -smallquantity 8 reports product change, generators -Study of toxic dosed - l o o p -largequantity use reduction recycling generators -Tax RCRA Excludes: generators -incineration -household -Technical -treatment generators assislance -volume change -Research -media transfer -Retail labeling

Includes: -Facility plans Includes: -input. process. -all haz. waste & summarier product change, generators (voluntary impl.)

regulated by -Feestpenalties closed-loop WA -Technical recycling

Excludes: -SARA assistance -incineration reporters -Research -media transler -Training

Includes: Voluntary Y!&alau -input. process, -Waste audits product change, Includes: -Research dosed-loop -haz. waste -Grants recycling generators

-incineration substance -Waste min. -treatment users documentation -out-of-process on manifests recycling 8 reports media lransler

Excludes: -hazardous Maadatory

-source Minimization:

Washington Reduction: - h a . waste -hazardous substance us8

goal- enacted '90 waste reductior

-50% by 1995 Wisconsin Use 8 Release

Reduction: -toxic pollutants

-ha. waste 8 substances

PollutionPrev.

- h a . waste

I 8 Reduction: -source -1oxics use I Establish and adopt a

enacted '90

Access

Citizen petit ion Trade secret: protected

Summaries are public: plans 8 reports aren't

Summaries and reports are public; plans are not Board can declare plan confidential

Trade secret: are protected

Summaries & reports are public; plans are not Competitive px i t i on protected

L l r r ? enacted 739 numeric goals

Funding Based on lee! and general fund

Based on lees

General fund

Based on fees

Based on fees

Based on lees

General fund

WRiTAR 1313 5th St. SE Suite 325 Minneapolis, MN 55414-4502 (612) 379-5995 SEPTEMBER 1992

2.2-WHAT IS SOURCE REDUCTION?

The PPA defines source reduction as any practice that "reduces the amount of any hazardous substance, pollutant, or contaminant entering a wastestream or otherwise relcased to the environment (including fugitive emissions) prior IO recycling, rreamenr. or diJposal." The PPA further defines, practices that are not considered source reduction as those that alter "the physical, chemical, or biological characteristics or the volume of a hazardous substance, pollutant. or contaminant through a process or activity which irselfis not integral to and necessaq'for the production of a product or the providing of a service:" For reponing source reduction and recycling on Form R. the terms hazardous substance, pollutant. or contaminant refer only to toxic chemicals listed under Section 313 of EPCRA.

eliminates the quantity of a toxic chemical entering wastesrreams. The following general categories of source reduction are to be reponed on Form R:

For PPA reponing purposes, a source reduction practice is therefore one that reduces or

Good operating practices

Inventory control

Spill and leak prevenaon

Raw materials modifications

Process modifications

Cleaning and degreasing

Surface preparation and finishing

Product modifications

These categories are general descriptions of h e types Of practices that are considered source reduction. Table 2-1,presenrs detailed subcategories for reponing on Form R. Table 2-2 provides specific examples of source reduction. dong with the applicable reponing category for Form R.

The key point to remember is that a source reduction activity reduces the amount of a toxic chemical that enters wastesneams. Actions taken to recycle, ueaS or dispose of a toxic chemical after it has entered a wastestream are not considered source reduction.

Most source reduction activities occur within a production process. Exceptions to this rule involve the use of a toxic chemical in a raw marerial or feedsrock srream in a recycling or treatment process. For example, if a facility was using hydrochloric acid as a pH control agent i n a wastewater m a t " process and then switched to the use of cimc acid for the same purpose. this would be considered a source reduction practice.

2.3 WHAT IS RECYCLISC? Recycling acliv~ties include bui are no! limited to the reuse. iunher use. rcclammon. 0:

exuactlon of the toxic chcmical throu_eh a proccss or acr ivtry thar 1s i e > x a ~ c from the process or acoviry that produced the wastcsueam. This includes recycling when Ine recycled toxic chemical 5s used for 11s original purporc or for a different one

prevennon reponing. recycling operations can be divided into three citegoner. in-process recycling. on-sire recyclinfg. and off-site recycling. In-process recycling I S reponed as source reduction on Form R. whcrcas on-site and off-sitc recycling arc reponed as rccycling. The followlng subsections present dcscriptions of the three categories

In-Process Recycling

I t is hercforc imponant 10 differcntiatc betwccn in-proccsr recycling and othcr recycling acliviticr that M not conridcrcd sourcc reduction. Thc dctcrmining factor is whcthcr thc activiv falls hsidc or outsidc a production proccrs. For rcponing purposcr. in-proccss recycling I S

dcfincd as hc muse orrccirculation of a toxic chcmical wirhin aproducnon procerr: it may also involvc a rccovcry orrcclamarion stcp. Thc toxic chcmical i s king returncd 10 thc production proccss and has not yct c n t c d a wastcsmam. 11 is considcrcd a sourcc rcduction activity if 11 1s soleiy dedicored 10 andphyrically inregrared wirh rhe producrionprocers by piping Or another mans of convcyancc. “Solcly dcdicatcd“ mcans thc chcmical is retumed to thc production proccss whcre it was gcncratcd. “Physically in t cp tcd with thc production proccss” includes the UK of open convcyancc or nansfcn to othcr containcrs by any mcans. Thc in-pmcrs rccycling dcfinidon may also k satisfied by mccting rhc conditions for RCRA “closcd-loop rccyclhg” in 40 CFR Sccuon 261.4(a)(8). which arc as follows:

Thc tcrm rccycllng covcrs a broad specr” of opcrations. For the purposes of p0Ilul:on

For pollution prcvcntion reponing, in.process recycling is conridered source reducrion.

* Only lank storagc (ifany) is involved. and hc cntirc p m c s r through completion Of

rcclamarion is closcd by being cntircly conncced with pipes or othcr comparablc enclosed mcanr of convcyancc. Rcclamadon docs nor involvc conuolled flamc combusrion (of the Section 313 chcmical) such as occurs in borlcn. indusmal furnaces. or incineraron. The malcrials are nwer accumulated in tanks for more than 12 months without being rcclaimcd. The m l i m c d matcrial is cirhcr not used 10 prcducc a fuel or othe: producrs that arc used i n a manner consuturing disposal.

.

.

On.Site Recycling

considemd on-sitc recycling: For pollution prcvcntion reponing. four critcria must bc met beforc an activity can be

The activity must be pcrformcd on-site. Rcuse or funhcr usc of thc roxic chemical must involvc a reclamation or rccovcry stcp prior to that funhcr usc or rcuse. Rcusc or funher use without a rcclamation or recoven. stcp is considcrcd in-proccrs rccycling or usc as a feedstock for anothcr proccss. Rccovcry or rcclamation is any proccss that thc chcmical undcrgccs to make i t rcurable. For cxample. rccovcw or rcclamation may include purification. cxuaction. distillation. filuarion. condcnsation. adsorption. or absorption pmcsscs .

Thc acrivity cannot bc conridcrcd in-proccsr recycling (this would be rcponcd as source rcduction). In-proccnr rccycling gencrally i n v o l v ~ s rcusc of P chcmical within a proccss. On-sitc rccycling activities must involve hc rcclamation of a chcmical in a wasusmam that i s rcturncd 10 a diffcrcnt proccss from that in which i t is gencratcd. Reuw activities involving combustion or acid ncumlization arc nor considcrcd on.sile recycling; they arc considcrcd maimcnt operations.

*

.

*

- OfT.Site Recycling

considcrcd off-site rccycling: For pollution prcvcntion rcponing. three cntcna must bc mct before an activity can bc

Thc activity must bc pcrformcd off-sitc. Rcusc or funhcr usc ofthc toxic chemical must involve a nclamation or rccovcry stcp prior 10 that funhcr UIC or rcusc. If rcusc or funhcr use of ihc toxic chcmical i s accomplirhcd without a rcclamarion or rccovcry step. the toxic chemical is considered a feedstock for an off-sitc activiry. I t is not conridcrcd a wastcsucam.

Rcuw activities involving combustion or acid ncumliration arc no1 conridcrcd off-sile mycling; they arc considcrcd off-ria ucatmcnt opcrations. For Sccrion 313 rcponing in previous years. toxic chcmicals scnt oil-rirc for rccycling

*

*

.

wcrc not rcpomd on Form R. Polludon prcvcntion rcponing rcquircs that thcrc quantiticr now k included in Section 8 of Form R. Anolhcr imponant change under the ncw pollurion prcvcnuon reponing rcquircmcnts is h a t combusdon for hear or energy rccovcry i s now P ” ” < i , i P r r r l 111111- *.-tm?”. ,.?,h-* .L*” ?-?.,*I;””

.

I

Table 2-2. Examples of Source Reduction.

Wasleslream

Releases of raw malerial from unloading hoses

Release of solvent to air

Release of phenol to watcr and air

Air emissions of volatile componenu from storage tanks

Air emissions of volatile solvenu

Releases from pump scal leaks

Off-sile transfer of manganese in solid w a s u

Air release and ofF-sile mnsfc r of solvent

Release of I.I.I-trichloroelhane IO air from vapor &greasing

Relwse of CFC-I 13 lo air from prinlcd circuit hiaril cleaning

Reporting Calegory

w32 Improved procedures for loading. unlcading. and transfer operations

W36 Implemented inspeclion or monitoring program of potenlial spill o r leak SOuTCeS

lndus l rv

General

General

Phenol manufacturing

Gcnen l

General

General

Pigment manufacture

P h m a c c u l i c a l s

General

Printcd circuit hi;ird ninnuLicturc

W39 Other spill and leak prevention

W42 Substituted raw malerials

~ ~~

Source Rcdurlion Aclivity

Replacemenl of h t o m unloading lrom tank cars wilh lop unloading IO reduce loss of raw niaierial fwm disconnection of .unloading hoses.

lmplemenlation of mutine i n s p i i o n s of solvent slllrdge and uansfer systems. including piping and uansfcr equipmenl. to prevent loss 01 v i lvcn~ 10 aar through early dcuction of leaks and spills.

Initiation of continuous wastewa(cr discharge monitoring for organics (r) ilctocl phenol in WilSlewiiicr effluent. which resulicd in rcpnir of phenol process Ical;s. Installation of a pressure relief valve ui minimiic breathing Iosscs of organic vapors 10 air from s o r a g e tanks. Replacement of flanged piping with weldnl piping 10 prevent emissions of volatile solvents to air through piping flanges.

Replacemcnl of single mechanical scnlr with solless pumps IO reduce losses from Icaks.

Replacement 01 potassium pcrmanganaie wilh potassium chlorate a an oxidizing agent for metals precipitation in the production of mcwl pigmetiis IO

climinau processing of manganese conipoimds.

Rcplacemcnl of toluene with non-Sat ion 3 I3 ailvcnt as a carrier solvcnl for medicinals.

Replacemcnt of I.I.I-uichlorcrihanc in a v a ~ x ilcgrcaser with an aqueous clcining system.

Replacemenl of CFC- I I3 in B conveyori7cd vavir dcgrcawr/ilcfluxcr with a lcqrnr hxwl clcancr.

(conrinued)

Tahle 2-2 (conlinited). I

W51 Instiluted in-poccss recycling

WSZ Modified equipment. layout. a piping

Wsstrslream

Release ol glycol elhers to air and water

HCI missions to air lrom swage. uansler. and mixing operations

Air missions of niuic acid

Ofl-site Iransfer of hrass casting waste

Spent core sand conwining chromium compounds

Washwater conwining glycol elhers

off-site mnsfer or butyl acrylate and vinyl ikclale residues

Air emissions of hydrogen fluoride

Raw materials in drums

Industry

Alkaline clwner manulaclure

Liquid detergent manufacture

Explosives prnduction

I3raswbrnnic foundry

Sray iron loundries

Seneral

'hosphoric acid produclion

kncral

~~ ~

Siiurrc Rcduclion Acllviiy

Change in ratio of prnducl mia or alkaline clwwr production lrom liquid ui solid prmlucn IO rduce h e quantity of glycol ethers pr~ressal as a component of liquid cleanns and suhsequenily. the amount releascd 10 air and water.

Replacement ol a 32 pencni HCI solution with a 2Y percent solution to reduce HCI air eniissionr hccausc of the dccreascd volatility ol the solution.

Modification or continuous process nimtion rmctm wilh fume recovery and reuse equipment UI ruluceemission olniuic acid mist.

Return of hrass-trimming shavings from lhc productinn ol brass castings to the lumace lor remelting and recasting.

Reuse ol core sand lor core molding process.

lnslallation ol a washwater rcclaiminglrocycling syswm u) allow in-priress r c u x ol wxshwarcr as inakeup w a r r in pmduc~ fnrmulatinn u> rcducc Ihc loss olglycol erhcrs in product tu wawwaicr.

lnslallation ofdulicated piping in the latea pra-e.;~ u) eliminafe piping clwnings h a t resulwd in generation ol hutyl acryl:ite and vinyl aceuw wastes.

Switch from usc ol an air-cooling sysvm to vacuum.fla$h ccnling ofrcrtnr vapors io mininiiie air emissions ol hydrogen fl~ioridc f r ~ n i the phosphnric acid rwctw.

U.% ol a mnre ellective pump lor emptying drums 11) dccreau: drum rcsiilues ;mil. thuclim. i~ff-sitc , . I . . 'ins us.

Iconrinupd)

Table 2-2 (continued).

ReportinR Catcprwy

WS3 Changed process c d y s t

W54 Instituted better controls oi operating conditions (flow rate. tempentwe. pressure Ksidence time)

W l 2 Modified spray systems or quipmcnt

W78 Other surface peparalicm and finishing modification

WR2 Modified design or composition

Waslalrvdm

Release of mercury to air and water, and off-site transfer of mercury in solid waste

Ai r emissions of hydrogen nuoridc .

