1 POLLUTION PREVENTION The EPA 33/50 Program 1960’S to 1980’s - increasing environmental awareness Approaches: 1) Regulations - Command and Control 2) Control of waste materials through chemical, mechanical, physical, even electrical treatment and collection (for disposal), transformation, and/or destruction of pollutants after they were generated. 1990’s - Growing awareness of pollution prevention Approaches Prevent the generation of waste itself. Reduce the need to control wastes because they are not produced to begin with. Source: OPPT - Pollution Prevention Success stories
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POLLUTION PREVENTIONThe EPA 33/50 Program
1960’S to 1980’s - increasing environmental awareness
Approaches: 1) Regulations - Command and Control 2) Control of waste materials through chemical, mechanical,
physical, even electrical treatment and collection (for disposal), transformation, and/or destruction of pollutants after they were generated.
1990’s - Growing awareness of pollution preventionApproaches
Prevent the generation of waste itself. Reduce the need to control wastes because they are not
produced to begin with.Source: OPPT - Pollution Prevention
Success stories
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POLLUTION PREVENTION: Definition
Prevention takes many forms:Buying correct amount so no excess materials
need to discarded.Producing less wastewater by better controlling
the amount of water used in cleaning or manufacturing.
Substituting non-toxic chemicals for hazardous or toxic materials currently used in processes.
Re-engineering and redesigning manufacturing processing lines to take advantage of newer, clear process equipment.
National Policy of the US Pollution should be prevented or reduced at source
whenever feasible Pollution that can not be prevented should be
recycled in an environmentally safe manner where feasible
If pollution cannot be recycled or prevented it should be handled in an environmentally friendly way
Disposal or release to the environment should be employed as a last resort and should be conducted in an environmentally friendly manner.
42 USC §§13101-13109
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Voluntary Overcompliance
Voluntary Overcompliance is a recent phenomenon.If the law requires toxic
emissions reductions of 50% some firms pledge to reduce more
A firm overcomplies when they go beyond a stated law or regulation voluntarily.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Voluntary Overcompliance
Factors leading to OvercomplianceDynamic nature of game between
firms and enforcement agencyViolators are threatened with
perpetual surveillance so, even though the penalty is less than the cost of compliance, firms comply and often go beyond compliance. Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Voluntary Overcompliance
Preference for environmental quality by consumers may combine with competition and induce some firms to overcomply
Increased public scrutiny has led some firms to self-impose stringent emissions standards.
Information about a firm’s environmental record is now available as part of Toxic Release Inventory.
Growth in overcompliance coupled with consumer desire for environmental quality.
Evidence is showing that those companies that make the investment to change early are much better off.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
TRI data collected focuses on source reduction activities
TRI is voluntary based, rather than risked based measure of pollution (exposure levels are not considered)
Facilities which manufacture or process more than 25,000 pounds or use more than 10,000 pounds of any reportable chemical must submit a TRI report for each chemical
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Toxic Release Inventory(TRI)
Data collected includes information on release into all media: air, land, (on-site land, underground injection wells and off-site transfers) and water.
Due to the public nature of the data collected and reported, the TRI may be the most significant measure of industry’s overall progress in reducing wastes and releases.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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TRI Data
TRI data show aggregate year to year decreases in releases and transfers of more than 320 chemicals
LimitationsTRI data set is self-reported, therefore there
exists an incentive to under-report the releases.
May also be an incentive to over-report if firms expect to be rewarded for improvements to a baseline emission level.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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TRI
Critics of TRI suggest that changing database, different reporting requirements, and production volume decreases, rather than real pollution prevention, are the primary reasons that decreases are being seen in releases.
Source: July 26, 1993 C&EN
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TRI, Pollution Prevention Act and 33/50 Program
Connections:There was anecdotal evidence that the
publication of the TRI data in 1988 “shamed” several top polluting firms to voluntarily reduce toxic releases.
The 33/50 program was developed in part to take advantage of this “voluntary sentiment” and its design was influenced by the Pollution Prevention Act 1990.
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Chemical Industry
Leads all the other industries in releases @1.5 billion pounds in 1991
90% of chemical manufacturing belongs to Chemical Manufacturers Association (CMA)
Source: July 26, 1993 C&EN
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CMA
CMA adopted Responsible Care Program (1988) Companies should strive for annual reduction,
recognizing that production rates, new operations, and other factors may result in increases. Despite these fluctuations, the goal is to establish a long-term, downward trend in the amounts of waste generated and contaminants and pollutants released.
Uses the TRI to measure progress Adherence to Responsible Care is a condition of
membership in CMA
Source: July 26, 1993 C&EN
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33/50 and CMA
EPA’s 33/50 program, which CMA supports as consistent with Responsible Care, is an example of a program where the focus has shifted from volume to environmental impact.
It may be better in the overall scope of things to spend $ to reduce smaller volumes of highly toxic chemicals rather that focusing on those produced merely by highest volume.
Source July 26, 1993 C&EN
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Overview of the 33/50 Program
EPA initiated 33/50 program in Feb. 1991Designed to reduce releases and transfers of
17 high priority chemicals by 33% at end of 1992 and by 50% at the end of 1995.
It encouraged firms to use less toxic substitutes and to reformulate products.
