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DRAFT
SOURCE REDUCTION PLANS: A PROPOSAL
Ken Geiser
Center f o r Environmental Management Tufts University
March, 1985
What Is a Source Reduction Plan?
Source Reduction Plans could be an effective tool in reducing
the amount and degree of hazard of toxic chemicals in society.
A Source Reduction Plan is a document describing the means
and timing by which corporations will reduce the risks of
toxic chemicals in production. Source reduction is here
defined in its broadest form to mean the reduction of toxic
chemical risks not only at the point of waste, but throughout
the production operations. Further, production is defined
broadly to include all functions of an organization including
maintenance, repair and source. The objective of source
reduction is fundamentally the reduction in the risk of
human exposure to toxic chemicals and, instrumentally, the
reduction in use of toxic chemicals.
Today, there is emerging a hierarchy of processes recommended
for reducing toxic chemical exposure and toxic chemicals.
These include
a. chemical substitution (less hazardous chemicals
substituted for more hazardous chemicals)
b. chemical process changes (changes in prodcution
that result in less chemical use or safer chemicals
used)
C.
d.
e.
f.
g.
improving production management (reducing spills,
leaks, vaporization, etc. and reducing mixture
errors and bad production runs)
product substitution (producing less toxic
1
products or products that are less hazardous
to produce)
reclaiming, recycling and reusing chemicals
point of production treatment and detoxification
improving waste management (including improved
storage, transport and on site disposal)
Most all of these changes require
a. increased awareness and attention about toxic
chemi ca Is
b. increased motivation to change existing patterns
C. knowledge of potential options for change
d. willingness to experiment and change
e. resources to implement changes
f. willingness to follow through, evaluate and
learn from such changes
All of these elements are advanced when corporations prepare
Source Reduction Plans. A Source Reduction Plan then becomes
a guide for raising the level of attention about toxic chemicals,
increasing motivation to change, presenting alternatives,
guiding decision making, advocating for resources and providing
information to evaluate the consequences of changes.
How Would a Source Reduction Plan Work?
Let’s assume an ideal. The management of a metal plating
shop decides to do a Source Reduction Plan. The management
hires an industrial engineering firm to prepare a plan.
The consultant first identifies all of the chemicals used
in production, notes the most hazardous chemicals and rates
them with priorities for attention. Next the consultant
notes the most hazardous uses of the high risk chemicals
and ranks those as well. The consultant then reviews technical
or management options that would reduce the risks, beginning
with the highest risk points and working down. Then the
consultant finds examples of experience of other firms with
these options or finds suppliers of equipment or services
that would implement the options. Then the consultant prepares
cost estimates for each option for each of the risk points
selected. Then the consultant considers payback periods,
liability reduction incentives, commercial or public financing
and effects on product pricing, profits and investment attractiveness.
Finally, the consultant, working with the management and
workers, analyzes changes, prepared schedules and projects
targets for future evaluation. As a final product, the
consultant prepares a planning document, with schedules
and projected risk reduction targets.
Following this model, the Source Reduction Plan document
would have as a minimum four elements.
a.
b.
C.
d.
a comprehensive inventory of all toxic and
hazardous chemicals used in the plant
a ranking of the chemicals as to priorities
for source reduction
a list of planned process changes that would
reduce the risk associated with the highest
priority chemicals
a schedule and set of performance targets that
would link process changes to reductions in
volume or degree-of-hazard of process chemicals
or waste
This then would constitute a Source Reduction Plan.
What Should Be the Role of the State?
In the ideal world a responsible management concerned about
toxic chemical liability would be currently trying to reduce
toxic exposure and a plan would be a sound way to advance
this. Here we can leave the world of ideals. Most managers
have little incentive to expend corporate resources on activities
that are costly, are risky, have other than short term benefits,
are not also being done by competitors and'are not required
by law. Even managers interested in reducing some chemical
exposures may not think comprehensively, may focus on the
easy to reduce, but insignificant, risks, may not know
about options and may have no way to assess benefits. Further,
it is not corporations that are advancing the goal of lowered
chemical risk. It is the public, acting through government, I
that is pressing for safer workplaces and less chemical
pollution. This public is not unjustifiably skeptical of
corporate volunteerism. Source reduction must somehow make
corporations accountable to the public. Further, it is
only the government that is in an effective position to
set rules equally for all firms and industries.