Air releases of cleaning solvent

Air releases of paint solids

Release ofcleaning solvent IO

air

Ai r emissions of chromium and $kite transfer of chromium in d i d waste

lndirslry

Dye m:inufaclure

Ilydrofli~oric x i d production

Spray coating operations

Spray coating operatinns

Spray coating

Gray iron loundry

~~~~ ~

Soarre Reclurlinn Arlivity

Change in Ihe process chemistry for fx~duclwn 01 dyes 10 eliminate Ihc need fiir a niercury camlysi. which wil l eliminate mercury from wiisie sucnn~s

Maintenance of a slight negative presswe in thc kiln during production.

Upgrading ormanual guns uscd in surfnce ciiatiiig crpcra~ion with a device i h a ~ limits ihe :imotini 01 claning solvenl lhal can he clisprnscd imni ihc gun nozzle during purging of Ihc gun; h i s dccrc:~scs ihc quantity of solvent iaul f o r purgmg aiid. I I I T ~ P I I I I C . the qiianlity released to air.

Replacement of manual spray guns for suri;tce- coating operdtions with aummatic spr:iy pitiis 111:ii

incmase the paint-mnsfcr eflicicncy :ml rctliicc tlic ipanuty of paint solicls lost to air.

Reduction in air rcleascs of Section 3 I 3 S O I V C I I I ' I h y institution of a program io train operat~rrs io c o n s " solvent during pain1 swirhnvcrs and equipment cleaning.

Decrease in Ihc percentage of rhromiiim alloy added to Ihc iron melt. while st i l l ni;iinw~nii~g thc critical pmpcrlies of the p m l i r t ; this change dccicmes Ihe quantity of chromium relwsd to air :mi vansferred off-sile f o r dispel in siilid wiiqic.

Material stream On-site:

Elecuoplating wastewater

Clean-up wastes from paint formulation

Industry

Elauoplad ng

Paint fwmulaiion

Metal wnrkinglfabrication

Refractory manufacturing

Slcel manufxiuring

General

Gcneml

Ofl-sirc: Solid metal waste

Dcrcriptinn

Rccovery of mcol frnm h e wastcwatcr using eleclrnwinning and ihcn reusing the mcwlas an ancxlc in anothcr clwropl;itmg lmc.

Collat inn and dislilliition of paint waste U i reclaim snlvc.iit and rain{ snlldy, the p i n t solids arc hlcndul with cilhcr raw niiltcri:ils ID IwxIiicc il KI I~C primer pmdirct.

Collcstion of metal grinding and finishing shavings that arc ccnt 1 0 ii nirul rccyclcr for resale.

Shipment of furnace dust conwining molyhdenum trioxitlc 1 0 a rccyclcr for resale tn Ihc stccl indusuy.

Transfer of furnace dust off-site fnr high-tempcnture ueauncnl to rccovcr the mcwls (zinc. caclmium. and lad) fur rcurc.

Shipmcnt nf spcnt dcgreising solvent tn an off-site facility t h t rccliiinis 111c chlorinatcd solvent pnnion of h e sueam.

Shipment of usul purge solvcnl to an off-site l i ~ i l ~ t y .

Solid metal compound waste

Electric arc furnace dust containing zinc. cadmium, and lead

Spent dcgrcacing solvent

Paint spny-Eun purRe solvent

I

Table 2-3. Examples of On-Site and Ofl-Sile Recycling.

Reuse acoviry

On.nte Otbsite

burning lor ueauoent

recycling

beaunent

RCRA

Not reponable (leedstock)

reclamation recycling

NOI rep3rtaMe Aclivities that are (intermediate considered +

feedstock) in.process recycling

Rbponas inwccess implemented in recycling e m n g year? ( W r W

redumon)

Figure 2.2. Distinguishing Between in-Process, On-Site, and 0lI.Sile Recycling Activities.

Release f .

Raw - mamds

c Rdaase f -

Schematlc Diagram of Generic Manufacturlng Process.

Release Release to air to air

p' p

Fresh solvent makeup

Dirty pans Clean pans

w- Faulily taundav

Figure 4.1. Material Streams in Vapor Degreasing.

1.1 VAPOR D E G R E A S I S G

from production items that are to be painted. Figure 3-1 illustrates the path of trichloroethylene in-the vapor degreasing process. Degreasing solvent i s stored in 55-gallon drums and added to the degreaser when makeup solvent is needed. Tnchloroerhylene is released to air during the addition of trichloroethylene to the degreaser ( A I ) and from the vapor degreasing process (A?) . Spent degreasing solvent from the unit is sent off-site for recycling 0-1).

Table 4-2 summarizes these streams and classifies each for source reduction and recycling reponing. The table can be used to identify reponable streams for completion of Form R. Table 4-3 shows how the required quantities should be entered onto Section 8 of Form R. The facility could use the change in the number of production items that were painted between the current year and the preceding year as the basis for the production ratio/activity index for trichloroethylene. Alternatively. the ratio of degreaser operating time between the current and preceding years could be used to derive the prcducrion rado/activity index.

trichloroethylene in the dirty solvent sent off-site for recycling ( L l ) are identified on Table 4-3 as “entering wastesueams or released to the environment prior to recycling. treatment. or disposal.“ No wastestream containing trichloroethylene is recycled on-site, nor is any wastestream with trichloroethylene treated on-site or off-site. Trichloroethylene in the spent solvent (L1) is the quantity “sent off-site for recycling.” No trichloroethylene is “released to the environment as a result of remedial action, catastrophe, or other onetime events not associated with production processes.”

.A facility otherwise uses mchloroethylsne i n a vapor degreasing un i t to clean din and 011s

.. The releases to the environment from production processes ( A l , A2) and the

e Table 4-2. Identification of Vapor Degreasing Streams.

Section 01 Form R

entering wastestreams or released ID the environment 8.1 Quantity pnor ID recycling. ueamment. or disposal

8.2 Quanuiy recycled on-site

8.3 Quaniity Sent off-site for recycling

8.4 Quantiiy enrering ueauneni on-site

8.5 Quantity Sent off-site for treament

8.6 Quantity released to b e environment as a result of a remedial action. calasuophe. or other one-time e v e w not associated with production p m e s w s

in s t ream

ethylene

ethylene

Trichlor- ethylene

Quant i t ies 10 be entered

A I + A 2 + L I

0

LI 0

0

0

I

Stream description

Au emissions of uichlorwthylene from uansfer operations (released w air)

&remissions of mchloroethylene from &greasing unil (released to alr)

Spent degreasing solvent (IO off-site recycling)

,.,. ,,

Classification lor Fo rm R reporl ing

Wasresv~ams from production w the $i

environmenl

!! Wasrestreams from production u) the environment

Wasrestreams from production 10 off-site recvcline

. .. ~ ~ . . . . . . . . , . ' . ...

. . . . ' JHH585

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- 1 SECTION 1. SHORT TITLE AND TABLE OF CONTENTS. .. 2 This Act may be cited as the Pollution Prevention Act

3 of 1990'*, . .

TABLE OF CONTENTS Sec. 1. Short title and table of contents. Sec. 2. Findings and policy. Sec. 3. Definitions. Sec. 4. EPA activities. Sec. 5. Grants to States for State technical assistance

programs. Sec. 6. Source reduc:ion clearinghouse. Sec. 7. Source reduc:ion and recycling data collection. Sec. 8. EPA report. Sec. 9. Savings provisions. Sec. 10. Authorization of appropriations. Sec. 11. Implementation.

4 SEC. 2. ?I?aDzMGs AND POLICY.

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12 materials use. Sach changes offer industry substantial

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(a) FIND I NGS.-Tae Congress finds that:

(1) The United States of America annually produces

millions of tons of pollution and spends tens of billions

of dollars per year controlling this pollution.

(2) There are significant opportunities for industry

to reduce or pre-~ent pollution at the sourct through

cost-effective cbnges in production, operation, and raw

savings in reduced raw material, pollution control, and

'liability costa as well as help protect the environment - ~d reduce risks to worker health and safety.

16 (3) The opportunities for source reduction are often L

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1 not realized because existizg regulations, and the

2 - industrial resources they require for compliance, focus

3 upon treatment and disposal, rather than source

4 reduction; existing regulations do not emphasize

5 multi-media management of pollution; and businesses need

6 information and technical assistance to overcome

7 institutional barriers to the adoption of Source

a reduction practices.

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(4) Source reduction is fundamentally different and

more desirable than waste BLaMgement and pollution

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control. The Environmental ?rotection Agency needs to

address the historical lack of attention to source

reduction.

(5) As a first step i n preventing pollution through

source reduction, the Environmental Protection Agency

must establish a source redaction program which collects

and disseminates informatioi, provides financial

assistance to States, and hplements the other activities

provided for in this Act.

(b) POLICY.--The Congress hereby declares it to be the

national policy of the United States that pollution should be

prevented or reduced at the source whenever feasible;

pollution that cannot be prevented should be recycled in an

24 environmentally safe mannerr whenever feasible; pollution

25 that cannot be prevented or recycled should be treated in an

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environmentally safe manner whenever feasible: and disposal

or other release into the environment should be employed only

as a last resort and should be conducted in an

environmentally safe manner.

SEC. 3. DmZlOlfIONS.

For purposes of this Act- .. (1) The term Administrator.. means the

Administrator of the Environmental Protection Agency. .. (2) The term Agency.’ means the Environmental

Protection Agency. .. (3) The term toxic chemical” means any substance

on the list described in section 313(c) of the Superfund

Amcndnents and Reauthorization Act of 1986. .. (4) The term release” has the same meaning as

provided by section‘329(8) of the Superfund Amendments

and Reauthorization Act of 1986. .. (5) (A) The term source reduction” means any

practice which-

(i) reduces the amount of any hazardous

mbstance, pollutant, or contaminant entering any

waste stream or otherwise released into the

environment (including fugitive cissions) prior to

recycling, treatment, or disposal: and - (ii) reducer the hazards to p;lblic health and the

environment associated with the release oi such

1 substances, pollutants, or contaminants.

2 The term includes equipment or technology modifications,

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process or procedure modifications, reformulation or

redesign of prcducts, substitution of raw materials, and

improvements in housekeeping, maintenance, training, or

inventory control.

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.. (B) The t e n source reduction" does not include

any practice w h i & alters the physical, chemical, or

biological CharacEeristics or the volume of a hazardous

substance, pollztant, or contaminant through a process or

activity which itself is not integral to and necessary

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13 service.

14 (6) The tern multi-media'. means water, air, and

for the productioa of a product or the providing of a

.. - 1s land. ..

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10 the Standard Iadustrial Classification Manual.

(7) The tern SIC codes" refers to the 2-digit code

numbers used foc classification of economic activity in

19 SEC. 4. nAACTIVITIFS.

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21 the Agency an office to carry out the functions of the

22 Admidstrator under t3is Act. The office shall be independent

23 of the Agency's siaqle-medium program offices but shall have

24 the authority to review and advise such offices on their

25 activities to promote a multi-media approach to source

(a) AUTHORITIESI--Thc Administrator shall establish in

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1 reduction. The office shall be under the direction of such

2 officer of the Agency as the kkinistrator shall designate.

3 (b) FUNCTIONS,-The Administ:ator shall develop and

4 implement a strategy to promotr source reduction. As part of .

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5 the strategy, the Administratc- shall--

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? source reduction;

8 ( 2 ) ensure that the A ~ e ~ c y considers the effect of

9 its existing and proposed 3rograms on source reduction

10 efforts and shall review replations of the Agency prior

11 and subsequent to their propsal to deternine their

1 2 effect on source reductiot:

13 ( 3 ) coordinate source reduction activities in each

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15 promote source reduction practices in other Federal

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1 8 ( 4 ) develop improved re-dods of coordinating, and

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20 environmental statutes:

21 ( 5 ) facilitate the adoption of source reduction

22 techniques by businesses. Ttis strategy shall include the

23 use of the Source Reduction Clearinghouse and State

24 matching grants provided fn this Act to foster the

25 exchange of information regarding source teduction

(1) establish standard methods of measurement of

Agency Office and coordinate with appropriate offices to

agencies, and generic research and development on

techniques and processes s!miich have broad applicability;

assuring public access to data collected under Federal

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techniques, the dissemination of such information to

businesses, and the provision of technical assistance to

businesses. The strategy shall also consider the

capabilities of various businesses to nrake use of source

reduction techniques;

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(6) ideniffy, where appropriate, measurable goals

vhich reflect the policy of this Act, the tasks necessary

to achieve the goals, dates at which the principal tasks

are to be accomplished, required resources,

organizational responsibilities, and the means by which

progress in meeting the goals will be measured:

(7) establish an advisory panel of technical experts

comprised of representatives from industry, the States,

and public interest groups, to advise the Administrator

on vaps to improve collection and dissemination of data:

(8) establish a training program on multimedia source

reduction opportunities, including workshops and guidance

documents, for State and Federal permit issuance,

enforcesent, and inspection officials working vithin all

agcnq program offices.

(9) identify and make recommendations to Congress to

eliminate barriers to source reduction including the use

of incentives and disincentives: *

(10) identify opportunities to use Federal

procurement to encourage source reduction:

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1 (11) develop, test and disseminate model source

reduction auditing procedures designed to highlight 2

3 source reduction opportunities; and

4 (12) establish an annual award program to recognize a

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6 innovative source reduction gkograms.

7 E. 5. c;BAIpTs TO STATES FOR STATE TECEMICAL ASSISTANCE

8 m. 9 (a) GENERAL ALITHORI TY ,--The Administrator shall make

10 matching grants to States for programs to promote the use of

11 source reduction techniques by businesses.

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13 under this section, the Administrator shall consider, among

14 other things, whether the proposed State program would

15 accomplish the following:

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company or companies which operate outstanding or e .

(b) CRITERIA,--When evaluating the requests for grants

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(1) Make specific technical assistance available to

- 17 businesses seeking information about source reduction

18 opportunities, including funding for experts to provide

19 onsite technical advice to business seeking assistance

20 and to assist in the development of source reduction

21 plans.

22 (2) Target assistance to businesses €or whom lack of

23 information is an impediment to source reduction.

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- (3) Provide training in source reduction techniques.

Such training may be provided through local engineering

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schools or any other appropriate means.

- (c) HATCHING FUNDS*--Fede:al funds used in any State

program under this section shall provide no more than 50 per . centum of the funds made available to a State in each year of

that State's participation in the program.

(d) EFFECTIVENESS*--The A&ninistrator shall establish

appropriate means for measuring the effectiveness of the

State grants made under this section in promoting the use of

source reduction techniques by businesses.

(e) INFORMATION.--States receiving grants under this

section shall make information generated under the grants

available to the Administrator.

SEC. 6. SOURCE REWCTION CLEABRK;HWSE.

(a) hJTHORITYa-Thc Administrator shall establish a

Source Reduction Clearinghouse to compile information

including a computer data base which contains information on

management, technical, and opcrational approaches to source

reduction. The Administrator shall use the clearinghouse to--

(1) serve as a center for source reduction technology

transf er;

(2) mount active outreach and education programs by

the States to further the adoption of source reduction

technologies; and - (3) collect and compile information reported by

States receiving grants under section 5 on the operation

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and scccess of State source reduction programs.

(b) PUBLIC AVAILABILITYI--The Administrator shall make available to the public such information cn source reduction

as is gatkered pursuant to this Act and such other pertinent

information and analysis regarding source reduction as may be

available to the Administrator. .&he data base shall permit

entry and retrieval of information t o any person.

SEC. 7. SOURCE REDUCTION AND REI=paIwG rm~ COLLECTION.

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(a) REPORTING REOUIREMENTSI--E~C~ owner or operator of a

facility required to file an annual toxic chemical release

form under section 313 of the Superfund Ar;endments and

Reauthorization Act of 1986 (“SARA”) for any toric chemical

shall include with each such annual filins a toxic chemical

source re8uction and recycling report for the preceeding

calendar pear. The toric chemical source reduction and

recycling report shall cover each toric cteAcal required to

be reported in the annual toxic chemical release form filed

by the ower or operator under section 313(c) of that Act.

This section shall take effect with the aznual report filed

under section 313 for the first full calerdar year beginning

after the enactment of this Act.

(b) ITEMS INCLUDED I N REPORT*--The toxic chemical source

reduction and recycling report required =der subsection (a)

shall-set forth each of the following on a

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(1) The quantity of the chemical entering aEy waste

- stream (or otherwise released into the environment) prior

- year for which the report is filed and the percentage

change from the previous year. The quantity reported

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shall not include any amount reported under paragraph

(7). When actual measurements of the quantity of a toxic

chemical entering the vaste streams are not readily

available, reasonable estimates should be made based on

best engineering judgment.

(2) The amount of the chemical from the facility

which is recycled (at the facility or elsewhere) during

such calendar year, the percentage change from the

previous year, and the process of recycling use&

(3) The source reduction practices used with respect

to that chemical during such year at the facility. Such

practices shall be reported in accordance with the

following categories unless the Administrator finds other

categories to be more appropriate:

(A) EquSpment, technology, process, or procedure

nodifiutions.

(B) Reformulation or redesign of products.

(c) Substitution of raw materials.

(D) Improvement in management, training,

inventory control, materials handling, or other

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general operational phases of industrial facilities.

(4) The amount expected to be reported under

paragraph (1) and (2) for the two calendar years

h d i a t t l y following the calendar year for whici the

report is filed. Such amoaEt shall be expressed as a

percentage change from the xkount reported in paragraphs

(1) and (2).

(5) A ratio of production in the reporting year to

production in the previous year. The ratio should be

calculated to most closely reflect all activities

involving the toxic chemical. In specific industrial

classifications subject to this section, where a

feedstock or some variable other than production is the

primary influence on waste characteristics’or volumes, ’

the report may provide an index based on that primary

variable for each toxic chemical. The Administrator is

encouraged to develop prodrction indexes to accommodate

individual industries for csc on a voluntary basis.

(6) The techniques wkich were used to identify source

teduction opportunities. Techniques listed should

include, but are not limited to, employee

rcconrmcndations, external and internal audits,

participative team management, and material balance

audits. Each type of aource reduction listed under

paragraph (3) should be associated with the techniques or

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multiples of techniques used to identify the source

- (7) The amount of any toxic chemical released into

the environment which resulted from a catastrophic event, -

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12 For the first year of reporting under this subsection,

13 comparison vith the previous year is required only to the

14 extent sach information is available.

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16 325(c), and 326 of the Superfund Amendments and

17 Reauthorization Act of 1986 shall apply to the reporting

18 requirements of this section in the same manner as to the

19 reports required under section 313 of that Act. The

20 Addnistrator may modify the form required for purposes of

21 reporting information under acction 313 of that Act to the

22 extent he deems necessary to include the aeditional

23 information required under this section.

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remedial action, or other onqtime eve=: and is not

associated with production processes dzring the reporting

(8) The amount of the chcmical from the facility

vhicd is treated (at the facility or elsewhere) during

such calendar year and the percentage change from the

(c) SARA PROVISIONS,--The provisions of sections 322,

ADDITIONAL OPTIONAL INFORNATION.--A~~ person filing a report under this section for any year may include with the

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report additional isforition regarding source reduction,

recycling, and othe: pollution control techniques in earlier

- (e) AVAILABILITY OF DATA,--Subject to section 322 of the

5 Superfund Amendments and Reauthotization Act of 1986, the

6 Ildmlnistrator shall make data collected under this section

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under section 313 of the Superfund Amendments and

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SEC. 8 . EPA BEPORT.

(a) BIENNIAL REPORTSa-The Administrator shall provide Congress with a report within eighteen months after ecactment

of this Act and bielnially thereafter, containing a detailed

description of the actions taken to implement the strategy to

promote source reduction developed under section 4 ( b ) and of

the results of such actions. The report shall include an

assessment of the effectiveness of the clearinghouse and

grant-program established under this Act in promoting the

goals of the strategy, and shall evaluate data gaps acd data

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duplication with respect to data collected under Federal

environmental statutes.

(b) SUBSEOUENT REPORTS.--&ch biennial report submitted - under subsection (a) after the first report shall contain

each of the following:

(1) An analysis of the data collected under section 7

on an industry-by-industry basis for not less than five

SIC codes or other categories as the Administrator deems

appropriate. The analysis shall begin with those SIC

codes or other categories of facilities which generate

the largest quantities of toxic chemical waste. The

analysis shall include an evaluation of trends in source

reduction by industry, firm size, production, ar other

useful means. Each such subsvent report shall cover

f ive SIC codes or other categories which were not covered

in a prior report until all SIC codes or other categories

have been covered.

(2) An analysis of the usefulness and validity of the

data collected under section 7 for.measuring trends in

sourc8 reduction and the adoption of source reduction by

business.

(31 Identification of regulatory and nonregulatory

.barriers to source reduction, and of opportunities for

rising existing regulatory programs, and incentives and disincentives to promote and assist source reduction.

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2 require priority assistance in multi-media source

3 reduction.

