Pollution Prevention (P2)


We hope you will find this P2 information useful.  You can use this P2 process to help with specific pollution problems or to establish a full-blown P2 program.  The process is generic enough to be useful for any waste-related issue, yet detailed enough to arm you with with sufficient information and tools to assist in reducing any waste stream.  Contact Walter Bowles with your specific P2 questions.

Pollution Prevention - Detailed Information

Section 1 - Regulatory Requirement

Section 2 - What is Pollution Prevention?

Section 3 - Now Will Pollution Prevention Benefit You Operation?

Section 4 - Pollution Prevention Problem Solving - A Practical Approach To Pollution Prevention

Step 1:  Select and Study an Operation for Losses
Step 2:  Identify Key Losses
Step 3:  Analyze Key Losses
Step 4:  Generate P2 Options
Step 5:  Evalutate P2 Options
Step 6:  Implement P2 Options & Measure Results

Section 5 - Pollution Prevention Facility Planning

Additional Sources of P2 Information

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Pollution Prevention – Principles and Detailed Information

 

Pollution and waste are serious issues for any manufacturer. Normally the pollution and waste are a result of inefficient material use and operations, and wasteful practices. The problems they present can lead to increased health and safety concerns, result in high regulatory compliance costs, and hamper your company’s ability to remain competitive in the marketplace.

The practice of controlling pollution after it was created is an outdated measure that did little to reduce waste. Not only does pollution control equipment cost a lot of money, companies are further saddled with the mounting internal costs such as poor process efficiency, waste disposal, and regulatory affairs.

    Pollution Prevention ("P2") is a process that can help companies overcome many of these costs by preventing the creation of pollution and waste at the source. P2 is a proven process that can help you improve on the practices and processes that cause pollution, as well as reduce or eliminate the costs associated with pollution control, waste disposal, and regulatory compliance.

The competitive market and stringent environmental laws dictate that pollution and wasteful practices need to be minimized or eliminated. Pollution Prevention must be in the future for any company planning to have a future.

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Section 1: Regulatory Requirements

 

Can you be regulated under the Pollution Prevention Act? The answer is No! There are no current requirements under Federal law that make Pollution Prevention programs mandatory – Pollution Prevention Programs are voluntary and non-regulatory.     However, pollution prevention practices are mandatory in different forms under media-specific regulations like EPCRA, RCRA, and NPDES. These laws call for waste minimization plans and storm water pollution plans, among others.  So even if your facility chooses not to pursue a facility-wide pollution prevention program on its own, certain environmental laws may dictate that P2 practices be incorporated in the facility's environmental affairs.

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Section 2: What is Pollution Prevention?

 

Some companies may choose to implement pollution prevention practices because it’s the right thing to do for the environment and for their employees. All companies should be interested in pollution prevention since it also provides an opportunity to reduce costs. Pollution prevention not only makes good environmental sense, it makes good business sense. It is a "win-win" approach for the company and the community.

What are some benefits offered by Pollution Prevention?

  • Economic - Reduced disposal and treatment costs; manpower and financial savings from reduced regulatory requirements (e.g. permits, reporting, etc.); increased productivity through efficient operation of equipment; and lower raw material costs when reusing materials.
  • Environmental - Reduced emissions, releases, and disposal of wastes and hazardous chemicals; conservation of natural resources.
   
  • Human Health - Reduced employee exposures and safety risks from handling or working with wastes or hazardous chemicals.
  • Regulatory Compliance - Reduced permitting, reporting, and recordkeeping requirements.
  • Liability - Reduced liability associated with waste disposal, employee exposure, and regulatory enforcement.
  • Public Relations - Reduced publicity associated with chemical release reporting, emergencies, or accidents; offers "environmentally friendly" operations and products to customers.
  • Plant Operations – Reduced wasteful processes and practices that compromise operations productivity and product quality.

The "Pollution Prevention Hierarchy" shown below provides an excellent visual representation of the benefits associated with each level of pollution prevention.

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Section 3: How Will Pollution Prevention Benefit Your Operation?

 

Historically, companies and regulators focused on pollution and waste after it was generated, relying on "end-of-pipe" controls or treatment (e.g. incinerator). Businesses now realize that efforts to reduce or eliminate waste before it is created (termed "Pollution Prevention") often result in positive environmental stewardship, reduced regulatory burden, and handsome cost savings. Protecting the environment and adding money to your bottom line are two powerful reasons for all companies to incorporate Pollution Prevention in their everyday thinking.

"Pollution Prevention is the use of various technical and non-technical means of source reduction and material recycling that limit waste and pollution creation."

Pollution prevention has close ties to the quality movement. Just as quality management strives for "zero defects," pollution prevention targets "zero discharge" of pollutants. The extent to which your operation will benefit from pollution prevention activities will depend on your control and knowledge of your own processes. Pollution prevention requires a neat, orderly, and efficient operation. Those businesses with operational discipline will likely succeed in changing materials and practices with minimum disruptions.

