"A pollution prevention program involves developing and implementing a continuous strategy to address all waste generated by a facility and procedures for prioritizing and systematically reducing these wastes."
There is often general confusion among the terms pollution prevention program, plan and project. Many companies have compiled a list of projects and called the list a plan - such a list is not a plan. A pollution prevention program involves developing and implementing a continuous strategy to address all waste generated by a facility and procedures for prioritizing and systematically reducing these wastes. A pollution prevention plan is a written guide used to chart the progress of the program. It reiterates management support, lists reasons for the program, identifies the pollution prevention team, describes how waste will be characterized, provides a strategy and schedule for pollution prevention assessments, includes an evaluation of all costs incurred by producing and handling waste, institutes a cost allocation system, indicates how technology transfer will take place, addresses training needs, and discusses how the program and projects will be evaluated and implemented. The plan needs to be periodically updated to reflect the continuous nature of a pollution prevention program. Pollution prevention projects are the specific activities undertaken to reduce or eliminate waste.
In the chapters that follow, the steps to establish and maintain a pollution prevention program will be presented. These steps follow the elements (with limited modifications) outlined in U.S. EPA's 1992 publication, Facility Pollution Prevention Guide (EPA/600/R-92/088). Figure 1 illustrates the major steps in a pollution prevention program as described in this guidance manual. These steps include:
Figure 1: Elements of a Pollution Prevention Program
A. Establishing the pollution prevention program by obtaining support from top management, writing a policy statement, and building consensus within the company or facility.
B. Getting the program started by naming a task force, stating goals, increasing employee awareness and involvement, and training employees in pollution prevention.
C. Doing a preliminary assessment, including reviewing and describing in detail the manufacturing processes within the facility to determine the sources of waste generation and to define a baseline inventory to be used to set goals and evaluate progress; and establishing priorities for further assessment based on the results.
D. Writing the pollution prevention program plan.
E. Conducting a detailed assessment.
F. Identifying potential pollution prevention opportunities for the facility.
G. Determining all costs of current waste generation, management, and disposal, and establishing a system of proportional waste management charges for those departments that generate waste.
H. Selecting the best pollution prevention options for the company through feasibility analyses of technical, economic, and environmental considerations.
I. Writing an assessment report to describe results of the assessment and including the report in the program plan.
J. Implementing the pollution prevention plan, including selecting projects, obtaining funding, and installing projects
K. Measuring progress by evaluating the pollution prevention program on a company-wide or facility-wide basis as well as evaluating specific pollution prevention projects.
L. Maintaining and sustaining the pollution prevention program for continued growth and continued benefits to the company. Reevaluating the program as economic situations change and/or process equipment require upgrading.
The concepts presented in this manual are applicable to the reduction of all waste regardless of environmental media, quantity or toxicity. Some interpretation may be needed to make the suggestions usable by your specific business and facility.
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.