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7 (6) Zdentification of opportunities and development

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encourage investment and research and development in

of priorities for research and developenent in source

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(7) An evaluation of the cost and technical

feasibility, by industry and processes, of source

reduction opportunities and current activities and an ..

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significant barriers to source reduction with an analysis

of the basis of this identification.

(8 ) An evaluation of methods of coordinating,

streamlining, and improving public access to data

collected under Federal environmental statutes.

(9 ) An evaluation of data gaps and data dupiication

w i t h respect to data collected under Federal

environmental statutes.

In the report following the first biennial report provided

for under this subsection, paragraphs ( 3 ) through (9) may be

inclu&d at the discretion of the Administrator.

25 9. SAVTBGS PROVISIONS- %.-@

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(a) Nothing in this Act shall be construed to E d i f y or

inferfare with the implementation of title 111 of the

Superfund Amendments and Reauthorization Act of-1986. - (b) lOothing contained in this Act shall be construed,

interpret.d.or applied to supplant? displace, prewpt or

otherwise diminish the responsibilities and liabilities under

other State or Federal law? whether Statutory or cannon.

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SEC. 10. ~ W S T I O N OF APPR0PluATsoRs.

There is authorized t o be appropriated to the

Abinistrator $8,000,000 for each of the fiscal years 1991,

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1992, and 1993 for functions carried out under this Act

(other thaa State grants)? and $8,000~000 far each of the

fiscal pears 1991, 1992, and 1993, for grant programs to

States issued pursuant to section 5.

In the States

Defining Pollution Prevention and Related Terms

Terry Foecke

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Asthe enuIronmentnl " e n t h n s gcmfximmentum omthepast -.-of W t e r m s h a u e emerged to describe - aspects of poUutlonpreventlon In this article. lue &cuss the origins of swne of these terms and ho~, thefr various definitions of pollution pre- - LS eudm mMlentalmanarrement.Today,pol- vention included in legislation, as the *a of polluaon prewntlon mves ~ t h e s p o t u g u

sophisticated approaches to envi-

POLLUTION DON. Waste re- duction. Wasteminimization. Source reduction. Sustainable development. Toxics use reduction. Law- and non- waste technology. Clean products. Green products. In less than a de- cade, these and other phrases have rapidly expanded the terminology associated with environmental pro- tection.

The proliferation of terms also reflects the search for new and more

grams run by public agencies, and legislation that mandates industrial pollution prevention, use their own terms. In addition, each term may have several definitions depending on the types of activities the state chooses to emphasize. This range of terms anddefinitionsillustrates how new pollution prevention ideas are; there has been much experimenta- tion, but little codification. This col- umn gathers and categorizes the

- lution control and pollution preven- tion have very distinct connotations. The co~sensus is that traditional pollution control methods simply trausf~pollutantsfiumonemedium to another and therefore do not go far enough to protect all components of our environment. Pollution preven- tion, on the other hand, suggests an approach that goes to heart of the problem and tries to eliminate it.

Still, pollution prevention has many different interpretations. For example, in many cases, the defini- tion of pollution prevention in one state maybe markedly different from that in another state; definitionsmay even vary within a state. Both state and local ponution prevention pro-

well as pollution prevention pro- grams, at the state and local level.

Historical Perspective State officials in North Carolina,

who established one of the earliest formal state prograxns that specifi- cally addressed what we now call pollution prevention, proved to be prescient in their name and breadth of focus. The first promotion and technical assistance program in North Carolina called itselfthe "Pol- lution Prevention Pays Program" (a slogan pioneered by the 3M Com- pany) and resolved to consider all materials and by-products associated with industrial processes. This mul- timedia focus was seen at that time

Teny Foecke is president of the Waste Reduction Institute for Training and Applicntions Research, Illc M A R ) , (I nonprofit institution in Minneapolis. MN.

103

. . . waste redurtlon began to be vlewd by some people as a termusedsbictlgto ea" processes w g - -indusb-ial hnzardous luaste.

tobe more common sense thanit was representative of an overarching philosophy. A definition of pollubon prevention was implicit in their ap- proach.

Since North Carolina first used the term in 1984, the definition of pollution prevention has actually shifted &om a broad, inclusive, in- tuitive beginning to a collection of fragmented, mutually exclusive definitions. It is only now returning to a definition that is broad in scope and application.

Waste minimization (which in- cludes volume reduction, in addition to reduced generation) and waste reduction are related terms that constituted common vocabulary in stateprograms duringtheyears 1986 to 1988. Waste reduction was usedto describe activities that reduce the generation of waste. Some say that one reasonthistermbecamepopular was that it lent itself to amnyms m, ", WRITE, WRFN?S, etc.).

The terms are not interchange- able, however. The most important reason is that Ywaste" carries a spe- cific definition under the Resource Conservation and Recovery Act (RCRA), and that definition can preclude, or seem to preclude, the use of the word waste in any phrase intended to cover materials other than hazardous waste as defined by RCRA. Thus, waste reduction began to be viewed by some people as a term used strictly to examine pro- cesses that generate industrial haz- ardous waste. Programs concemed with air releases, water discharges, or other toxin often found waste reduction too "exclusive" to describe or guide their efforts.

Source reduction has always had adherents as a descriptive phrase,

mostly because of its implied focus on the point of generation, rather than the point of release to the environ- ment. Source reduction, which has traditionally been used in programs that dealt with municipal and in- dustrial recycling, began to see more use as a pollution prevention term in the late 1980s. It even generated a few acronyms of its o w n (SRRF', SREtTA, SRPA, etc.). However, source reduction has not adapted easily to broader usage. Specifically, the ac- tual location of the source, intended to be the point of use or generation, has often been interpreted to mean an entire facility or group of activities that constitute a s o m e of a release to the environment. This interpreta- tion has its roots in regulations per- tainingtoairpollutionconh1,which could limit its application to other media. A s a result, source reduction is oRen used more often to clarify the definition of pollution prevention.

Tmics use reduction has gained considerable prominence over the past few years. This term refers spec5cally to use as a means to focus on the earliest point of possible gen- eration or release. Its popularity can be attributed to at least two factors. First, the Toldcs Release Inventory (TFU) required under Title III of the Superfund Amendment and Reauthorization Act (SARA) estab- lished a database to measure im- provements in industrial environ- mental performance. This accounts, in large part, for the focus on toxin covered by any number of lists, and especially those substances included in the TRI. Second, many people are now as concemed about the potential exposure of workers to hazardous andto~csubstancesastheyareabout the health and safety of the public.

A groundswell of pollution pre-

104 Pollution Premtim Reuiew/Winter 1991-92

vention legislation at the state level in 1989 and 1990, in many cases, incorporated the themes of toxics source and use reduction. Use re- duction has been used as a descrip tivephrase insome ofthat legislation as a way toeliminate the ambiguities described in the preceding para- graphs and to drive the focus of pol- lutionnrevention as close as uossible

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Even though pUution prewntlon

descrIptIye phrase of choice. ti3

f S M W t h e

to th~source. whatever it; philo- sophical advantages, however, toxic9 use reductionis sometimes seen tobe limited to certain classes of sub- stances and activities.

Throughout the late 1980s and &m fs stul early1990s,otherterms have floated open to c e a b l e in and out of usage. Low- and non- interpretation waste technology, clean technology,

green business, and other phases have been used in other countries, especially in Europe. None of these terms are able to span all economic sedors (e.g.,industry andcommerce, transportation, and energy), al- though such an approach is deemed by many to be critical to a compre- hensive approach to environmental management. The most obvious problem is the failure to allow enough flexibility to consider all processes and decisions that may affect the environment.

Two responses to the demand for broader based concepts have been the phrasessustainable development and, in a return to the roots of the environmental movement, pollution prevention. Sustainable development is favored in international circles to promote the idea that economic growth does not have to be achieved at the expense of the environment. The specific message to industry: produce more with less.

Pollution prevention, however, is the term of choice in the United States. The US. Congress passed a

Pollution Prevention Act in 1990, and the EPA has published a Pollu- tion Prevention Policy Statement. The selection appears to be based on faders such as scope, ease of under- standing, and wide applicability. Once again, pollution prevention has spawned a number of acronyms (PPIs, PPIC, PPPFL, PPOA, and so on).

Difficulties of Application Even though pollution prevention

is now the descriptive phrase of choice, its definition is stiU open to considerable interpretation. One reason is the inclusion of many con- stituent parts (toxics use reduction, source reduction, waste ” i z a - tion, and the like) to cover all human activities, decisions, and processes. Establishing a priority ranking or hierarchy has also opened pollution prevention to further definition. For example, is recycling preferable to, or part of, source reduction? Ifrecy- cling is preferable, should it be on- site or off-site? If it is on-site, should itbeclosed-looprecyclingorrecycling that allows reuse in another on-site process?

Finally, the term pollution pre- vention sti l l can be confused with pollution control. This confusion oc- curs because of the failure of the phrase pollution prevention to high- light the most significant philo- sophical difference between the two: Traditional pollution control focuses on discharges to a single environ- mental medium (i.e., air, water or land), but can result in the transfer of pollutants from one medium to another (the oft-mentioned “shell game” inherent to end-of-pipe man- agement). Under pollution preven- tion, cross-media transfers are not acceptable.

PoUution Prevention Rev&?w/W[nter 1991 -92 105

Yet the distinction between pol- lution prevention and pollution con- trol is not always clear. One way to differentiate the terms is through the use of the waste management hierarchy. Although some confusion is possible because of the mention of the word Uwaste,n the hierarchy (shownbe1ow)is easytounderstand. It is an especially useful tool for en- vironmental decision maldng (mov- ing &om one area of p m s s and use examination to another). Typically, the hierarchy flows from source re- duction (at the top of the hierarchy) downthroughdisposal. Therankings encourage a full exploration of each option, moving on only when all o p portunities at a given level are ex- hausted.

SOURCE REDUCTION REUSE

ON-SITE RECYCLING OFF-SITE RECYCLING

TREATMENT DISPOSAL

By beginning with source reduc- tion, the hierarchy encourages the examination of basic assumptions about processes and use. By ending with treatment and disposal, the hierarchy also acknowledges that residuals are possible. However, the hierarchy is not a definition. It is simply a tool for individuals to use to makeinformeddecisions. Terms such as "source reduction" and "recycling" are not dehed in the hierarchy. Those who must deal with pollution prevention and related terms in the context of regulatory or legislative mandates, or who must choose the "best" option for any reason, must sti l l define and use their o w n guide- Lines.

At the State and Local Level This column has gathered defini-

tions of pollution prevention and of components of pollution prevention (e.g.. source reduction) from two sources: state and local pollution prevention programs, and state leg- islation that mandates pollution prevention activity.

Pollution prevention programs mayuse thesedefinitions forinternal goal-setting (e.g., choosing to allo- cate fewer resources to documenting treatment practices in favor of lo- cating and documenting recycling opportunities or process modifica- tions). Programs may also use defi- nitions to carve out a niche that is separate from other activities within a parent agency or organization (e.g., a nonregulatory program based in a regulatorg agency). In most instances, however, the definition only gives general guidance in initiative selec- tion and program development.

Legislative definitions are more focused. In the case of mandates to write and implement facility plans for pollution prevention, the defini- tion will determine the types of action a facility considers, what it may implement, and what matters when progress reports are written. In the case of regulatory requirements, definitions may guide the wordingof notices of violation and enforcement settlements. However, even the most elaborate definitions require inter- pretation, often at a site-specific or process-specific level. This is a com- mon problem in all types oflegislation and is no less diacult when it comes to pollution prevention.

Program definitions Among pollution prevention pro-

grams run by public agencies, there

106 Pollution Prevention Reuiew/Wmter 1991 -92

isabroadrangeindefinitions. Some programs see no need to state explicit definitions; others have definitions that are longer than those found in any legislation. These fall into four rough categories. Minimal or no dehitions are used by a minority of programs, primarily older programs that began operations before defini- tions were much of an issue and programs with a nonregulatory focus. An example of this group is the Pollution Prevention Pays Fro- gram in North Carolina, which in responsetoasurveystatedKSpec5c, limiting definitions arenotaproblem in our program since we are not involved directly with regulatory efforts.”

Some programs define only pol- lution prevention and define that term in such a way that source re- ductionis clearlyprefemd.Pmg”s that favor toldcs reduction or use reduction are includedin this p u p . Few programs define pollution pre- vention in the very broad terms de- scribed earlier. One example of a definition that strives to be allen- compassingcomes &the Pollution Prevention Program in Los Angeles County (California):

-

Pollution prevention is the pre- vention of the generation of wastes from industrial, com- mercial and residential activi- ties, including the avoidance of crossmedia transfer of pollut- ants. The waste can be hazard- ous or non-hazardous, solid, liq- uid or gaseous, and the means could include waste reduction, sourcereduction, recycling, clean product development and CUI- t u d and habit change or refor- mulation, industrial process m&cation, improved aciency and management practices, etc.

Another category of programs has definitionlists that encompass alarge number of terms, u sudy including pollution prevention, waste reduc- tion, waste minimization, source re- duction, and recycling. This is by far the largest category (thirty-eight of seventy-four programs surveyed). Thereisawiderangeinthedegreeof language specificity and the inter- connection between terms. Many of the detailed -dehi t ion lists” do not express a preference for a particular term. Some are drawn from legisla- tion passed in that state, and some make reference to federal legislation and policy statements. An example of a definition list is provided by the Bureau of Pollution Prevention in New York:

Pollution prevention is the re- duction in volume of solid waste, reduction in volume andor tox- icity of hazardous waste and/or toxic substances, including source reduction and recycling.

Waste reduction is the reduction in volume of solid waste, reduc- tion in volume and/or toxicity of hazardous waste, and is directed a t solid waste media.

Waste minimization is the same as waste reduction except that treatment to reduce or detoxi@ generated waste is included un- der waste minimization.

Source reduction is the in-plant practices used to reduce, avoid, or eliminate the generation of waste, includinginput substitu- tion, technology modification, goodhousekeepingpractices and product reformulation.

Recycling is the direct use or re- use (that which is not closed-

PoLluffonPrewntfonR~/Wfnter 1991-92 107

loop) ofwaste material in a pro- cess or reclamation by recover- ing secondary materials for separateend useorbyremoving impurities so that waste maybe reused.

-

Afinalcategoryawers those pro- gramsthat defineafew chosenterms, where others are not applicable or simply not commonly used by pro- gam ofEcids or their clients. This is a %ly large group (twenty of sev- anty-fburprograms). This is also the most d35cult list to catemrize be- cam of the variety of definitions and the reasons given for making thoa9 choices. Several examples will illustrate this divfmity.

The Maine Oflice of Pollution prevention goes to the heart of the a t i o n controversy and defines two components only, pollution pre- vention and recycling, as follows:

Pollution prevention is the use of processes, practices or prod- uetsthatreduceoreliminatethe generation of pollutants and wastes or that protect natural resources through consewation or more &aent use. Recycling is the collection, separation, recovery, and sale or reuse of material that would otherwise be disposed of or pr- cessed as waste, or mechanized separation and treatment of waste, other than through com- bustion, and the creation and recovery of reuseable materials other than as fuel for the gen- eration of electricity.

The Iowa Waste Reduction Cen- ter only uses a deb i t ion to award the annual Govemois Waste Reduc- tion Award. The Center therefore chooses to define only waste reduc- tion, but in a way that gives that term broad coverage:

Waste reduction is the reduction in volume andlortoecity ofwaste at the source, or reuse as a raw material in a production process. Reduction measures include process modifications, raw ma- terial substitutions, housekeep- ingtmanagement practices, re- cycling within a process, o r any other measure that reduces the volumdbxiaty of waste exiting aprocess or requiring treatment, or r e e s waste as a raw mate- rial in production of goods or services. .

AhalexampleisfromtheCityof Berkeley,California,ToudcsProgram, which uses the shortest dehi t ion of any of the programs:

Source reduction is any action that causes a net reduction in the generation of hazardous waste.

Table lshows the pollution preven- tion programs surveyed, grouped by the categories described above.

Legislative definitions The twenty-three state laws ex-

amined for this column yielded no fewer than ten discrete, but related, approaches to the problem of d e k - ing pollution prevention. Careful reading of the provisions of each defi- nition, however, reveals that many share some basic characteristics. On the issue of”allowab1e” recycling, for example, seventeen of the laws ex- plicitly exclude recycling activities that occur either away from the fa- cility or away from the generating process. Treatment or incineration or both are excluded &om the defi- nitionin fourteenlaws. Fourteen laws also include the dynamic W i s notm to M e r clarify the definition. Legis- lation passed by the s t a t e of Iowa includes all these themes:

Pollution RewntIon R a m / Wfnter 1991 -92

Table 1. State and Local Pollution Prevention Programs Grouped by Definition Category

Waste Reduction Assistance Program, Alaska Health Project 0 Pollution Prevention Office 0 Project ROSE (Recycled Oil Saves Energy) (AL) Center for Training, Research and Education for Environmental Occupations (FL)

Ninois Environmental Protection Agency (IL) The Hazardous Waste Research and Information Center (IL) Kansas State University RIl'TA Program (Rs)

Minnesota Pollution Control Agency 0 EPA Center for Waste Minimization and Management RIG)

Pollution Prevention Pays Program (NC) WasteCap (NH)

University Center for Environmental and Hazardous Materials Studies WA) Pollution Prevention Division (VT)

Vermont Waste Cap (VT)

City of Berkeley Toxics Program (CAI Connecticut Department of Environmental Protection (CT) Toxic Use Reduction Act Implementation Team CMA)

Minnesota Office of Waste Management 0 Minnesota Technical Assistance Program 0

Hazardous Material Management and Resource Recovery (a) Biomass Resource Recovery Program (AR) Hazardous and Toxic Materials Office, City of Los hge le s (CA) Pollution Prevention Program, San Diegu (CA) Chief Administrative Ofiicer's Hazardous Waste Management Rogram, San Francisco (CA) Connecticut Technical Assistance Program (CT) Florida Waste Reduction Assistance Program (F'L) Pollution Prevention Program, Hazardous Waste Technical Assistance Program (GA) Landfill Altemative Grants CIA) Comprehensive Solid Waste Management Planning CIA) Waste Reduction Assistance Program (IA)

The Indiana Pollution Prevention Program (IN)

PoUutlonPrewntion Reuiew/Winto 1991-92 109

Table 1. (continued) State and Local Pollution Prevention Programs - Grouped by Definition Category

Indiana PointSource Pollution Prevention Program for Agridturnl Industries 0 Rentucky Partners, State Waste Reduction Center 0 Waste Minimization Assessment Center 0 Toxics Use Reduction Institute (MA) Waste Reduction and Management Program 0 Mississippi Technical Assistance Program, Mississippi Solid Waste Reduction Assistance Program (MS) North Carolina Pollution Prevention Pays Program (NC) New Hampshire Pollution Prevention Program 0 Municipal Water Pollution Prevention Program 0 Solid Waste Bureau 0 Bureau of Pollution Prevention 0 Erie County Otfice of Pollution Prevention 0 - Pollution Prevention Program. Los Angeles County (CAI Pollution and Hazardous Waste Reduction Program, Bay Area (CAI Pollution Prevention and Waste Reduction Program (CO) Delaware Pollution Prevention Program (DE) Florida Center for Solid and Hazardous Waste Management (n)

Iowa Waste Reduction Center 0 Indiana Pollution Prevention Program OEce (INl Office of Pollution Prevention (ME)

Office of Waste Reduction Services (MI)

Waste Management Program (MO) Hazardous Waste Section (NE) New Jersey Office of Pollution Prevention (NJ) New Jersey Technical Assistance Program for Industrial Pollution Prevention (NJ) Business Environmental Program 0 Technical Advisory Services Division, New York State Environmental Facilities Corp. 0 Source Reduction Program 0 Toxics Redudion,Waste Reduction, Recycling and Litter Control Program (OR) Division of Waste Minimization and Planning (PA) Wisconsin Department of Natural Resources 0

110 Pollution Prewntlon R e ~ ~ k ~ / W i l ~ t e r 1991 -92

i ?

Toxics pollution prevention: em- ployment of practices or tech- niquesthatreduceindustrialus of toxic substances or the haz- ards associated with an environ- mental waste, excluding any practice applied to environmen- tal waste aRer generation (in- cluding dilution or concentra- tion). It includes:

L Input substitution 2. product reformulation 3. Production process redesign

or modification 4. Production process modem-

ization 5. Improved operation and

maintenance, including -improved housekeeping -system adjustments -product or process in- spection

-production process control equipment and methods

6. Recycling,reuse,orextended use integral to the production process

It does not include:

1. Buming of waste to re-

2. Transfer of waste be- cover energy

tween environmental or workplace media, or

into a product 3. Off-site recycling 4. Wasteexchange 5. Incorporating o r

. embedding regulated environmental wastes into products or by- products

6. Any other end-of-pipe management

Some state legislative definitions douseopen-endedlanguage,leading to broader applications. For example, legislation in Ohio and Alaska de- h e s a priority list ofwaste manage- ment actions that generators may employ. That noted, however, none ofthe state legislation has attempted the conceptual definitions and inter- twining of terms used by many of the pollution prevention programs, probably because of strider legal re- quirements applied to definitions that are to be included in legislation. Table 2 categorizes legislative defi- nitions accordingtothe primaryterm used in the law. The reader should keep in mind, however, that there are more similarities between these seemingly disparate terms than are readily apparent.