Pollution prevention conserves raw materials through source reduction, material reuse or reclamation, responsible chemical management, and efficient energy and water use. Preventing waste from being created eliminates the need to recycle, treat, or dispose of wastes.

    Congress, via the 1990 Pollution Prevention Act, established a national hierarchy (ranking system) for evaluating various approaches to managing wastes. This ranking system established pollution prevention as the most desirable and beneficial approach to managing wastes. The complete hierarchy for managing wastes includes:
  • Prevention (Source Reduction);
  • Recycling;
  • Treatment; and lastly
  • Disposal.

Your goal should be to rise on the hierarchy as you evaluate and implement different approaches to managing wastes.

What Pollution Prevention Isn’t:

Pollution prevention, as explained in the preceding paragraphs, incorporates prevention and some types of recycling (reuse or reclamation). Pollution prevention does not include:

  • Off-site waste management (e.g. chemical waste recyclers);
  • Energy recovery (e.g. incineration, heat transfer);
  • Thermal treatment;
  • Treatment to reduce volume (e.g. compaction);
  • Treatment to reduce toxicity (e.g. neutralizing an acidic waste);
  • Reduction in production volume;
  • Installation of end-of-pipe pollution control equipment;
  • De-listing of hazardous materials; or
  • Disposal (e.g. landfill).

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Section 4: Pollution Prevention Problem Solving -
A Practical Approach to Preventing Pollution

 

A structured problem-solving process is the most effective method for finding the right pollution prevention opportunities for your environmental management issues. A problem-solving process will ensure you effectively identify, analyze, and implement the best solution to your environmental problem. This process will help save you time, resources, and money.

Many companies have used problem-solving processes to improve quality and productivity. Now more companies are using these same problem-solving processes to prevent losses (wastes) from occurring from their operations. Take a look at four "Pollution Prevention Success Stories" from companies that have implemented pollution prevention activities and are currently reaping the benefits. Your company can also enjoy these benefits if you implement a sound pollution prevention process.

    Most models used for problem-solving processes include elements such as problem identification, data collection and analysis, generating potential solutions, evaluating and selecting solutions, implementing solutions, and measuring results. These same models can be adapted and used for pollution prevention. Problem-solving processes for pollution prevention can be improved through the use of tools such as process mapping, materials accounting, and cause/effect analysis.

The Pollution Prevention Problem-Solving Process is shown below, and it can be used (or adapted) to help your company identify, evaluate, and implement pollution prevention opportunities. This process is neither complicated nor does it require a great deal of technical skill to use. With a little practice through hands-on use by an employee team, your company will have the skill and ability to effectively identify pollution prevention opportunities for any situation.

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Pollution Prevention Problem-Solving Process:

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Step 1: Select and Study an Operation for Losses

The first step is to select and begin studying an operation (or process) for improvement.

Any facility operation where there are losses occurring could be a good candidate for pollution prevention. For example, consider these common pollution prevention areas for chemical operations:

  • chemical processing (formulation, reaction, polymerization, separation, distillation);
  • material handling and distribution;
  • tank/vessel/equipment cleaning;
  • product packaging, and laboratory activities.

An important outcome from Step 1 is a complete understanding of the process. To improve a process, you must first completely understand it. A useful tool for developing an understanding of a process is "process mapping." Process mapping identifies individual steps of the process, including important "inputs" and "outputs." The material flow diagrams used in process mapping will lead to a better understanding of a process, including where key "losses" may be occurring. An example of a process map for a batch chemical operation is shown below.

A "Process Map Template" can be used to map your key chemical processes.

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Step 2: Identify Key Losses

Step 2 focuses on identifying and collecting data relating to the losses, which includes assigning volume and cost data to inputs and outputs. This is referred to as "materials accounting." The process map developed in Step 1 can be used as a template to easily display the materials accounting information. Completing this step will show you the volume of "losses" that are occurring from your operation, and more importantly, how much these losses are costing your company. This helps identify the economic and environmental impact of losses from your various operations.

A "Materials Accounting Template" can be used to display this information for further analysis. Once this template is completed for a process, you will want to prioritize the waste streams to determine which should be investigated first.

To do this, utilize the "Waste Stream Priority Rating" worksheet.  Based on the Priority Ranks you develop, you can now select one or more key waste streams to further investigate for pollution prevention opportunities.

 

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Batch Chemical Operation Process:

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Step 3: Analyze Key Losses

After you select a waste stream for investigation, the next step is to fully analyze the factors that are contributing to the losses. This is often referred to as "root cause analysis." In this step, defining all the causes (and importantly the primary cause) for the losses will help you decide on and prepare the right pollution prevention opportunities to reduce or eliminate those losses.

An effective tool used for root cause analysis is a "Cause and Effect Diagram" (or fishbone diagram). The effect (or loss) is the "head of the fish". Causes branch out from the backbone attached to the head of the diagram. Most often four main cause categories are used for the diagram (main branches): people; materials; methods; and machinery. By asking the question "why is this occurring?" several times, you begin to fill in the diagram. This analysis will help you identify important factors contributing to the loss that is occurring. An example of a simple cause and effect analysis is shown below.

