| Pollution
Prevention Planning
Developing
plans to prevent pollution can help any business reduce
waste and increase efficiency. Some companies are required
to plan.
The Minnesota Toxic Pollution
Prevention Act (TPPA) states that most companies submitting
an Environmental Protection Agency (EPA) Form R to the
Minnesota Emergency Planning and Community Right-to-Know
Act (EPCRA) Program must write plans for reducing the
emissions of Form R chemicals. Pollution prevention
plans are also required of companies participating in
the Minnesota Pollution Control Agency (MPCA) Environmental
Auditing (Green Star Award) Program.
Minnesota
Guide to Pollution Prevention Planning This guide
can help companies comply with the TPPA and develop
pollution prevention plans.
Using Your
Plan to Prevent Pollution
Develop an effective plan that has positive impact for
your company. Don't shortchange your company by writing
a pollution prevention plan that only meets the letter
of the law. Plans cost time and money to prepare. At
a minimum, options laid out in your plan should pay
for the cost of the planning process. Below are a few
tips on how to make the plan return value.
Basic Requirements
of a Plan
A pollution prevention plan must have the following
seven legal requirements in boxes below:
1. Policy Statement
| Develop a policy statement expressing
management support for eliminating or reducing the
generation or release of toxic chemicals (pollutants)
at the facility |
See a sample
policy statement.
Use the policy to set a measurable
goal that makes sense for your company and use these
overarching goals to set specific reduction objectives
for each chemical on your Form R. Don't end up with
a commendable philosophic statement that provides little
true guidance for employees.
Examples of goals to set in
your policy statement:
- Improve productivity/efficiency
to reduce scrap product and rework by 15 percent over
two years
- Reduce waste costs (costs related
to regulations, purchase, disposal, control) by 10
percent
- Reduce exposure to CHEMICAL X
- Eliminate Toxic Release Inventory
(TRI) chemicals and related reporting
Meeting these
kinds of goals will directly benefit companies. Reducing
chemical releases and transfers are natural outcomes
of meeting these kinds of goals. For example, a 15 percent
improvement in quality over two years will most likely
reduce TRI chemical releases by an amount proportional
to the volume of scrap product eliminated. For many
companies, the goals of improving quality and productivity
will give the greatest return.
Well-designed goals follow the SMART
approach. They are specific, measurable, acceptable,
realistic and timed.
2. Processes
| Describe the current processes
generating or releasing toxic chemicals (pollutants).
Specify the types, sources, and quantities of toxic
chemicals (pollutants) currently being generated
or released by the facility. |
Identify specific sources and causes
of waste. Don't just name a broad process step. Most
processes can be broken down into steps then substeps.
The substeps can help identify individual sources of
releases, or they can be evaluated for factors that
affect chemical use.
Some chemicals may be eliminated from
your facility by finding a substitute chemical. But,
reducing chemical volumes typically requires knowledge
of the specific, narrow causes of wastes or losses.
Once the specific causes are identified and considered,
potential solutions often become evident.
Flow
Chart
A flow chart/process flow diagram/process map can
be a useful tool for describing and understanding a
process. Process flow diagrams can help identify, prioritize
and document waste volumes and causes, or sources of
inefficiency and cost.
Start a flow chart by laying out a
process in general terms, with important inputs and
outputs. Then examine individual process steps in more
detail. Break them up into substeps with their inputs
and outputs. In some cases, substeps can be broken down
further.
Inputs and outputs for individual
operations or steps should be measured directly or carefully
estimated. Once process steps are described as finely
as possible, you should have identified process steps
causing the waste, release or loss.
Cause
& Effect Diagram
Next identify the specific sources of each waste or
loss for the operation by analyzing its root causes.
A cause and effect/fishbone diagram is a helpful tool.
It requires you to consider the major categories of
potential causes—people, materials, procedures
and equipment. Then propose solutions to be evaluated.
To keep the task manageable, you can
concentrate on the process steps you deem particularly
important or process steps that appear to have relatively
large waste streams. Keep in mind how the loses from
a process step compare to the total losses.
If the step you initially look at
turns out to be less significant than you thought, go
onto the next most important process step and examine
that.
3. List Options
| Write a description of the current
and past practices used to eliminate or reduce the
generation or release of toxic pollutants at the
facility and an evaluation of the effectiveness
of these practices. |
General
Pollution Prevention Options for Industry lists
a broad range of general pollution prevention options.
Some of these may fit your operations and serve as the
basis for setting a second policy goal.
4. Assess Options
| Assess the technically and economically
feasible options available to eliminate or reduce
the generation or release of toxic chemicals (pollutants)
at the facility, including options such as changing
the raw materials, operating techniques, equipment
and technology; personnel training; and other practices
used at the facility. |
5. Objectives
and Timeline
| State objectives and develop
a schedule for achieving those objectives. The TPPA
requires companies to express objectives in numeric
terms wherever technically and economically feasible.
Otherwise, non-numeric objectives can be stated;
however, they must include a clearly stated list
of actions designed to lead to establishing numeric
objectives as soon as they become feasible. Facility
pollution prevention plans must contain objectives
for each chemical for which a facility submits a
TRI Form R report. Pollution prevention plans may
also contain objectives for other chemicals as well.
Include the rationale for each objective established
for the facility. |
6. List Unfeasible
Options
| List options that were considered
but were not technically or economically feasible. |
7. Certification
| A certification, signed and dated
by the facility manager and an officer of the company,
attesting to the accuracy of the information in
the plan. Pollution prevention plans are required
to be updated by January 1st of every even numbered
year. |
See a sample
certification statement.
Working Document
The plan should function best as a working document
that organizes all the ideas and tracks the status of
them as they are evaluated and either discarded or implemented.
The following worksheets can be used to fulfill most
of the plan requirements.
Schedule
Use this form to list all ideas for reducing waste.
Include each waste stream covered by the plan. You may
also want to include each complex process step generating
a TRI chemical release. Track dates for completing:
- Initial reviews to determine if
the ideas are worth pursuing
- Evaluations of the technical and
economic feasibility of ideas deemed promising; and
- Implementation of feasible ideas.
Option
Tracking
For each option seriously considered, use this form
to record the expected results and the actual outcomes.
Information on this form can be used to identify and
solve implementation or operational problems. Good tracking
can help you understand if a past failed attempt can
be turned into a promising new option (i.e., improvements
in wood finishes now make them acceptable in your application).
Use one form for each idea reviewed.
Once the pollution prevention plan
is in place, the above forms can be used to easily track
pollution practices as well as options that are deemed
impractical. Keeping this information organized can
later help you blow your own horn about successes and
avoid covering old ground.
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