1994 Pollution Prevention Report - Appendix E
DEQ Pollution Prevention Implementation Plan, Survey and Survey Summary

1. Background

The DEQ Pollution Prevention Implementation Plan has been developed consistent with the goal of promoting pollution prevention included in the agency's operating principles and in the 1993 pollution prevention legislation adopted by the Virginia General Assembly.

This plan is intended to be a dynamic document that will be revised over time as Department experience with pollution prevention develops. Key to the success of the plan is effective communication among agency staff, and a significant portion of the plan will focus on developing and fostering methods of communication.

2. Roles and Responsibilities

Although the Office of Pollution Prevention, within the Division of Policy and Research, has primary responsibility for promoting pollution prevention concepts, all programs within the agency have agreed that they must be involved for the plan to be successful. Specific roles and responsibilities of agency programs are identified below:

A. Office Of Pollution Prevention

• Establish and support internal DEQ Pollution Prevention Workgroup consisting of representatives of key headquarters programs and all regional offices
  
• Develop and maintain methods of regular communication for agency staff in general and the internal DEQ Pollution Prevention Workgroup in particular
  
• Assist in the development and delivery of training for agency staff
  
• Provide information and research in response to staff inquiries
  
• Provide to and receive from staff of Public Affairs advice and assistance in the development of outreach materials such as videotapes, posters, brochures, etc.
  
• Provide to and receive from staff of Public Affairs advice and assistance in conference and workshop planning
  
• Work with the Human Resources staff to investigate opportunities to incorporate pollution prevention concepts within position descriptions
  
• Staff the external Pollution Prevention Advisory Committee

B. Training Office

• Designate staff representative to serve on the internal DEQ Pollution Prevention Workgroup
  
• Work with the Human Resources staff to investigate opportunities to incorporate pollution prevention concepts within position descriptions
  
• Work cooperatively with Office of Pollution Prevention staff in developing training programs on pollution prevention

C. Human Resources

• Designate staff representative to serve on the internal DEQ Pollution Prevention Workgroup
  
• Investigate methods to incorporate pollution prevention concepts within position descriptions

D. Operations

• Designate staff representatives from enforcement, permitting and inspections programs (including regional offices) to serve on the internal DEQ Pollution Prevention Workgroup
  
• Work with the Human Resources staff to investigate opportunities to incorporate pollution prevention concepts within position descriptions
  
• Promote the Department's pollution prevention services

E. Public Affairs

• Designate staff representative to serve on the internal DEQ Pollution Prevention Workgroup
  
• Work cooperatively with Office of Pollution Prevention staff to develop a newsletter to communicate information on pollution prevention
  
• Provide to and receive from the Office of Pollution Prevention advice and assistance in the development of outreach materials such as videotapes, posters, brochures, etc.
  
• Work with the Human Resources staff to investigate opportunities to incorporate pollution prevention concepts within position descriptions
  
• Provide to and receive from the Office of Pollution Prevention advice and assistance in conference and workshop planning

F. Intergovernmental Affairs

• Designate staff representative to serve on the internal DEQ Pollution Prevention Workgroup
  
• Promote the Department's pollution prevention services
  
• Encourage state agencies to adopt pollution prevention strategies
  
• Work with the Human Resources staff to investigate opportunities to incorporate pollution prevention concepts within position descriptions

G. Procurement

• Designate staff representative to serve on the internal DEQ Pollution Prevention Workgroup
  
• Work with the Office of Pollution Prevention to make available to agency staff information on less hazardous products
  
• Work with the Human Resources staff to investigate opportunities to incorporate pollution prevention concepts within position descriptions

H. Permit Assistance

• Designate staff representative to serve on the internal DEQ Pollution Prevention Workgroup
  
• Work with the Office of Pollution Prevention to make pollution prevention information available to small businesses
  
• Work with the Human Resources staff to investigate opportunities to incorporate pollution prevention concepts within position descriptions

3. Specific Plan Activities

The DEQ Pollution Prevention Implementation Plan will be undertaken through a series of steps involving an assessment of current activities, the development of pilot projects and the development of policies, guidance and training modules based on the outcomes of the pilot projects. Plan progress will be continually evaluated, and adjustments in the implementation plan will be made accordingly.