~~~~ ~

Table 2. State Legislative Definitions Grouped by Term

Primary Definition Term Hazardous waste reduction WasteJsource reduction Source reduction Pollution prevention waste minimization Waste reduction Toxic pollution prevention Toxics use reduction

No specific term defined

States Using Kentucky, Ohio Alaska, Tennessee California, Minnesota, Vermont Connecticut, Florida, Indiana, New Jersey Delaware, Mississippi Georgia, Louisiana Illinois, Iowa Maine, Massachusetts, Oregon, South Carolina %ode Island, Washington

PouutiOnRewntlonRariew/Winter 1991-92 111

.I ,,

Terry Foecke

In Conclusion As implementation of pollution

- prevention programs continues and legislative mandates evolve, a clear definition should emerge from these discussions andexperiments. At this time, it is important to remember that pollution prevention is a can- cept-a way of thinking about a numberofenvimnmentalissues.Like any concept, ita definition is clearest

when it is put in the context of a spedfic application and less clear when it is presented in the abstract.

Still, considerable variation remains: Waste reduction" in one state may mean "source reduction" in another. Nevertheless, dispari- ties are diminishing. and some clear lines are being drawn, especially in the areas of treatment and nwc-&.*

112 POLIutlonReventlonRe~~&~/viao/Wfnter 1991-92

Chapter 2

TIPS ON FACILITATING TRAINING COURSES

Introduction

This chapter presents a variety of sections designed to provide training facilitators with tips on the design, format and preparations for training workshops. The first section provides advice on organizing participatory workshops that can include lectures, small group activities, hand on activities and large group discussions. The next section provides tips on preparing the material, the physical space and yourself for a workshop. The final section provides some advice on workshop evaluation techniques.

This chapter has been designed to complement the materials in the EPA Instructor Training Workshop Manual, which provides much useful information on facilitating workshops. We recommend that users of this Handbook consult this Manual for advice and ideas on organizing training workshops. We have excerpted a few sections of the EPA Manual in this chapter. We believe these sections provide some useful tips on preparing for training programs. We felt that the advice in these sections would be useful to those users of this Handbook who do not have access to the EPA Manual.

Tips on Organizing Participatory Training by Jack Luskin, Sc.D., Toxics Use Reduction Institute

Participatory training is a methodology that encourages and depends on student participation through small-group activities and learner-centered participatory techniques. This "learner-centered" method is based on the assumption that people, especially adults, learn more fully by doine. than by listening passively.

In addition, the small-group problem solving structure elicits the experiences and knowledge of participants allowing them to share information with each other. Such a process generates confidence in students, helps them understand that they are capable of solving problems collectively, and thereby empowers them to take control of their lives. Small groups provide a learning environment that is based on student-to-student exchanges rather than on the traditional instructor-to-student transfer of information.

Empowerment, as used here, implies that social, political, and ideological learning has taken place that will result in conscious collective or individual actions that change the circumstances in which the individuals works or lives. What this means is that a training program is developed with the assumption that this methodology and training technique will have some impact on the actions of individuals and groups, subsequent to

5

the actual training session.

This process occurs as a result of a learning environment in which the students’ experiences, ideas, and knowledge are respected; these resources are then used as part of the teachindearning environment. In addition, the small-group activity problem-solving sessions build students’ confidence, which is constantly reinforced by the classroom atmosphere, the instructor’s technique, the quality and accessibility of the teaching materials, and the sense of collective responsibility and challenge occurring in the classroom. By being active participants in the learning process rather than passive observers, students are motivated to learn in a way that rarely occurs in the traditional classroom. As a result, students should take a more active role in their own working environment.