There are also administrative reasons for government encouragement
of Source Reduction Plans. Amendments to the federal Resource
Conservation and Recovery Act passed last year focused increased
government attention on "waste minimization." The new regulations
require that waste manifests certify that the volume and
toxicity of the waste has been reduced to the maximum degree
economically feasible and that the biennial waste generator
reports indicate efforts to reduce waste volumes and the
degree of success achieved by these efforts. Thus the government
is already slowly creeping into a significant role in requiring
source reduction planning.
The public role in Source Reduction Plans could then be
significant. Policy options include
a. State mandated plans for all corporations. The
state requires all chemical using corporations
to prepare and submit Source Reduction Plans
b.
C.
d.
State mandated plans for specific industry
classifications. The state identifies the
top twenty or so industries that use toxic
chemicals and targets them
State required plans as a condition of state
action.
all corporations applying for grants or loans,
or permits and licenses or exemptions and tax
credits
State urging corporations to prepare plans.
State could provide training and education
and moral persuasion.
The state could require plans from
While any of these options might be considerec , the strongest and most effective policy option would be the first: state
mandated plans for all chemical using corporations. Such
a policy would be far-reaching and dramatic. It would serve
to raise attention throughout the state and it would create
a significant market for technical assistance.
What Role for Technical Assistance?
While the state should put itself squarely on line in demanding
that corporations begin now to reduce toxic exposure risks,
the state should as much as possible stay out of the technical
aspects of how firms go about this business. The state
does not have the resources or skills to train corporate
managers in new industrial processes. There are thousands
of corporations in the state, most with highly specific
conditions, resources and commitments. The state could
never effectively service all of them. Yet the state does
need
a. to effectively monitor the preparation and
implementation of Source Reduction Plans, and
to guarantee that hundreds of small businesses
get the technical help they need to stay in
business, but meet the goals of source reduction
b.
A l o o k at Massachusetts' recent experience with the "right
to know" law suggests a model. Few who struggled to achieve
passage of this law foresaw that it would create a small
market for technical assistance into which innumerable consultant
firms would leap. This experience suggests that mandating
Source Reduction Plans would likely create a similar market.
A s a means of inducing innovation and the diffusion of innovations,
this service industry has significant value, both to corporations
and the state. For corporations there would be technical
assistance services that could prepare Source Reduction
Plans, help broker equipment and financing packages, oversee
production changes and train employees in new processes.
For the state there would be a pool of technical consultants
who could be hired to review Source Reduction Plans filed
by corporations, assess plans, service small firms and monitor
corporate progress in achieving the objectives of the plans.
What Role for Local Communities?
While fairness and effectiveness both dictate that the state
should set the requirements and timetables for Source Reduction
Plans, it does not follow that the state should be the primary
agent for monitoring and compliance. After all, toxic exposure
is a local event. Local communities have the most to gain
from reducing the risk of chemical contamination. Local
officials and community residents have much to learn and
say about the kind of health and safety conditions that
should exist within their municipalities. Local participation
also builds a borader base of support for source reduction
and provides for the development of a public constituency
for this and further programs.
Several options exist at the local level. Local Boards
of Health, or fire companies or tax collectors, or hazardous
waste coordinators or right to know coordinators, or special
officially appointed committees could review Source Reduction
Plans and periodically assess progress and compliance. There
is probably a lot here to recommend special local Boards
of Public Safety that unite hazardous waste coordination,
right to know coordination, fire, police and civil defense
functions. Such local Boards of Public Safety, while not
necessary to implement Source Reduction Plans, would be
an attractive new local institution for coordinating and
monitoring the health and safety environments of local communities.
Nor should the voice of workers be neglected here. Employees
of local firms often are intimately familiar with the current
production processes in a firm.
with practical and inexpensive ideas about production improvements.