After asking "why" several times to complete this root cause analysis, it may become apparent which factors are the leading causes of the losses. Often, additional data gathering and analysis may be needed to better identify the key factors.

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Step 4: Generate P2 Options

In Step 3, you analyzed key losses and identified the most important factors leading to those losses. In Step 4, you will generate specific source reduction and recycling options to reduce or eliminate those losses. Possible source reduction options would include those relating to improved operating practices (i.e. inventory control, employee training, better procedures, improved housekeeping, preventative maintenance), material substitutions, process changes and/or equipment modifications, and product changes.

Methods used to generate options can include a simple "brainstorming session" with employees. Benchmarking with other chemical companies, customers, suppliers and using outside vendors or technical assistance providers may also prove beneficial.

The "Option Generation" and "Option Description" worksheets will help you list and select P2 options for further evaluation.


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Step 5: Evaluate P2 Options

At this point, you need to analyze the feasibility of the pollution prevention options to determine which options are best for your situation. In some cases, you may decide to proceed directly to implementation for those options that are of little or no cost, easily implemented (no technical risk), and clearly have environmental benefits. For other options, you may decide further economic, technical and/or environmental analysis may be needed.

The "Economic Analysis – Payback Period" and "Economic Analysis – Net Present Value" worksheets (Examples of these can be found in Figure 3.8 (.pdf) & 3.10 (.pdf) respectively) can be used to help you determine the costs, savings, and payback period for the pollution prevention options. Options with favorable payback periods (i.e. less than 2 years) could be good candidates for implementation. Options that have a positive net present value should also be looked upon favorably for implementation.

Often loans, grants, tax exemptions, and other financial incentives are available to make some options more economically attractive. For example, the State of Ohio has the "Pollution Prevention Loan Program" that provides low interest loans for P2 equipment.  You should contact the State of Ohio for more information if it appears your company does not have the upfront resources to complete a costly, but highly beneficial, P2 project.

A "Technical Analysis" worksheet, can be used to determine if options will "technically" fit your operations. This will be important for P2 options that include process changes and/or new equipment.  Be sure your proposed P2 option is a good "operational fit" before you sink the resources into it.

The "Environmental Analysis" worksheet can help you score which P2 options provide the highest environmental benefit. Those options scoring the highest could be selected and prioritized for implementation. The Environmental Analysis will address the criteria used earlier in Step 2 in the Waste Stream Summary Worksheet.

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Step 6: Implement P2 Options & Measure Results

Based on the feasibility analyses performed in Step 5, the best P2 options based on your specific application can be selected for implementation. Consider establishing an implementation plan that would include a project schedule to identify tasks and timelines for better managing the implementation of your pollution prevention options. Your plan may also need to consider obtaining capital for financing the implementation of your options. Finally, a very important element of implementation should include gathering appropriate data to help monitor your option.

To determine if your option is effective and is getting the desired results, evaluation of the option is needed after implementation. You should look at data collected since implementation and compare it to information collected when you began the pollution prevention process. For example, you can consider re-evaluating those key factors that were previously determined to be contributing to losses to see if they have been effectively addressed. Your evaluation should also look for any new problems that may have occurred after implementation.

Consider publicizing the results (internally and externally) to encourage and promote ongoing P2 activities. You should also consider measuring the economic (annual savings) and environmental (annual pounds of pollution prevented) benefits from the implementation of your P2 options. Information from this step can be used for continuously improving your ongoing pollution prevention problem-solving efforts.

 

 


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Section 5: Pollution Prevention Facility Planning

 

Many companies have benefited from implementing a facility-wide pollution prevention program. There are several quality P2 resources to help companies develop and implement facility-wide pollution prevention programs. One of the better and more useful resources is "Office of Pollution Prevention" at the Ohio EPA.  Check out the P2 links below for more information and guidance with P2.

A facility-wide pollution prevention program involves developing and implementing a continuous strategy to reduce all forms of waste generated by facility operations. What are the key elements of an effective pollution prevention program? 

    While there are several important characteristics of successful pollution prevention programs, the elements listed below are often recognized as the key elements common to model pollution prevention programs.

Key Elements of a Model P2 Program

  • Top Management Commitment;
  • Pollution Prevention Goals;
  • Employee Involvement Teams;
  • Periodic P2 Assessments, and
  • Measurement of Program Results.

If you are interested in implementing a P2 program, just getting started with one, or looking to improve your company’s existing program, consider learning more about these elements from the resources listed below.

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Other P2 Links
U.S. EPA's Design for the Environment (DfE)
Ohio EPA's Office of Pollution Prevention
U.S. Federal Agency P2 and Compliance Assistance Cooperative
U.S. EPA Enviro$en$e
U.S. EPA Office of Pollution Prevention and Toxics
Dr. Robert B. Pojasek - Harvard School of Public Health

 


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Last Update 9/16/00