"To keep ahead of the many environmental and economic challenges that face us in the 1990s, Ohio must focus on pollution prevention. Global competition and the public's demand for environmental protection require that business be as efficient and produce as little waste as possible."
Donald R. Schregardus, Director, Ohio EPA
Why is pollution prevention planning essential for the State of Ohio? Ohio companies and governments generate large amounts of waste, as illustrated in brief summary below, "Waste Generation in Ohio." These wastes discharged to our air, water or land represent a significant loss of raw materials and a potential threat to human health and the environment. To be responsible guardians of environmental quality, waste generators must review their production processes and operations as well as consider both the economic and the environmental benefits of implementing a pollution prevention program. The public, consumers and employees expect simultaneous attention to both economics and the environment. Pollution prevention is an excellent way to satisfy this demand.
Waste Generation in Ohio 2.9 million tons of hazardous waste generated in 1991 |
Adopting a pollution prevention program as a way of doing business can provide a number of significant benefits to a company. By decreasing the amount of waste generated or released, a company can reduce waste disposal costs, improve worker safety, and reduce long-term liability. In addition, pollution prevention methods may increase the efficiency of the production line and decrease costs associated with the purchase of raw materials, inventory control, etc. Any resulting changes in efficiency or expenditures may help the company to retain or improve its competitiveness in the marketplace.
Companies have traditionally evaluated their industrial processes in terms of optimizing their production, but times have changed. Due to increasing environmental concerns associated with industrial waste, companies must now incorporate waste management and prevention strategies into their production lines with the goal of reducing waste generation. By increasing efficiency of operation, companies can see that more of their raw materials go into products rather than ending up as waste.
Donald R. Schregardus, Director of the Ohio EPA, emphasizes that, "To keep ahead of the many environmental and economic challenges that face us in the 1990's, Ohio must focus on pollution prevention. Global competition and the public's demand for environmental protection require that business be as efficient and produce as little waste as possible." Ohio is also working to reach the national goal for environmental protection - to reduce or eliminate waste at its source - as established by the Pollution Prevention Act of 1990 (see Chapter 4).
This guidance manual is a general overview of how Ohio businesses and government facilities can develop and implement a pollution prevention program. The manual uses the pollution prevention program steps (with limited modifications) outlined in U.S. EPA's 1992 publication, Facility Pollution Prevention Guide (EPA/600/R-92/088). (Table C-3 in Appendix C compares the elements of U.S. EPA's and the State of Ohio's guidance for developing a program). These steps include planning and organization, assessment, feasibility analysis, implementation, and measuring progress. The manual also uses substantial portions of the text from the Illinois Hazardous Waste Research and Information Center's 1993 publication, Pollution Prevention: A Guide to Program Implementation.
On September 1, 1993, Governor George V. Voinovich requested the top 100 Toxic Release Inventory (TRI) reporters in Ohio to work with Ohio EPA on developing comprehensive pollution prevention plans to reduce the various types of waste they generate. As Ohio EPA Director Donald R. Schregardus emphasized, "This is not just a paperwork exercise. The real goal is not the plan, it's the reduction." |
This document was prepared under a federal fiscal year 1993 RCRA grant from U.S. EPA to Ohio EPA, Division of Hazardous Waste Management, and the Office of Pollution Prevention, for Great Lakes Basin activities. The original intent of this guidance manual was to provide waste minimization planning guidelines (1) for class I injection well facilities and (2) for hazardous waste treatment, storage, and disposal facilities. Class I injection well facilities have a statutory requirement to prepare and adopt a waste minimization and treatment plan, including several general requirements for plan content. Hazardous waste facilities are required by Ohio permits to submit a report describing their waste minimization program. Specific requirements for these types of facilities are slightly different; however, Ohio EPA does not want to create different pollution prevention and waste minimization planning guidance manuals for each regulated category of business nor for each environmental medium. This general guidance manual provides a common approach for pollution prevention planning in Ohio for all waste generators and for all media. This manual can be used by any organization, including businesses and state and local government organizations. For brevity the words "company" and "business" are used throughout the manual, but any organization's title can be substituted for these terms.
Because this manual is a generalized overview of how to develop and implement a pollution prevention program, you will want to modify the program as needed to fit your facility.
Specific requirements for class I injection well facilities and hazardous waste treatment, storage, and disposal facilities are included as appendices.
For more detailed information about pollution prevention programs, refer to U.S. EPA's Facility Pollution Prevention Guide and to the reference section in the appendices of this guidance manual. U.S. EPA's Facility Pollution Prevention Guide contains worksheets that may be helpful in implementing and documenting a pollution prevention program. Another general reference document is U.S. EPA's 1993 Reference Guide to Pollution Prevention Resources (EPA/742/B-93/001). This annual guide contains information about publicly sponsored pollution prevention resources and training opportunities. The document consolidates a wide range of pollution prevention information. Contact the Ohio EPA's Office of Pollution Prevention for copies of these documents and a list of additional references.
Purpose of the Guidance ManualThis guidance manual is intended to increase the amount and improve the quality of activity in pollution prevention planning in Ohio. It will help companies to compare their pollution prevention programs to the State of Ohio's goals. The State of Ohio, including Ohio EPA, does not intend to enforce the letter of this manual to determine what should be included in a pollution prevention plan or program. Ohio EPA does not intend to issue related checklists for inspection and enforcement. However, we do expect that all pollution prevention programs and plans will have significant substantive content, include the general components covered in this manual where appropriate, and clearly meet the spirit of this guidance and any applicable law. We do expect that programs and plans include efforts and substance comparable to the general headings of Table C-3 in Appendix C of this document, e.g., "Establish the pollution prevention program." We do not expect to require subsections, e.g., "Executive level decision; Policy statement;" following the exact content of Table C-3. |