Steps:

1. Organizational meeting of the internal DEQ Pollution Prevention Workgroup, consisting of representatives of key headquarters programs and regional offices, to discuss implementation of the plan. A survey will developed by the OPP staff to assess the level of knowledge about pollution prevention and the current status of pollution prevention activities within the agency will be reviewed by the Workgroup. The survey will solicit ideas for pollution prevention pilot projects. Program areas as well as individual staff to be surveyed will be identified. (April)

2. Assessment of the current status of pollution prevention activities within Operations and other areas conducted through a survey of program managers and other key staff. The survey will be sent to approximately 100-150 employees for completion. A series of follow-up face-to-face interviews will be conducted with a smaller number of staff by OPP staff to explore issues raised in the survey responses. Responses will be processed, analyzed and summarized. (April/May)

3. As necessary, agency management will outline the importance and relevance of pollution prevention to the agency mission. The memo will also introduce or reinforce the awareness of the Office of Pollution Prevention's services. Also, the memo will explain the process that has been developed to begin institutionalizing pollution prevention within the agency. Members of the internal DEQ Pollution Prevention Workgroup will be listed as contacts for agency staff. (April)

4. List of potential pilot projects within the program areas of permitting, inspections, enforcement, administration and training identified by Workgroup. Plans for each of the projects selected will be drafted for review by senior agency management. The external Pollution Prevention Advisory Committee will be briefed on the pilot projects identified. (Summer)

5. Implementation of pilot projects. (Fall)

6. Development of policies, guidance and training modules based on successes and difficulties identified through the pilot projects. The external Pollution Prevention Advisory Committee will be briefed on the policies, guidance and training modules. (Winter, 1995)

7. Implementation of policies, guidance and training modules. (Ongoing basis, beginning Winter/Spring, 1995)

8. Regular follow up and examination of policies, guidance and training modules to determine where revisions or further studies are needed. The Pollution Prevention Advisory Committee will make recommendations to the agency on future directions.

DEQ Pollution Prevention Survey
April 20, 1994

In 1993, the General Assembly passed legislation establishing pollution prevention as the environmental management strategy of choice for the Commonwealth, similar to the action taken by Congress in 1990 with the federal Pollution Prevention Act. Definitions of pollution prevention vary. In the Virginia law, pollution prevention is defined as "eliminating or reducing the use, generation or release at the source of environmental waste."

Source reduction is the "first" step in the environmental management hierarchy. As outlined in both the national and Virginia laws, source reduction or pollution prevention is the preferred approach.

Source Reduction Recycle/Reuse Treatment Disposal/Environmental Release

However, wastes that cannot be eliminated should be managed in the following order of preference: recycle/reuse; treatment; disposal/environmental release. The Department has programs that focus on each of these management techniques.

Examples of pollution prevention techniques listed in Virginia's law include, "equipment or technology modifications; process or procedure modifications; reformulation or redesign of products; substitution of raw materials; improvements in housekeeping, maintenance, training, or inventory control; and closed-loop recycling, on-site process-related recycling, reuse or extended use of any material utilizing equipment or methods which are an integral part of a production process."

Consistent with the agency's operating principles, pollution prevention should be an integral aspect of every agency program. In order to accomplish this, a DEQ Pollution Prevention Implementation Plan has been developed by the DEQ Pollution Prevention Workgroup (which consists of representatives from a variety of agency programs). The Workgroup is interested in all types of pollution prevention, from its use in permits, enforcement settlements and inspection protocols to its use in procurement to the prevalence of office waste reduction techniques (e.g., double-sided copying, use of electronic mail, etc.).

The attached survey, which represents the first phase of the implementation plan, is designed to assess the level of knowledge about pollution prevention and the current status of pollution prevention activities within the agency. It is being sent to approximately 80 Department employees. As a follow-up, a smaller number of agency staff will be interviewed next month to explore issues raised in the survey responses. Once this process is complete, there will be an opportunity for all Department staff to provide input.

Based on the results of the survey responses and interviews, a number of pilot projects that incorporate pollution prevention will be developed for implementation during late 1994 and early 1995. Lessons learned from the pilot projects will be incorporated into agency policies and guidance to be developed next winter.

Based on the implementation process outlined above, it is clear that assessing the current status of pollution prevention implementation and knowledge is critical to the success of our efforts. Similarly, the cooperation of the entire agency will be required to make pollution prevention a reality within the agency.

Thanks in advance for your cooperation. If you have any questions, or would prefer to discuss your responses face-to-face rather than put them in writing, please contact any of the DEQ Pollution Prevention Workgroup members listed below.