A learning environment should be established from the start that requires student participation and puts students at ease. Emphasis should be placed on how participants can apply their skills and knowledge to gain power and solve problems. Students know more about their own experiences than the instructors; we should therefore use this knowledge rather than be intimidated by it and let students learn from each other as well as from the trainer.

To facilitate participation, the workshop facilitator should try to avoid relying too heavily on the lecture format. We often rely on lectures either because we believe there is so much information to cover in a short time or because of unfamiliarity or discomfort with participatory group activities. However, encouraging participants to bring their ideas and experiences into the classroom helps to ensure that the students retain the concepts and ideas that are being presented and is essential to the success of participatory courses.

In keeping with the goals of this methodology each session should allow:

0 time for learning new information, time for applying new skills, and

0 time for discussing causes of problems and barriers to solving them.

‘Qpes of Learning Activities

The types of learning activities include:

0 lectures, small group exercises and report-back sessions,

0 large group discussions, hands-on exercises,

0 audio-visual presentations, and 0 evaluation sessions.

6

Lectures

The purpose of a lecture is to convey a basic body of information. It should be brief and can be combined with participatory exercises that allow students to work with and apply information provided in the presentation.

The following are some brief guidelines to help you present successful lectures:

0 keep presentations short (people can only sit and listen attentively for limited periods of time);

begin with an overview of what the lecture will cover and its practical application; end with a similar summary;

0 be explicit about why this information is useful or important;

make lectures relevant by drawing on examples from students’ experiences;

make lectures interesting by using good visual aids and never reading you1 notes; and

encourage active participation by inviting questions from the group and by posing questions that require students to apply the information being presented to their own situations.

Srliall Grow Exercises

The purpose of getting people to work together in small groups to solve problems

to increase participation, to allow people to use their experience and new information presented in the

to establish trust between and enhance the confidence of course participants,

to develop collective problem solving skills.

Small group exercises can take the following different forms:

0 filling out worksheets as a group, 0 brainstorming a list of ideas on a given topic, or 0 analyzing situations presented in case studies.

is:

course to answer questions or address complex issues,

and

These activities can be adapted for relevance to a particular group. The following are some guidelines for designing case studies and role play:

0 The situation presented should be familiar and evoke strong feelings among the students so they will want to act on it.

0 The situation should lend itself to in-depth analysis that requires students to explore underlying causes of a problem and a wide range of possible strategies for solving it. Do not try to limit or direct students’ efforts too much; let them explore how to proceed on the matter for themselves.

0 Enough information should be provided to outline the basic problems and issues to be dealt with, but it is not necessary to include every detail about a situation. (Students can improve on the scenarios, calling on their own experience to make them realistic.)

0 Make it clear what you want students to do with the role-play or case study by posing questions to be addressed or tasks to be achieved by the group. A good basic series of questions for most case studies include:

0

0

0

0

what are the problems in the situation? how do these problems compare with yours? what are the root causes of the problems? what can be done about them (what strategies are called for, what obstacles will be faced)?

Tables 2-1 and 2-2 describe how to organize role pay and case study activities in de tail.

It is important for the trainer to facilitate small group activities well. The following sections provide guidelines for administering small group activities:

Group size and selection

0 Each group should contain four to six people. Each instructor can supervise up to five groups. Each group should work in a separate area.

8

Table 2-1 TIPS ON FACILITATING ROLE PLAYING

In role playing some members act out a real-life situation in front of the group. There is no script, no set dialogue, and they make up their parts as they go along. The group then discusses the implications of the performance to the situation or problem under consideration.

Role Plavine Mav Be Used: 1. To examine a delicate problem in human relations. 2. To explore possible solutions to an emotion laden problem. 3. To provide insight into attitudes differing sharply from those of the participants.

Some Advantaees: 1. Provides a dramatic way of presenting a problem and stimulating discussion. 2. Provides clues to possible solutions and explore them without the dangers inherent in a real-life trial and error approach. 3. Gives the players a chance to assume the personality of another human being--to think and act like him or her.

Some Limitations: 1. Some people may be too self-conscious or too self-centered to act successfully in role playing. Others may be shy and fear being made "ridiculous" before the group. 2. Role playing before large audiences is less effective because of the psychological effect of the large group upon the players.

Physical Reauirements: 1. A room large enough to provide seating so that all members of the group may see the action. No stage or platform is necessary witE =-o~ps of 30 or l e x Costumes or ehborate props arc not necessdy.

Procedures: 1. The problem or situation is clearly defined by the group before the role playing begins, and the scene is set by the group leader with the assistance of the group. 2. Players should be selected just before role playing begins and not warned in advance, although a brief warm-up period may be necessary to throw off self-consciousness and get in the spirit. 3. The leader should allow the action to proceed only so long as it is contributing to understanding (usually five to ten minutes) 4. After discussion a second set of actors may be chosen and the scene replayed.

9

Table 2-2 TIPS ON FACILITATING CASE STUDY DISCUSSIONS

The case study is a detailed account of an event or a series of related events that may be presented to an audience orally, in written form, or film, or in a combination of these forms.

The Case Studv May be Used 1. To present in detail to a group a problem with which the group is concerned. 2. To present and study the solution of a problem similar to one confronting the group. 3. To teach the problem-solving process.

Some Advantaees: 1. Gives detailed accounting of the case under study. 2. Helps the learner to see various alternative solutions to the problem. 3. Helps people develop analytical and problem-solving skills.

Some Limitations: 1. Some individuals may not see the relevance of the case being studied to their own situation or the group's problem. 2. A considerable amount of time and thought is often required to develop the study. 3. Some group members are stimulated to overparticipation while other may assume a non-participatory role.

Phvsical Requirements: 1 Pbyical requirements vary with the type of prasen'ntkn. If the case is presented through dramatic acting, a stage areas is required. If visual aids are required in a presentation, the room should be suitable for this kind of presentation. If the case study is written, a large table and chairs may be all that is necessary.

Procedure: 1. Materials are put into the hands of the participants in advance if the case study is in written form and designed to be read before the workshop. 2. Appropriate techniques to use during the presentation and discussion are selected, and parts rehearsed if necessary. 3. The facilitator introduces the topic, explains what the case study is, and the responsibility of each individual. He or she then guides the discussion and other activity. 4. Group discussion may be used to carry a second part of the case study.

10

Group composition can be varied during the course of the training for the widest sharing of experience (this also prevents dominant people from establishing control over any one group). A way to break up groups and allow people to mix is to vary the size: for example, start with five groups of three each and change to three groups of five.

Recording

Tell students to select a recorder/discussion leader each time they break into a group. This helps organize the group to work efficiently and enables people to learn important communication and leadership skills. Some helpful techniques to review with students include:

Keep time. Try to prevent the group from running out of time before completing the exercise.

Keep the group focused on one question at a time. Make sure all sides are heard before moving on to the next question.

Encourage participation from everyone. If one person dominates, you can say, "thanks for your information, maybe someone else would like to add something?" Or ask someone who has been quiet if they have a different perspective or experience to relate.

Be responsible for summing up the discussion (either the consensus reached or the many sides presented). This requires you to be neutral. Even though you have your own personal opinion, your role is to facilitate group discussion.

Listen for key words and basic ideas.

0

0

Check things out: "Is this what you meant?"

Supenising

The role of the instructor during small group activities is to ensure that the groups are operating smoothly. At the start of a course, getting people talking instead of working quietly as individuals is especially important. Circulate among the groups and listen in to assess their progress. Make sure a recorder is selected and is fulfilling hisher roles; ask questions that will help them proceed if they get stuck and suggest resources they may have overlooked.

The instructor should NOT provide all the answers for the groups or distract them from working things out for themselves, It is too easy for a small group to disintegrate

11

into a questiodanswer period between the instructor and the students if the instructor hovers. There is a fine line between ignoring and intervening too much. Therefore, make your observations: intervene only when necessary; move on to the next group. If the groups are talking among themselves and making progress, leave them alone.

Report-Back Sessions

Report-back sessions that follow small group activities are more than time for summarizing and rehashing; they are separate and important activities. The effectiveness of small-group work is drastically reduced if not followed by adequate report-back Report-back sessions:

0 are not optional; always end the small groups in time to allow for ample discussion and analysis in the report-back sessions.

require as much preparation as other learning activities and need discussion questions to be planned ahead of time.

0 may begin with each group giving a summary of findings, but the bulk of time should be devoted to discussing questions that bring more depth to the issue.

In a report-back session there is time:

0 to explore what participants learned during the small group exercises,

0 to correct answers that are factually wrong,

to pursue a deeper analysis,

to challenge the students to defend their analyses and conclusions,

0 to allow groups that reached different conclusions for different reasons to learn from each other,

to have the instructor summarize and raise any important points that did not come up in small group discussions.

Sample questions for instructors to pose:

0 How did you come up with your conclusions? 0 Why did the groups come up with different conclusions?

Who benefits from the analysis you come up with? 0 What are some of the underlying reasons for the problems you have identified?

12

0 What further information would you need in order to come up with a more thorough answer to the question(s) your group addressed?

Do not be afraid to leave some questions unresolved (for example, if different students express views at odds with each other or are unconvinced by the group discussion). Some activities do not have correct answers, and sometimes participants will push to have the teacher tell what the right answer is. However, do not be afraid to take a stand on factual issues.

Laree Group Discussions

Preparing to lead an effective discussion with a large group of people takes time. The following are two important points to consider when preparing for a large group discussion:

How will you initiate the discussion? 0 How will you ask questions and elicit participation to maintain the discussion?

To initiate discussion, you can:

Use a small group exercise or other activity (film, mini-lecture) to provide a common experience that students can talk about. Plan a few specific questions that ask for opinions of the common experience. After a small group activity, people, may have expressed their opinions and should have less difficulty talking in a large group.

Use "brainstorming," a listening - exercise, where the groiq? ;s asked to generate as x x i y i k a s oil a given topic as possible. After a lisr is winpiled, it is easier to go back and get a discussion going on some of the points already raised. Table 2-3 provides some tips on leading a brainstorm discussion.

0 Use "buzz groups": briefly break into pairs or small groups to come up with ideas on an issue.

0 Ask an open-ended question of the group, or pose a controversial position to evoke a response. This technique doesn't work so well early on in the course when people are not yet used to talking together.

Once a discussion is off the ground, think about keeping it lively and on track. Table 2-4 provides some tips on leading group discussions. The following are some useful pointers for maintaining discussions:

13

~ ~~~

Table 2-3 TIPS ON FACILITATING BRAINSTORMING SESSIONS

Brainstorming is a technique where creative thinking takes precedence over the practical. The idea is to get out before the group all ideas possible, with no thought to how practical the ideas might be. The participants are urged to be as "free wheeling" and uninhibited as possible.

Brainstorming May be Used: 1. To get as many new and novel ideas as possible before the group for evaluative discussion. 2. To encourage practical-minded individuals to think beyond their day-to-day problems and to think quantitatively instead of qualitatively. 3. To move out on a problem when the more conventional techniques have failed to come up with a solution. 4. To develop creative thinking.

Some Advantages: 1. Many people are thrilled at the freedom of expression inherent in brainstorming. 2. Solutions to previously insoluble problems can be discovered. 3. All members of the group can be encouraged to participate.

Some Limitations: 1. Many individuals have difficulty getting away from practicalities. 2. Many of the suggestions made may not be worth anything. 3. In the evaluation session, it is necessary to criticize the ideas of fellow members.

phys;-,a\ K:q JiLerr ,c I Ity 1. A meeting room with a chalkboard or other surface on which the ideas produced ., can be written hurriedly and preserved for the follow-up discussion period. 2. A conference table or semicircle arrangement to expedite discussion following the brainstorming.

Procedure: 1. The facilitator explains the procedure to be used, and a recorder is selected to list the suggestions. 2. As ideas are thrown out they are recorded in public view. 3. The ideas are discussed to determine if any have practical application to the problem at hand.

14

Table 2-4 TIPS ON LEADING GROUP DISCUSSIONS

Some techniques for conducting successful discussions sessions are:

Set Ground Rules 0 Try to adhere to the amount of time allotted for each discussion 0 Encourage everyone to participate 0 Discourage interruptions to the speaker 0 Monitor the discussion and the speakers 0 End the discussion when the allotted time has passed

E- O Encourage open, relaxed communication. Keep the discussion on a positive constructive note. There are no wrong responses. If a response is not the answer you are seek, ask the group for addition answers. When the correct answer is offered, substantiate and support that answer.

Ask for Volunteers to Resuond to Ouestions 0 Don’t demand-invite and encourage participation. If necessary, call on individuals who will not be intimidated by being singled out. You may be able to encourage participation from shy or quiet individuals by engaging them in conversation during a break.

Encourage - Particiuants to be Concise and Specific 0 Ask them to provide support for their answers

Encourwe Resuonses from Personal Exoerience 0 The participants’ personal experiences are important elements of the learning process. Actual experiences help to relate the material to on-the-job applications.

Keeu the Discussion on Topic If a participant’s response is clearly off the subject under discussion, redirect the

discussion by asking a question that ties it back to the subject. Or acknowledge the point and recommend that it be brought up again at another more pertinent time in the discussion.

Summarize What Has Been Said 0 When it is time to move on to another topic or question, summarize what has been said. This provides a valuable reinforcement of key points and smooths the transition between topics.

15

0 Be prepared to keep asking questions of the group that require them to come up with ideas themselves (rather than just responding to instructor’s ideas). Questions should encourage students to draw on their experience to make or illustrate points. Calling on people to answer may be necessary to keep things moving.

0 If students direct questions to you, you can redirect them to the group. Ask if others have ideas that could address the situation.

0 Try to keep everyone involved in the discussion. Do not allow one or two people to dominate. If necessary, stop the discussion and tell the group you will call on only those who have not yet spoken. Set a good example yourselk keep your own comments brief.

0 Sometimes you will have to direct the discussion, with a class that likes to talk a lot, to make sure the section you are doing is covered thoroughly and does not expand to take time from later sections. If the discussion loses its focus, try a couple of things to regain it: for instance, by summarize points that have been made on the blackboard or break into small groups to summarize where discussion stands.

Hands-on Exercises

The purpose of hands-on exercises is to:

enable participants to try out equipment and gear,

0 Dxak tip i & i ? . k q &;is d l i ~ y arc not GI! s!tti;ig ac tiiLics doing h ; , k work; people can get up and move around, and

0 allow people to learn by doing.

The following are some useful pointers on running hands-on exercises:

0 As a rule, more instructors are needed to run hands-on exercises than other activities. You need a lead trainer and assistants to provide one-on-one help to students.

0 Often classes will have participants with a range of prior experience. Trainers should try to plan for this by pairing buddies, splitting groups, or having additional instructors available to help some people.

16

Audio-visual Presentations

A variety of audio-visual materials can be used in the course to supplement other teaching methods. The more different ways that information is provided (graphics, audio, print) the more likely people are to retain it.