Local workers and unions might play an important role in
helping to develop Source Reduction Plans, to review and
comment on plans and to monitor plans for compliance.
of local unions might add depth and insight if also included
on local Boards of Public Safety.
Workers often are filled
Representatives
What About Enforcement and Compliance?
The preparation and filing of a Source Reduction Plan has
much value in its own right. Attention would be raised
and options explored. Public access to such plans would
provide some incentive toward implementation, due to the
perceived threat of embarrassing corporations in default
of their plans. Yet, perhaps, there needs to be some "bigger
stick." Corporations that fail to file plans of course
should be penalized with some significant weight.
corporate papers is always possible, but perhaps something
more like fines or civil sanctions would do. Failure to
Revoking
follow out a plan must, in fairness, be more judicial.
Many factors could lead to failure to implement. If local
communities are to monitor plans, there must also be local
discretion and the right to negotiate and alter plans.
The incentive at this point might be no more than a referral
to state sanctions, such as loss of permits, licenses or
access to public resources. An interesting planning experience
in New Jersey offers a useful parallel here. In 1976 New
Jersey passed legislation that mandated that all firms that
purchased and used chemicals from a list of some 155 priority
chemicals report to the state quantities purchased and exactly
how those chemicals left the plant, either as product or
waste. This simple chemical inventory ran for three years
between 1978 and 1981, and covered all industries in the
state. During that period compliance was extremely high.
What Protections Do Corporations Have?
It is always best to start by assuming that corporate managers
will do their best to comply with social objectives. That
they fail, and fail often, is a lesson worthy of learning
anew each time. Yet corporations do need some protections
against arbitrariness, excessive burden and, particularly,
against losing competitive position. If local Boards of
Public Safety or other agents are designated as monitors
of compliance, then criteria need to be strict and limits
on local sanctions well marked. There also needs to be
an effectie appeals process that settles disputes and relieves
corporations of vindictiveness and harrassment at the local
level. Further, there will need to be careful trade secret
protections defined so that corporations may hide aspects
of production that truly yield competitive advantage. Much
of this was handled in the right to know legislation and
lessons learned there would be helpful here.
Another lesson learned from the right to know experience
is the value to corporations of having effective advance
notice and clear guidelines. Phasing in of mandates for
Source Reduction Plans could be tied to size of firm or
industrial classification. Targeting less than all firms
at once would lead to learning lessons as the program develops
and avoid the managerial and fiscal traumas of overwhelming
either business or government.
There is also no need to target all corporations equally.
Some corporations employ significant amounts of toxic chemicals,
while others may do little more than purchase janitorial
supplies.
by standard industrial category, by volume of hazardous
waste produced or by use of particular priority chemicals.
Those of particularly high priority could be targeted first
Priority could be given to corporations defined
or plans could be required of only certain of the priority
classifications.
Source Reduction Plans in the Larger Context
Source reduction planning does not solve the problems of
new, safer technology development or the access to capital
that firms may need to finance changes in production processes.
But planning does raise consciousness and attention, does
produce and communicate information and does provide the
basis for more effective action. Source Reduction Plans
are a tool for requiring the private sector to present its
responsibility for guaranteeing a less risky work and community
environment. But, such planning in the private sector must
be coordinated with public sector planning as well. The
aggregate of private Source Reduction Plans should provide
an effective base for the development of state Toxic Substances
Management Plans. The role of the state as regulator and
motivator must be carefully coordinated with private plans
to guarantee that transitions to less toxic production are
fair and comprehensive and do not overly burden any single
sectors or individuals. The state must therefore develop
and follow its own plans -- something on the order of a
Toxic Substances Management Plan.
Nor should the state act independently of its own local
districts. For local communities and local Boards of Public
Safety to effectively monitor and encourage firms to comply
with their own Source Reduction Plans, there will need to
be local plans as well. The private Source Reduction Plans
f . I
of all firms in a local city or town should easily become
the basis for local Hazardous Materials Management Plans
as well. Only with such careful coordination at both the
state and local levels can source reduction be advanced
as a benefit to industry, workers, residents and the larger
state commonwealth.
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