Encouraged firms to redesign production processes to achieve source reduction, rather than resort to end-of-pipe clean-up.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Overview of the 33/50 Program
33/50 focused on 17 chemicals becauseThe Chemicals selected for 33/50
program accounted for one-quarter of releases produced by industry
33/50 was a unique regulatory experiment which:Stressed cooperation between regulators and
industryWas non-adversarialProvided positive feedback to participantsAwarded participating firmsParticipants’ commitments to achieve pollution
prevention goals were not enforceable by law; thus firms could renege on their commitment.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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Overview of the 33/50 Program
Incentives offered by the program include: Public recognition by EPA(newsletters, PSA, trade
journal articles) Awards for innovators and firms with outstanding
pollution prevention achievements Flexibility to undertake the most cost-effective
emission reductions Firms benefit form Pollution Prevention Information
Exchange System (PIES) - technical information is available to both participating and non-participating firms
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33/50 and EPA’s Enforcement Duty Caveat
The voluntary nature of the program meant that a company’s decision to participate did not change its responsibilities for complying with all other laws and regulations.
Participation in the program was enforcement neutrala company would receive no special scrutiny
if it elected not to participatereceived no relief from normal enforcement
attention if it did elect to participate.Source: USEPA Reducing Risks Through Voluntary Action. Aurora and Carson
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Company Participation
EPA Outreach Focused on facilities reporting to TRI on any of the
17 targeted chemicals from 1988 - 1994. This pool of Companies numbered almost 20,000.
Initial communications were to CEO or parent companies.
EPA Invited 5,000 companies to participate in 1991. Subsequently invited 2,500 more over next three
years.Targeted outreach to the 600 companies with
greatest amount of releases and transfers to the environment.
33/50 Program: The Final record [Source: EPA-745-R-99-004]
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Company Participation
Approximately 1,300 signed agreements to participate (13% of all those targeted)
These 1,300 companies were responsible for 60% of releases and transfers of the 17 TRI chemicals targeted by 33/50.
1,066 companies set measurable goals for reducing their releases and transfers of the 17 targeted chemicals against the 1988 baselines.
These pledges totaled 370 million pounds, representing a little less than 1/2 of their total 1988 release and transfers of 778 million pounds.
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Flexibility in Goal Setting
Other companies developed goals: Tied to changes in their production levels By choosing alternative baseline years By setting reduction goals for all of their TRI reporting
without specific goals for the 33/50 chemicals. Choose pollution prevention to reduce their targeted
chemicals.
As a result: 370 million pounds of pledged reductions represent a
lower bound that companies attempted under 33/50 program.
33/50 Program: The Final record[Source: EPA-745-R-99-004]
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EPA Program Evaluation33/50 Program
Data is presented for three time periods1988 - 1990 : Captures information
before program began1990 - 1995 : Measures progress
during program tenure1995 -1996 : tracks development in
1988 - 1990: Releases and transfers of 33/50 program chemicals decreased by 16% while releases and transfers of non-33/50 chemicals decreased by 24%.
During 33/50 1990 - 1991: Releases and transfers of 33/50
chemicals decreased by 21%, while the releases and transfers of all TRI chemicals fell by 8 %.
One year after 33/50, reduction trend continues
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
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33/50 Program Results
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33/50 Program Results
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33/50 Program Results
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33/50 Program Results
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33/50 Program: Key Findings
The program achieved its goal in 1994, one year ahead of schedule
Largest reductions in 33/50 Program chemical emissions were driven by U.S. action to phase out ozone-depleting chemicals under the Montreal Protocol.
Facilities also reduced releases and transfers of the other 33/50 chemicals (excluding ozone depleters) by 50% from 1988 to 1995.
There is some indication that there have been shifts toward on-site treatment and releases to land and water away from air.
[Source: EPA-745-R-99-004]
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33/50 Program: Key Findings
Facilities reported more source reduction activity for 33/50 chemicals than for other TRI chemicals.
Activity covered a greater percentage of production-related waste for 33/50 chemicals than for other TRI chemicals.
Reductions continued at a higher rate for 33/50 chemicals than for other TRI chemicals in the year after the 33/50 Program ended
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Methods Used to Meet P2 Goals
Materials substitution is a very common method to reduce wastes and emissionsOlin has eliminated use of 1,1,1
trichloroethane (TCA) and dichloromethane used as degreasers by using an alkaline and hot water rinsing system.
DuPont is now using high pressure water for cleaning equipment in its fluroelastomer production facility.
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Methods Used to Meet P2 Goals
Recycling has become a frequently used means for managing wasteAllied signal installed a sulfuric acid
purification system and reduced waste by 250,000 lb/yr.
American Cyanamid designed a facility to recover sulfuric acid and other chemicals that they previously disposed of through deep-well injection.
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Another Look at Results
Of total reduction in releases of these 17 chemicals during 1988 - 1993, 40 % took place between 1988 and 1990 - before the program started.
Between 1991 and 1993 releases by participants fell by 41% and non-participants by 18%.
It is inappropriate to attribute all the reductions that occurred since 1991 to the 33/50 Program, according to the GAO, because some was achieved by non-participants.
Toxic Watch reports that 31 % of participants had achieved some reduction in release before 33/50 program. Firms that had already demonstrated reductions relative to 1988 baseline would be more likely to join.
Source: EPA’s 33/5- Program: Impact on Toxic Releases and Economic Performance of Firms Khanna/Damon
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Overview of the 33/50 Program
ConclusionCompanies emitting largest amounts of toxic
releases are most likely to take part in the program.Voluntary programs may work because they target
the companies with the greatest reduction potential.Public awareness plays a key role and can increase
participation by encouraging competition in environmental quality.
EPA should provide substantial public recognition and awards to firms achieving real reductions.
Source: Journal of Environmental Economics and Management 28, 271 -286 (1995)