Please complete the questions below and return by Tuesday, May 10 to:

Sharon K. Baxter
Office of Pollution Prevention
629 East Main Street (7th Floor)
Richmond
(804) 762-4346 (fax).

If you are a Regional Director, please discuss the questions with your staff and respond as an office (differing opinions can be included -- consensus is not required).

Name:
Phone:
Program:
Yes	No	1.	Are you familiar with DEQ's Office of Pollution Prevention and the services it offers? If yes, how and when were you made aware of the program?
Yes	No	2.	Have you seen the Pollution Prevention Virginia newsletter?
Yes	No		Do you think it is a good communication mechanism?
Yes	No		Are there additional ways to update staff on Office of Pollution Prevention activities?
Yes	No	3.	Have you come across or initiated any efforts to encourage pollution prevention within the Department's general office activities such as reducing paper waste or conserving energy? If yes, briefly describe.
		4.	If you are not within Operations, please skip to question 5. Have you:
Yes	No		a. Read any technical reports on pollution prevention that were helpful in your current position?
Yes	No		b. Discussed and/or implemented pollution prevention options with the public (e.g., industry, local governments, state agencies, citizens, etc.)? (If yes, please attach relevant documentation such as memos, reports, etc.)
Yes	No		c. Noticed more interest in pollution prevention from the regulated community?
		5.	a. What opportunities (e.g., revision of policies and manuals) can you think of to incorporate pollution prevention into the Department's daily operations (including both external and internal activities)? This may include opportunities related to procurement, agency administration, inspections, permitting, enforcement actions, etc. b. Similarly, are you aware of a specific situation (e.g., agency procurement action, inspection, permit or enforcement settlement) pending or expected within the next few months that may be a good candidate for a pilot pollution prevention project (e.g., ABC Chemical is expected to submit a permit application in September that you expect may present pollution prevention opportunities, the Department will be procuring a certain type of office supply that may be available in a more "environmentally friendly" form than is normally purchased, etc.)
		6.	a. Do you think that there is a good general understanding of pollution prevention consistent with Virginia's definition (included in the attached memo):
			Poor Adequate Excellent
			Among the regulated community?	1 2 3 4 5 6 7 8 9 10
			Within the Department?	1 2 3 4 5 6 7 8 9 10
			Within your Division?	1 2 3 4 5 6 7 8 9 10
			b. How can the awareness of pollution prevention concepts throughout the agency be improved or reinforced?
		7.	a. What difficulties could you anticipate to incorporating pollution prevention concepts within the agency?
			b. In what ways could these be overcome?
Yes	No	8.	Have you had specific training in pollution prevention? If not, what type of pollution prevention training are you interested in receiving?
		9.	What types of pollution prevention information would be helpful to your program or office staff (e.g., reports, factsheets, contacts within other states, etc.)?

Summary of DEQ Survey Results

The DEQ Pollution Prevention Integration Survey was distributed selectively in Spring, 1994 to 80 staff members who were determined to have a potentially significant impact on the integration of the pollution prevention concept throughout the agency. OPP received an excellent response, with 78 surveys tabulated and compiled. For a detailed compilation of responses, please consult with OPP staff for a copy.

DEQ staff determined that the best ways to integrate pollution prevention in the agency are as follows:

• Policy from the Director should require strategic planning and the incorporation of pollution prevention in all staff functions, and peer leadership should show that it is encouraged, expected, and demanded

• OPP should provide additional education/training that discusses how to implement pollution prevention strategies throughout agency activities (i.e., concrete examples on how to carry out pollution prevention as an agency)

• OPP should increase communication about pollution prevention activities and new pollution prevention developments throughout DEQ -- via E- mail, newsletter, fact sheets, success stories, and videos

• DEQ should create a policy that requires all of its offices to reduce paper and energy consumption, which would serve as an appropriate model of environmental conservation for the community-at-large.

Survey respondents also noted that paper reduction and energy conservation are the best ways to practice pollution prevention in their office operations and should be standard procedure, considering that DEQ should serve as a model for other agencies in protecting the environment. The survey was also designed to assess the current level of understanding and practice of pollution prevention in DEQ; survey responses suggested moderate levels of knowledge of the pollution prevention ethic in the Department and the regulated community.

Return to 1994 Pollution Prevention Report index

Go to Appendix F