Blackboards or flipcharts can be used for recording ideas generated by the group. Having one student record main points while you lead a discussion makes it easier for people to remember what was last said, introduces students to a "teaching role" and reinforces the belief that solutions have to start with them.

Flipcharts also can be prepared ahead of time to accompany a presentation; the visual outline helps students listen effectively.

0 Overhead transparencies can also be prepared to accompany a lecture. However, using overhead transparencies generally means turning off the lights and reducing discussion, so many trainers prefer to reuse outlines and pictures drawn on flipcharts.

Slides and videos can present information in an entertaining way. Used sparingly, they can stimulate large group discussions.

0

Videos should always be short (less than 30 minutes).

Make sure you prescreen the video to check that its point of view ties in with what you are teaching.

Avoid snowing videob ri$t d t c r imchl

Evaluation

The final learner-centered teaching technique is the evaluation session. A section at the end of this chapter provides some tips on evaluation techniques. Evaluation is important for:

0 ensuring that students' needs are being met by the training; it allows the instructor to make appropriate adjustments of course content to respond to unmet needs.

0 helping students to become more effective trainers by having them think about what they would do the same or do differently in teaching the course.

17

0 helping instructors to become more effective trainers; although it can be difficult to hear criticisms or suggestions, instructors can always improve their ability to provide future training by getting feedback from the group.

Tips on Preparing for Training

If you have ever organized a workshop or seminar, you know that keeping yourself on a schedule is critical. There are hundreds of details to remember --- contacting speakers, securing a facility, copying handouts, sending out announcement, etc. To help you keep track of all of these details and be prepared for the seminar, we provide a sample seminar task checklist and some tips on preparing your materials and yourself for the workshop.

Table 2-5 provides a sample checklist for you to use in preparing your workshop. We suggest that you modify this sample checklist for your own program. There may be details that you need to add or delete from this checklist, but it covers many of the tasks that need to be completed in organizing any seminar.

The following sections provide useful advice on preparing your materials, preparing your space and preparing yourself for the workshop.

Preparing Your Materials by Mary Dingee Fillmore reprinted from the EPA Insrmctor Training Workshop Manual

When you prepare handouts, either to include in advance materials. or to give people aficr your couibe is finished, think first about your purpose.

Do you want to remind people of what you said? 0 Do you want to tantalize them with what you are about to say? 0 Do you want to give them clear instructions about an exercise or case study? 0 Do you want them to read the material later as an amplification of what they learned? 0 Do you want them to find more detail about what they already know, or just reinforce it? 0 Will the materials be used for reference? 0 Would you like participants to distribute the materials to others?

There will nearly always be some people in a course who want to pursue the subject further, and you may want to provide them with a bibliography or list of groups and people they might consult. In designing the materials, try to put yourself in the position of the trainee. What would you want to know? How much would you already

18

Table 2-5

SEMINAR TASK CHECKLIST

Seminar

Instructor/Presen ter

Date of first session

Task

Number of Weeks To Be Prior to Person Done Date Program Responsible B y Done

Outside SpeakerslPresenters

Determine budget for speakers

Identify available speakers

Review credentials/references

Select & prioritize speakers

Invite speakers/presenters

Develop speaker/presenter

Obtain signed speaker contract

Obtain biographical!resum6 data from speakers & presenccrs

Obtain approval of brochure & materials, including biographic information, from speakers & presenters

Communicate logistics & proce- dures to speakers/presenters

Provide speakers with presenta- tion & materials development guidelines

Obtain materials for reproduction from speakers/presenters

Confirm with speakers/presenters

Seminar Facilities & Hospitality

Select program location(s)

contract

Reprinted ith permission from How to Develop and Promote Successful Seminars and Workshops by Howard Shenson, John Wiley & Sons, Inc. 1990.

I n

Table 2-5 (continued)

Identify available facilities & costs Rate adequacy of facilities -- Select/Book facilities -- Obtain guest room block & rates

--

-- Obtain facility contract/

Determine refreshment

Provide facility with require-

Confirm facility arrangements/

confirmation -- requirements --

ments --

provide final counts/guarantees -- Seminar/Workshop Materials

Determine information

Determine information passing

Determine exercise/skills practi

Design participant materials

requirements

requirements

requirements

Design trainer/presenter materials -- '3emmi.ie publishei nratcr d s

requirements -- Pilot-test materials -- Select packaging -- Order packaging -- Schedule printing & binding

services -- Prepare camera-ready art

Proof materials Produce materials -- Produce visuals -- Inspect finished materials --

seminar/workshop site -- Deliver completed materials to

20

Table 2-5 (continued)

Confirm amval of materials

Promotion of Program

at site --

Determine promotional objectives -- Select promotional strategies

Establish promotional schedule Develop rough promotional

materials

Test promotional materials for readability

Test promotional materials for validity

Direct Mail

Identify available mailing lists & costs

Determine size of mailing

Select mailing lists

Design promotional brochure Order mailing lists Select/schedule printer/mailer

Develop brochure camera-

Check mailing lists for accuracy

Print brochure Mail brochure

Space Advertising Determine available publica-

tions & costs Select publications Book advertising space Design advertisements

Produce camera-ready art Deliver camera-ready art to

ready art

publication

21

Table 2-5 (continued)

Public Relations

Identify those who will help to promote your program & the advance notice they need --

tionall publicity assistance --

requirements -- Develop publicity materials -- Print publicity materials -- Deliver publicity materials --

Prepare mailing list for those who will be providing promo-

Determine information

Follow-up Promotions

Determine follow-up marketing strategies --

Implement follow-up strategies -- Participant Registration

Develop registration policies & procedures --

Design registration forms -- P I : ~ : x g h z t . 0 7 forms --- -- Confirm participant registration -- Set go/no go date and number

Remind participant of seminar -- Prepare seminar rosters -- Develop participant evaluation

forms -- Print evaluation forms --

--

Type name badges --

assistance & equipment -- Arrange for on-site clerical

L L

be likely to know? How much background would you need? If possible, talk to some people like those who will be participating and get their opinions.

Once you have drafted the materials, get other people’s comments about them- particularly those who know little or nothing about the subject. They are most likely to pick up on anything obscure or inconsistent, unless you are dealing with a highly technical areas. Expect that you will need to revise your draft at least once.

In considering audiovisual aids, be sure that they are merely aids, rather than ends in themselves. An overhead projector, showing the outline of what you are doing, can be useful in an extremely large group. But it means a darker room where people are much more likely to nod off. If your purpose is to maintain a good connection with the group, any visual aids is likely to dilute your contact with them. On the other hand, a video or film can be most helpful in changing pace, especially in a course that lasts several days. If you decide to use any audiovisual aids, know the equipment backwards and forwards, or who the technician will be, and have phone numbers you can call if something goes wrong.

Preparing Your Space by Mary Dingee Fillmore reprinted from the EPA Instructor Training Workshops Manual

You will probably be more comfortable and effective if you can select the room and arrange the seating to suit the group. Be sure that you see the space in advance and have a clear picture in mind of how you will see it. Know who has the key to the room, if it will not be open, and specify the equipment you will need:

0 Fiqchdr t Papzripens for participants Fresh markers 0 AV equipment Paper for flipchart 0 Tables or not Podium or table for notes 0 Water Name tags 0 Access to photocopy machine Pointers Tape or substitute

You may have your own peculiarities, but this is a good beginning list. Consider:

0 Space

Do you have a comfortable space for the number of participants? The interaction will be very different if a few people are swallowed up in a cavernous space, or if they are crammed together. If you feel that the space is too big, use room dividers, if available, or keep the lights out in one end of the room. See if there are visual tricks you can play to make it seem smaller. On the other hand, if the room is tiny, clear

everything out of it except the flipchart, a table for notes, and the chairs. If possible, leave the door open. Plan in advance for breakout space, if you need it.

Chairs

If you have a choice, be sure the chairs are the most comfortable available, no matter how they look. The chairs will have more to do with how well people listen than almost anything else you do. Arrange them in a way that suits your purpose well. If you want the participants to talk with each other and connect well, give them an arrangement like a circle that will help them see and talk with each other. If you want all of their attention on you and the flipchart, try a more conventional configuration. You may also want to vary the seating, especially if you are working with them more than one day,

0 Tables

If participants have to take extensive notes, tables can make them less physically tired and enable them to spread out comfortably. The price is that tables divide people from each other and can get in the way if you want the group to break down into smaller units than pairs.

Clocks

Try to set us the room so you can see the clock but the participants can’t. If there is no clock, bring some timepiece of your own with an analog dial. You can’t glance at a digital display as quickly as you can an analog display.

0 Orientation

If the mom ha5 a ~;urgc:ous VLW O U L the window, set up thc L J O ~ so quu :~?UI, a. it, rather than the participants. They will have natural light coming in over their shoulders, and will be focused on you and one another, rather than the beauties of the great outdoors. If you have a choice between a blank wall and one that is cluttered up with doors and equipment, choose the less cluttered one. The less people have to be distracted by accoutrements, the better.

0 AV Equipment

If you are using AV equipment, be sure that it is installed and in working order. Run through what you will have to do with it, if there is no technician, and double check the phone numbers for people who can repair it, if something does go wrong.

Flipchart

Be sure that there is enough paper to meet your requirements, and then double

24

that amount. Markers are usually old, so be sure you get some fresh ones. Prepare all the flipcharts you want to have ready in advance. If some of them will follow group discussions, when you expect to use up blank pages, consider putting the prepared flipcharts at the back of the pad, and tabbing them with paper and tape so a number or word indicates where each one is, or using paper clips for the same purpose. The flipchart should be used not only to keep the group clear about what will come next, but also to clarify and order their discussion so they can see how they are related to the course topics.

Be in the training room at least an hour before your session begins. Try to make the final arrangements and head problems off at the pass. A few participants will be there 15 minutes early, and you want to be ready when they come.

Preparing Yourself by Mary Dingee Fillmore reprinted from the EPA Instructor Training Workshop Manual

1. Recognize and build on your strengths as a trainer.

Ask others what you do well, and use your own good judgement. If you have a strong voice, be aware of how you use it. If you know the subject backwards and forwards, use that as a confidence builder. Write down some of the things you know and do well on index cards as reminders for the time when anxiety is building. Figure out how you can strengthen your strong suits still further--through practice or amplification, using them in new settings or whenever.

2. Identi@ and erode vaur fears and mxieties

i

Be very exact about what is bothering you. When you fantasize a disastrous scene in the training room, what is it? Is it yourself drying up, or getting no response from the group? Is it being attacked by a hostile participant? Be as specific as possible, and work with others on what you would actively do to change the situation, if it arose. Role play if you need to, in order to give yourself more confidence.

3. Diagnose and practice improving areas in which you are weak.

Ask friends and observers whether you have verbal or non-verbal mannerisms, which could distract an audience. Most of us say "Um" or "Uh," put questions at the end of our sentences when they are not appropriate, and have irritating fidgety or other non- verbal tics. Watching yourself in a mirror, or listening to yourself on a tape, you will soon find them just as irritating as others do, and will be more conscious of them. Think about what you will do instead. In the case of verbal mannerisms, reminding yourself before you begin to speak that you do have something important to say, and can say it

clearly, may help. Non-verbal mannerisms usually have to be extirpated by replacing them with something eke. If you play with a pencil, be aware of arranging your hands differently and perhaps keeping pencils away from the training room altogether.

4. Rehearse if front of a mirror, with friends, and especially with peers who are t’ying to learn the same skills.

Ask an ally to attend your training session, so you can get feedback from a supportive peer. Tape what you way and listen to yourself. See if it makes sense, and how you sound. Get as many opinions of your performance as possible.

5. Clear away false obstacles.

Don’t wreck your composure by having any concems that are unnecessary. Try your clothes on a few days before the event and make sure you didn’t spot that blouse or those trousers. Think about transportation in advance. What time will you have to leave home, and how to get where you’re going in good time? Preparing your material well in advance, and knowing it thoroughly, can alleviate some (although probably not all!) of the anxiety every novice feels.

6. Make sensible final preparations.

Get enough sleep the night before the session. Prepare flipcharts and other materials in advance, so you don’t have to w o w about them. Review your notes only as much as necessary; don’t obsess. By the time the day itself comes, you know what you are going to know, and the rest has to wait. Remind yourself of your strengths and what you are trying to do. Remember why you wanted to teach the course in the first place. Finally. put it in perspective, none of the participants will die if the day ckxsn’t go perfcctiy; and neither will you.

Tips on Evaluating Training Reprinted with permission from How to Conduct naining Seminars, by Lawrence Munson, McGraw-Hill, 1992.

The most generally used postseminar evaluation takes place right in the seminar room. The participants are asked to fill out a form to give their opinions on the quality of the presentation and subject matter and the relevance of their new learning to their job responsibilities. There are differences of opinion on the reliability of these judgments. The main criticism voiced is that the participants may be unduly influenced by the pleasure of the experience rather than its value. This criticism is especially directed at evaluations made in the glow of the seminar leader’s last impassioned summary.

26

Why to Do It

Despite these criticisms, participant evaluations can be helpful, if interpreted with good judgment in light of all the surrounding circumstances. Even if the performance of the presenter produces an upward bias, you still get a picture of the strongest and weakest portions of the programs. The evaluations can be heIpful to the presenter in improving future seminars. In some instances, the comments of participants can result in a redesign of the seminar.

Furthermore, patterns may emerge from one group to the next, if the seminar is a continuing one. For example, if the visual aids are consistently rated lower than other aspects of the seminar, you can reasonably conclude there is the need for improvement in the visuals. If your favorite cost-effective facility is always rated on the low side, you might want to get another place for your seminar. If a change in location is not practical, you might find it worthwhile for the presenter to mention the favorable economics of the site at an early point in the seminar.

In this democratic country, "the voice of the people" has an important value. If some participant has a very strong reaction, either positive or negative, some tension can be created if there is no outlet through which to express it.

How to Do It

In using participant evaluations, there are some guidelines that can be developed from accumulated experience. You may not agree with all of them, but perhaps they will start you thinking about the subject.

The first suggestion is to develop a standard form that is partly structured and partly unstructured. The structure makes it easy to make statistical summaries. The unstructured portion encourages creative contributions. We favor a rather simple form that focuses separately on the presentation, the subject matter, and the overall impact of the seminar, while providing a few "open end" questions. Figures 2-1 - 2-5 provide some examples of evaluation forms. You will note that some of these forms feature a five- point scale to provide a range of scoring options but without too much definition on the precise meaning of each. Our own experience would indicate that successful seminars will be at least 80 percent of the responses in the 4 and 5 categories.

Get Immediate Evaluations

Get the evaluations filled out before the participants leave the seminar room, even at the risk of a positive bias. Why? A simple answer: to get 100 percent response. If you try to get the responses at a later date, you may get only 60 to 70 percent and

21

cannot be sure how truly representative they are. Members of the "silent majority" may not be fully represented. It takes time and effort to fill out the form - time and effort more likely to be expended by those with something particular they want to say, often negative.

Encouraee Siened Forms

Try to get the participants to sign their evaluations. But do it gently. You don't want to force them, if they prefer to remain anonymous. The reason for getting their signatures is to help in reviewing the evaluations. If, for example, you know that some individual participant was forced to go to the seminar against his or her will, you might expect a less favorable evaluation. Furthermore, you may value the judgment of some individuals more than others.

Use With Care

Participant evaluations are valuable, but after all, you are the professional in the training business. It is your professional judgment that should have the greatest weight.

Let me offer an illustration from recent experience. A management seminar specially designed for higher management levels had been getting excellent ratings from three prior groups when it suddenly was rated just satisfactory with a few strongly negative votes. Was it the presenter who had gone stale? Was it due to unusually poor timing (the participants were constantly on the telephone with their subordinates to finalize strategic plans that were due on the day after the seminar)? Was it the makeup of the group (there were two "angry young men" represented)? It was extraordinarily difficult to sort out these possibilities. Some changes were made in the seminar to step up the pace and to provide more team exercise- on "real world" problems. With tlvse changes, and a inore sensitive eye on ; k h g , the training director was please to see the "excellent" ratings resumed. If he had taken the evaluations at face value, he might have abandoned a seminar that had been having a positive impact with other groups.

28

Figure 2-1

LOUIS ALLEN ASSOCIATES, INC. CONFIDENTIAL PARTICIPANT EVALUATION

Rog" Presen!er Dates atv Fubllc InCompony

Presentation (Clrcle your answer)

subject molter? 1. How would you dexrlbe the presenter3 knowledge of the Umlted Extensive

1 2 3 4 5

2. In general, how did the presenter treat dlferlng vlewpolnts? Wlth Acknowledged Antagonlm them

1 2 3 4 5

3. How dld you find the presenter's siyle of dellvev Unlnterestlng Dpamlc I 2 3 4 5

4. Were the concepts, principles and technlques explolned In Seldom Consistently 1 2 3 4 5 a n understandable manner?

5. Dld the mesenter Invlte and encouraae lndlvlduol mrtlclw- Seldom ConslStentlV I

1 2 3 4 5 tion?

6. DM the presenter malntaln control of the dlxusslon and work Seldom Conslstently QrOUPS? 1 2 3 4 5

7. Old tt\e presenter use visual aids for relnforcement of dlscus- Seldom Consistently 1 2 3 4 5 slon polnts?

Reprinted with permission from How to Conduct Training Seminars by Lawrence Munson, McGraw Hill, Inc., 1992.

Figure 2-1 . .n t inued)

8. Dld the presenter hold your Interest? Seldom Consistently

1 2 3 4 5

Progmm Content

stand It? Understand Understand 9. Was the program content organized so that you coulu under- DlfRcult to Easy to

1 2 3 4 5

IO. Dld you find the workbook clearly outlined the content of Not very clear Very clear

1 2 3 4 5 the program?

11. How often could you relate the sltuatlon In the case studles Seldom Conslstently

1 2 3 4 5 to your own job?

12. Did you find prtlclpotlon In the appllcatlon exercises benefi- Seldom Conslstently

1 2 3 4 5 clal?

13. How useful did you find the visual alds used? (slides, Vu- Of no use very Useful

graphs, etc.) 1 2 3 4 5

Program Overall

14. Do you thlnk that you wlll be able to apply what yol; ieomed Seldom Conslsten tly

1 2 3 4 5 In this progmm to your job sltuatlon?

15. Did you feel challenged by the content and the erercises? Seldom Consistently

1 2 3 4 5

Very relevant 16. To whot d e r e e dld you feel that the content and exerclses Not relevant

1 2 3 4 5 were relevant to your job? Louis A. Allen Associates, Inc.: Confidential Participant Evaluation.

30

F i g u r e 2-1 (continued)

LOUIS ALLEN ASSOCIATES, INC. CONFIDENTIAL PARTICIPANT EVALUATION Roorom Presenter Dotes

FUbllC - InCompany 17. How w l d you rate the taclllty In whlch the program w a s Poor Exceptlonal

1 2 3 4 5 hew

18. Flease " e n t on any questlon (Presentatlon. Projram Content or Program Overall) to which you gave a.rating of 1 or 5.

Comments

31

iYgure 2-1 (continued)

19. Do you have any additional comments regarding program of pfesentatlon strengths and weaknesses?

~~

Portkipant Profile. Your answers to the following quastlons are for our research purposes only. You may sign or not, as you wish.

A. T y p e of business or enterprise

B. Your posltlon title

D. Mucutlonot level Slgnature

C. Years in management

~ o r m NO. 640.1 ( i i a i i

(Continued) Louis A. Allen Associates, Inc.: ConZdential Participant EvaluaUon.

32

Figure 2-2

EVALUATION

Pollution Prevention Training Program July 11 and 12, 1991

We would appreciate your honest evaluation of the training program so that we can incorporate your comments before the next training session. Please complete the following.

Bureau: Air Management Water Management Waste Management

Role: Inspector Permit Writer Enforcement Staff Other

Please indicate role if other:

1. What is your overall impression of the information presented at this workshop?

Excellent Very Good Good Fair 5 . 4 3 2

Poor 1

Please comment:

2 . How useful do think this information will be to you in your role as an inspector/permit writer/enforcement staff?

Excellent Very Good Good Fair Poor 5 4 3 2 1

Please comment:

3 . What part of the training did you find most interesting/useful?

Communication Exercise Case Study Mock Industrial Processes and Discussion Small Group Discussion: Barriers Small Group Discussion: Compliance Orders

Please comment:

4 . What topics are you interested in for future training/workshops related to pollution prevention?

33

Figure 2-2 (continued)

5 . Do you think that it is likely that the relationship between you and the facilities you work with will be different when you are emphasizing pollution prevention alternatives in addition to your traditional regulatory compliance emphasis?

If you answered "Yes", please explain briefly:

If you answered "No", please explain why not:

6 . Please describe the ways in which you have already been working with industry to implement pollution prevention.

7 . Do you think that it will be important to have ongoing communication with staff from other bureaus at DEP regarding efforts to institute pollution prevention practices?

If you answered "Yes", please explain briefly:

If you answered "NO", please explain why not:

8 . In vour op ip ion , is there an inherent cmfli.ct far the inspmtor/permit WiitrrJenforcement staff in his or her dual role as regulator/technical assistance provider?

If you answered "Yes", please explain briefly:

If you answered "No", please explain why not:

9 . General comments, questions or problems.

Please return form to the registration table before you -leave. Thank you.

34

Figure 2-3

EPA Institute Instructor Training Course Participant Wookbook 4 4

,'i

Course Evaluation

By completing this form, you will be helping me evaluate and plan for future offerings of this program. If you need additional space for comments, please use the back of the page.

1. In your opinion, how successful was the course overall?

Extremely Moderately Not at all

7 6 5 4 3 2 1

2. Rate the overall performance of the instructor.

Excellent Moderate Not Good

7 6 5 4 3 2 1

3. What recommendations would you like to make with regard to the instructor/ instructions?

4. h l a t criiicisills, if any, regarding program content, materials, or process did you hear during the course?

5. Which topics, exercises, or presentations did you feel were the most successful?

6 . Based on this specific course experience, are there any improvements in content, exercises, or activities that you might suggest?

Please make any further comments about this course and the instructor on the reverse of this form. .

35

Figure 2-3 (continued)

EPA Institute Instructor Training Course Participant Wookbook

Additional Comments

36

Figure 2-4

POLLUTION PREVENTION FOR THE METAL FINISHERS INDUSTRY NOVEMBER 17, 1992

EVALUATION

Please take the time to answer the following questions. Your response will help us in planning future events.

1) Which title most accurately describes your position?

- Production Manager - Manufacturing Engineer - Government Representative - Other

- Plant Manager - Environmental Engineer

2) Please rate the topics presented today on content and presentation

l=Very Useful 2=Useful 3=Not Useful

Content Presentation a) Regulation Update 1 2 3 1 2 3 b) Coolant Management 1 2 3 1 2 3 c) Coolant Applications 1 2 3 1 2 3 d) Flood Coolant Substitute 1 2 3 1 2 3 e) Oil Additives and Recycling 1 2 3 1 2 3

3) Would you be interested in expanding on Pollution Prevention and the metal finishink indut iy?

- Very Interested - Interested - Not Interested

’ h

4) Additional Comments:

37

Figure 2-5

COURSE EVALUATION FORM Date: Location : Section:

Please help evahate this workshop In order to Improve Its content.

1. Were the contents of this workshop beneficial to you?

2. Describe how this course did or did not meet your needs and expectations.

3.

Strengths: Weaknesses:

Please evaluate the quality of the teaching, listing briefly both strengths and weaknesses:

4. How could this workshop be improved to meet your needs better?

6. COMMENTS:

38

Chapter 3

POLLUTION PREVENTION TRAINING FOR MANUFACTURERS, COMMERCIAL SERVICES &

EDUCATIONAL INSTITUTIONS

Introduction

States and EPA in the Northeast have been conducting workshops and training seminars on pollution prevention for industry, commercial services, and educational institutions during the past five years. The audiences for these sessions range from representatives of a wide variety of industries to representatives of companies with specific industrial processes. An example of a general industry session was a two-day conference on pollution prevention for all manufacturers in Rhode Island. An example of a process specific seminar was a workshop in Massachusetts on metal lubricants. The states and EPA have organized other types of sessions that are targeted toward a specific industrial sector covering more than one manufacturing process. The following chapter summarizes these activities as reported by the Northeast states and EPA in a survey conducted by NEWMOA in the fall of 1992.

The first section of this chapter presents an paper by Terry Foecke and Joel Schurke from the Waste Reduction Institute for Training and Applications Research (WRITAR) on developing pollution prevention strategies for training business and industry. This paper presents useful information on evaluating and analyzing your audience, developing an agenda, challenges that trainers may face, evaluation and a sample agenda.

The second section of this chapter focuses on general training programs designed for multiple industry, commercial sem'ces and educational institution audiences by the states and EPA This section is followed by summaries of specific training programs for the following: textile manufacturers; fabricated metal products and machinery manufacturers; electronic equipment and computer manufacturers; dry cleaners; photo processors; auto body, repair, and maintenance services; educational institutions; and other manufacturers and commercial services.

At the beginning of each industry training section, we present a table summarizing the training programs offered by the states, EPA or NEWMOA for each type of industrial, commercial firm or educational institution. The tables are designed to provide a quick reference for users to identify which state or EPA program has offered the training seminar and to find out who to contact for additional information. The tables are followed by sample agendas, case studies, and training exercises that states and EPA have used in training programs. Many of the sample case studies and exercises presented

39

in this chapter could be adapted for use in training of state and federal government officials. Similarly many of the case studies and exercises presented in Chapter 4 for use in training public agency staff could be adapted for use in training industry representatives. We urge users of this manual to be creative in adapting the available case studies for use with various audiences.

As stated above, this chapter presents a sampling of the available case studies for use in PP training with industxy, commercial services and education institutions. Chapter 5 includes a list of books and reports that contain numerous case studies that PP trainers can use in their training activities with industry. We urge you to consult these books when you are looking for case studies to use in your workshops.

When we compiled the material for this Handbook, we received a large amount of information from the Northeast states and E P A We could not include everything that we received. We tried to select those materials that we felt would be useful to Handbook users trying to organize training sessions with information on who to contact for additional information. For example, we did not include fact sheets and handouts that states and EPA have distributed at training sessions because this would be a huge amount of material. We tried to sample agendas and case study materials that represent a cross section of the training programs that Northeast states and EPA have offered. Many of the tables in this chapter have a large number of blank spaces, and we hope to add more material to the tables and the materials attached to the tables as the Northeast states and EPA develop more pollution prevention training workshops for industrial, commercial services and educational institutions in the Northeast. We also hope to add other sectors to the Handbook in future editions as states and EPA develop training programs for them.

In addition, there are numerous PP workshops takicg p!xe across the country. In ILL H;-d',cok, \.e Iiav'i i~!ii:Icd rraiimg I,,&ilals dcvekb CJ b j ;:IC I\;b!:reast sXes and EPA programs. We urge PP trainers to contact state and EPA programs in other parts of the country to find out what workshops they have organized. For information on state PP programs outside of the Northeast, we suggest you contact the Northeast States Pollution Prevention Clearinghouse at N E W O A The Clearinghouse has files on state programs around the country, including newsletters and announcements of activities of those programs.

Finally, the tables in this chapter list state and federal and other programs that have organized pollution prevention training in the Northeast. The Table identified the primary organizer/s or sponsor/s of the workshop or conference. In many cases these programs were sponsored by multiple organizations. In the interests of space, we did not list all of the cosponsors of these activities. We hope this will not present a problem for the organizers of these activities. The following is a key to the abbreviations for the names of the state and federal programs listed in the Tables:

0 (3 DEP -- Connecticut Department of Environmental Protection ConnTAP -- Connecticut Technical Assistance Program ME DEP -- Maine Department of Environmental Protection

0 Univ. of ME -- University of Maine 0 MA OTA -- Massachusetts Office of Technical Assistance

MA TURI -- Massachusetts Toxics Use Reduction Institute 0 MA DEP -- Massachusetts Department of Environmental Protection 0 NH DES -- New Hampshire Department of Environmental Services 0 NJ DEPE -- New Jersey Department of Environmental Protection and Energy 0 NJ TAP -- New Jersey Technical Assistance Program

NYS DEC -- New York State Department of Environmental Conservation Erie County PP -- Erie County, Office of Pollution Prevention

0 RI DEM OEC -- Rhode Island Department of Environmental Management, Office of Environmental Coordination 0 VT DEC -- Vermont Department of Environmental Conservation 0 EPA Region I -- US. EPA Region I

EPA Region I1 -- US. EPA Region I1 0 NEWMOA -- Northeast Waste Management Officials’ Association

41

Pollution Prevention Training Strategies

for Business and Industry

Terry Foecke Joel Schurke

Waste Reduction Institute for

Training and Applications Research, Inc. (WRITAR)

paper presented to

Environmental Solutions Expo and Conference Minneapolis, MN

September 15-17, 1992

42

Pollution Prevention Training Strategies

This paper will consider the following components of pollution prevention training development and delivery, based on experience and the literature:

Evaluation Audience analysis Agenda development - Challenges Evaluation A Sample Agenda

The most important point about evz ration c x)ollution prevention training is : need to establish at least two sorts of baselines: one concerning attendees‘ awareness and/or skills as regards pollution prevention, and another conceming actual progress in implementing pollution prevention opportunities and seeing a decrease in substance use anam waste generation. A fial baseline that might be considered for more mature programs would be one that tracked that scale of integration of pollution prevention principles with all standard business practices withii the organization (similar to the goals for a fully mature quality program).

Audience A nalvsis

There are at least four major audiences usually considered during audience analysis: senior management, other management, technical staff (design, engineering, and usually including environmental), and line and operations and staff. In practice, these audiences are often mixed, but audiences should normally be mixed only to achieve specified mining goals. For example, since pollution prevention activities are often perceived to be added duties, management would be asked to attend part of the training for operations employees, in order that questions may be asked and fears allayed immediately, thus clearing the way for substantive discussions.

To date, the most important information to be derived from audience analysis will concern attitude towards the environment/pollution prevention and perceived barriers to implementation. Gathering of case information about past successes or efforts at this time for use during mining can also be useful. .

4 3

As in any training or education, knowing the audience is important in the design and eventual success of a pollution prevention training effort. Some basic issues to consider about attendees are:

4 Function 4 Position 4 Experience 4 Motivation 4 Needs An attendee's function (e.g., process operator, plant manager, engineer) can influence

selection of specific agenda items and give clues to the approach needed. For example, an operator may very well be more familiar with specific parts of industrial facilities, a plant manager with overall function of facilities. Knowing the attendees' functions appropriate selection of materjals, as well as adjustment of the level of detail of those materials. In pollution prevention training, an operator is more likely to be concerned with the h, a manager with the &

The position an attendee holds is important for broad agenda decisions. The type of information and style of presentation is different for an audience of managers than that best suited for an audience of staff or operators. At the management level, the concem is that managers understand the commitment required of the organization, and the employees of that organization, in order to participate in pollution prevention. For managers, recognition of environmental concems is a key component of training, along with stressing the need to include all levels of the corporation in change (much along the lines of quality/qua!cty imp-ovement trahiqg). A distinction csn 31sn he made between senior management and middle management in many organizations, a distinction that especially affects the length of the training and the level of detail. Other staff may also require at least some orientation to pollution prevention, since they may be the primary agents of its implementation. Even solid waste recycling waste programs that focus on aluminum soft drink cans and office paper can be important levers for extensive awareness building.

I

Experience of the attendees in pollution prevention, or even sometimes in environmental issues or indusmal processes, will drive the choice of technical content areas, the amount of time devoted to communications, and perhaps the amount of time required for the training to be effective.

What the attendees bring to the training as motivation affects the delivery of the material, and the amount of time spent developing the come. The most basic point to remember is that attendees who are told to be there, or who feel forced to attend, will not be "good" attendees, in the

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sense of being willing to engage fully in discussions and entertain creative solutions, key elements in pollution prevention training.

All these factors are analyzed to determine the training needs of particular group of attendees. First, the goals of the training are determined. Then, agenda components are chosen and developed, taking into consideration the above factors. Finally, trainers are selected and the delivery and site details completed An important point to remember is that the needs that a group of attendees can perceive for themselves are not completely accurate. This is me of any training focused mostly on change, but especially true for training in pollution prevention. It may be helpful to think of information gathered directly from attendees not as needs but as "wants", subject to revision and expansion.

A particular problem with all kinds of mining is that nearly always the attendees will be a mixed audience, containing members with different functions, motivations and needs, and very possibly also some observers who will stop in and out just to "see what's going on." There is no way to serve all members of a mixed audience. All that can be done is to choose a "core" audience and make decisions related to the needs of that group.

--Doing audience analysis

The steps to follow in actually describing a group of training attendees could go something Iikc this:

Determine overall training program Sometimes no training "program" exists, but some sense of the framework for any particular training helps in agenda decisions. For example, it is easier to justify large upfront development costs for materials like resource packets if the progam calls for later mining of other groups.

--Long-term or one-shot? A long-term commitment to pollution prevention ususally means that some attention needs to be paid to laying a good foundation for organizational change, for example by training managers first along with a key group like inspectors or environmental coordmators. A one-shot training will be more concerned with reaching a group with high topical interest, e.g., facilities with high air releases of solvents or enforcement staff charged with implementing a new directive to include pollution prevention conditions in settlements.

--Multiple audiences? In addition to the considerations for the "long-term v. one-shot'' question, other questions to ask are whether any particular training is intended to be given over a period of time, whether new audiences may be sought for the training (as can be the case with orientation training) and whether completely new audiences and topics will ever be considered.

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--Funding available Later in this chapter a case history is presented of part of a training that had a $30,000 budget--more than many programs will ever have for pollution prevention training. The amount of money available will affect almost every decision, from who the instructors will be to whether refreshments are provided to how much time is spent developing the agenda and resources. Inexpensive (less than $500) training can be done, especially as more "canned" materials become available, but only limited customizing will be possible.

--Time frames Does all mining have to be completed in a certain period, for budgetary or project-related reasons? Is there latitude to Create follow-up or refresher training at a later date? How much time can attendees reasonably be expected to devote to training and practice? These answers will determine how much time can be devoted to audience analysis and training development, and also determine the design of the training. For example, if only eight hours is available for presentation, after breaks and lunch there are only five-and-a-half to six hours available for delivery of the training materials. Furthermore, if the training must be presented in 90 days, this allows very little time for development, meaning that the search for existing materials will be very important. Another rule of thumb is that a minimum of 30 days is required for attendees to get a training date on their calendars, and 60 days is far more realistic. In addition, an agenda must be developed before you can seek attendees.

--Significant baniers Barriers are part of what must be considered in designing training, and baniers are in part what trainees are trained to overcome. Some common baniers encountered for pollution prevention training are: Lack of management commitment. Lack of resources. Lack of motivation on the part of trainees. Few materials available. Few experienced, local trainers available. Topic seen as overwhelmingly large and complex. Regulations are media- specific, while pollution prevention focuses on cross-media transfers and cross-functional activities.

--S,gnificant opportunities Opportunities must also be considered as part of mining design, and may be a large part of what makes a training successful. Some common opportunities encountered in pollution prevention training: Management sees it as an opportunity to increase efficiency. Trainees see it as an opportunity to learn something new and "hot". All parties see it as an opportunity to do something good for the world. High public awareness of the issue. Builds heavily on issues such as quality management, communications and team-building that are already being discussed and implemented in many organizations.

4 Determine draft training goals Goals serve to give attendees a sense of the content of the training, as well as what might be expected of them after the training. Goals also serve to focus training design and delivery discussions. Progress in meeting goals is often difficult to measure; measurement should be attempted at a finer level of detail, that of objectives. For example, a training goal might be that attendees understand pollution prevention. A somewhat related training objective might be that attendees would be able to examine a list of activities, ask some questions, and be able to determine which were likely to be pollution prevention with 90% accuracy.

46

The following list of goals are drawn from actual example trainings:

--Build awareness Attendees could be made aware of pollution prevention as a possible course of action; the possibility for incorporating pollution prevention into their own activties; the level of activity already occumng in the field of pollution prevention.

--Build competence Skills can be gained in the delivery of pollution prevention training; communicating in or about unfamiliar situations; gathering and evaluating information; thinking creatively.

--Build teams Team-building is already a common focus in many organizations, especially when change is the focus. Pollution prevention cannot be fully implemented without a team effort, so any practice in putting together and working on teams concemed with pollution preevntion activities is very useful.

--Change jobs Often attendees are asked to consider how they might do their jobs differently in order to promote pollution prevention

--Change an organization A basic premise of pollution prevention is that it is different from pollution control as an approach to environmental management. Therefore it is critical that an attendee's organization changer in order to a) promote pollution prevention, b) implement pollution prevention, or c) both.

d Determine potential attendees Sometimes the attendecs are determined fairly early in the life of a training project, e.g., "We want to train all our operators to spot pollution prevention opportunities." But often the attendee list needs to be narrowed and focused considerably before an agenda can be developed. One important consideration is that audiences are rarely composed exclusively of the target attendees. Observers ~ n d other intewtr,(! yrties may wish to attcnd all or paTt cf the Wininz V- Tgenrla wil! wffe- i f it is "strztched' too iar to cover nontqqxecl groups.

4 Survey attendees Whether done formally or informally, some sort of assessement of attendees must be done in order to properly develop an agenda and training. An informal assessment may simply be three to five phone calls to randomly selected representatives of the group, asking if they know about pollution prevention and what they would like to know, with a total time commitment of less than two hours. Done more formally, the assessment could require professional expertise in survey design and analysis and require several weeks to complete. One shortcut is to locate instances of similar training and "borrow" whatever assessment infomation seems applicable.

--Determine attitudes, experience, needs, expectations

--Test awareness of the definition of pollution prevention If definitions need to be discussed and are not, much of the mining could be lost in confusion or disagreement. If definitions are clear to the attendees, but too much time is devoted to their discussion, resentment is a likely result.

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I! Analyze survey results Analysis can be simple or complex, depending on time available and the survey itself. If the survey reveals information about any of the follwing it can be used to design and deliver the training.

--Special needs

--Expectations that require management

--Attendee skills/background that can be incorporated

--Identify believers

.\! Propose final training goals and draft agenda

--No more than five objectives

--Show times and place

--Give time for each component

--Give purpose for each component

.\! Check with sample of potential attendees A quick phone to a few people who might attend can yield important reactions that can then be used for last-minute corrections of the agenda. But whether this input is gathered before advertising the mining, or when registrations start to come in. flexibility in the agenda should be considered until the very last minute, as long as incorporating one comment does not eliminate other material seen as important by a significant number of the group.

Develoo ment

Major training goals derived from audience analysis arc usually similar to the following, which could be considered agenda components:

Definitions and motivation --What is pollution prevention? --Why should [this organization] do pollution prevention? --What is your [the attendee’s] role?

Background --What is happening at [this organization]? --What is happening elsewhere? --What is the forecast?

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Technical content --Uses, wastes and releases at [this organization] --Pollution prevention opportunities at [this organization]

(may be presented or developed in training)

Implementing pollution prevention at [this organization] --Measuring progress --Integration --Cross-functional coordination

After considering those magor components, the length of a training session is probably

the next decision to be made. This decision on length while considering the attendees' position

can be adjusted as the content becomes more clear, increasing or decreasing the time allotted within

rough boundaries. Somewry rough rules of thumb for pollution prevention training:

- Senior management-two hours

Managers without direct supervisory responsibility for "line" staff--two to four hours,

Managers charged with day-to-day direction of field or production staff--four to eight

Field staff, production staff, managerscharged with pollution preventiodenvironmental

depending on motivation

hours, depending on motivation and direction from top management

management--one to two days for any one training; a series of trainings may be necessary

. . ..,noiF.w ra-ly ir""l:l.,,~-nt'd~~is;on h::s t 3 de wlth ~ I L : applown cir stylc UC the 3.u:iing. Two major schools of thought are lechue-bused and inreructive. Lecture-based is the format and approach with which most attendees are familiar, and probably most comfortable. Interactive (or cooperative, or learner-centered, or hands-on) training emphasizes the need to develop a "process" or "tools" that each attendee will later customize to fit their personal situation. In addition, this approach to mining involves attendees themselves, and their interactions, as much as possible. Attendees experience the concepts, rather than having them presented.

Because of its unfamiliarity and development needs, the interactive approach is almost always supplemented with some material delivered by lecture, as well as overheads/slides, hand- outs and resource packets. At this point in agenda development, the most important decision to make is whether any interactive sessions will be included, so that instructors and materials can be located.

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A final early decision area is in the weighting of agenda components. Some basic agenda components are:

. Introduction . Background/Historical Review/Current Events . Communications . Technical Content . Application/Integration . ResourceslNext Steps

Depending on the objectives of the training and the attendees, different components will have different amounts of time devoted to their development and delivery. Senior management might receive mostly background and integration information, but very little technical material; other managers a fairly even mix of all components, with a slight emphasis on communications; implementation staff a heavy emphasis on technical content and application, with only a brief background section. The decisions will be made using the audience analysis completed initially, and by use of a good development team, with both in-house and external members.

Generic pollution prevention training is often only useful as an introduction to the topic; thus the need for customization. In order to customize the above generic agenda components, a fairly standard training analysis would be conducted, looking at training needs and related goals. Topics to be considered for pollution prevention training could include:

Organizational structure --I iieiarLhies --Decision-making process --Information flow

Organizational culture --Latitude for innovation --Existence of team-based initiatives (quaIity/productivity

improvement) --Environmental ethic

Organizational capability --Capital availability --Personnel --Market exposure/stability --Change-determining factors (time-to-market infrastructure;

product life cycle)

,' .

The most effective delivery of all may be a sequence of short, problem-focused trainings that also teach a predetermined series of lessons. For example, Training #1 for senior management

50

would have attendees consider in a two-hour agenda their role in structuring a pollution prevention program for their organization by asking them to draft an action plan in response to regulatory pressure on a substance of great importance to the organization. Training #2 would ask those same attendees to consider implementation of that program by having them confront the fact that opportunities do not exist and must be generated intemally. And so on t h u g h the whole process.

A principal difficulty seems to be in the definition of the key basic term, pollution prevention (or waste rduction, or source reduction, or use reduction, or waste minimization) and the impact of that definition. In addition, for many attendees pollution prevention can be seen as "not my job." But beyond those shared concerns, each type of training has yielded its own lessons.

In longer versions of orientation training, communication techniques and practice of such ideas as "unbounded thinking" and "creative thinking" may be a large component, since changes in attitude is often the thrust. Introductory training may also be blatantly inspirational and "rah- rah" for the same reason. Both need for better communication and the effect of being "proselytized" can lead to attendee dissatisfaction.

Indusv- and use/waste/release-specific mining is at a very early stage of development, due ;o scvcral factorJ. Fmt, tl., fkld (I: +tilutiuki p=.veniiun i; 31.11 nla5vely n,w as a unique discipline. This means that the methods to find, develop and transfer good pollution prevention information are still being developed. Second, much of the information is very site- and use- specific, making it difficult to use it with wider audiences. Third, many of the truly innovative attempts to implement pollution prevention occur in industrial facilities, conducted by staff who are far too busy operating processes to pause and document changes and their impact on waste generation.

The difficulties asssociated with assessment training are similar to those mentioned for more specific training. For example, while it seems to be possible to suggest approaches and point out pitfalls, taeching a skill called "pollution prevention assessment" is very hard. The actual conduct of an assessment is dependent on things like: Who is available to lead the tour of the facility?; What sort of information about uses/wastes/releases is readily available?; and What motivates the facility to seek the assessment? In addition, an assessor must actually practice

51

something like industrial sales, with pollution prevention as the "product", and be able to find such bits of information as the attitude of management and whether or not what is revealed is actually the truth.

Evaluation is mentioned twice in this paper to stress an often unrecognized point: That establishing a baseline and an evaluation scheme the mining is at least as important as any assessment done &r the training. This is especially hue in pollution prevention, where progress can be so difficult to measure, in addition to the already familiar problem od evaluating training. Experience has shown that while it may be interesting to document attendees' immediate reaction to

pollution prevention training, tracking implementation is a far better indicator of whether goals were met.

The following q p d a and overheads are part of an actual project conducted for a Department of Energy facility, the Idaho National Engineering Laboratories (INEL). These materials were used to present the pollution prevention project to senior management, seeking their support and resources. The entire project covered assessment mining and management awareness for the entire site, .~4th. the premise that pol!i:ion p m :i~Con is besi conducted by facility personnel, with targeted support by contractors.

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I .