Index to the Report af the Pollution Prevention Blue Ribbon Panel

I. Letter from the Panel

11.

111.

IV.

V.

VI. Attachments

Panel M ~ ~ X F S and Other Participants

Majority Report of the Blue Ribbon Panel

Minority Report of the Blue Ribbon Panel

Flow Chart for a Future Model of P2 regulation

I. Letter from the Panel

June 25- 1999

Robert Durand, Secretary Executive Office of Environmental Affairs 100 Cambridge Street Boston. MA 02022

Dear Secret- Durand: -

The Pollution Prevention Blue Ribbon Panel hereby transmits its final report for your consideration. The panel was charged by Secretary Coxe With examining state govemment’s ability to promote pollution prevention and to examine the Toxics Use Reduction Act’s role in this.

The enclosed report contains a set of agreed principles and a series of proposals for an evolving pollution prevention program for Massachusetts. The recommendations contain core values for pollution prevention - a combination of compliance and assistance programs. The report also includes a minority report, which suggests an alternative analysis and program for pollution prevention than the majority report.

A broad, meaningful, and effective pollution prevention program will require changes to TURA and other current laws and even new laws. It is our understanding that you will be developing proposals for such statutory changes. We hope that you will keep the Panel members apprised your work and look to us as a sounding board for change.

Finally, we would like to acknowledge thank Gina McCarthy for her work in chairing and coordinating the Panel’s deliberations.

Sincerely,

The members of the Pollution Prevention Blue Ribbon Panel (signatures attached).

Paul Bums MASSPXRG

t l L , R6bertRuddock

Associated Industries of lb€assachusctts

Physicians for Social RnponaibiEty

/ Environmental League of Massachusetts /

%incr Environmental

Northtasr Utilties

Silent Sprirqj k t i t u l c

P a l k i d Corporation __

11. Panel Members and Other Participants

P2 PANEL

Robert Chatcl Gary Siege1 I’aul L3urris I irn (ireiner

I larry !.’akin 1iobe1-1 Ruddock R u t h Polk

..

f’A RTl C1 P A NTS: I

Robcr-t \<io ’l‘ara Szvincliatt ’

Matthcw Goldinan Jody I,clircr

’ Micliael Ellenbeckcr lhrbara Kwclz James Colnian Iticliard Dizzozero 1.L I larriman

Aiinc 1;itzgerald (Facilita\or)

‘Ihe Fiobbins Company ENSR MASSPI RG Greiner Environmental

I

Associated Industries of Massachusetts Si leri t Spring Institute

Associated Industries of Massachusetts Northeast Utilities Environmental Regulatory Affairs Roy F. Weston, Inc. liep. Douglas Peterson’s Office

UMASS Toxics Use Redt. Institute Dept. of Environmental Protection Dept. of Environmental Protection Office of Technical Assistance ‘I’UKI Exec. Office of Environmental Affairs

An IC Fitzgcrald & Associates 1

Ted Schetler Ken Geiser Julia Brody Silent Spring institute James Gomes Stephen Greene Polaroid H.L. Chamberlain

Physicians for Social Responsibility

Environmental League of Mass

Northeast Utilities - Environmental Scrviccs

Kevin Costas Ed Surette Global Environmental Service

Department of Pubic Health

Tim Ilawes Polaroid Corporation

Cynthia Chaves William Panos Barbara Kelley Rick Reibstein

Dept. of Environniental Protection Dept. of Environmental Protection Office of Technical Assistance Office of Technical Assistance

Jody flensley TURI

111. Majority Report of the Blue Ribbon Panel

&lay 17, 1999

The Pollution Prevention Blue Ribbon Pane] is a group of srakeholders called together by the Secretary of EnL+ronmental Affairs to provide r e c ~ m e n d a t i o n s on the htux of pollution prevention (P2) ~EOITS in Massachusetts, including the state's Toxics Yjse Reduction Act

L

(nrR4). - -

Panel Members and participants included representatives of business, environmental, public health, academic and c c m " m t y interests. (See attached list.)

THE PANEL'S GOAL - A NEW STATUTE

During a series of 1 1 meetings held benveen September 1998 and March 1999, the Panel sought to develop recommendations for a new statute that would learn from and build upon the past efforts of government, the private sector and the public, to promote and reward continuous environmental improvement. Continuous environmenta! improvement was defmed as improved environmental performance and increased eficiency achieved through the periodic review and implementation of strategies to prevent pollution and conserve resources.

The new statute was envisioned to include both improvements to existing regulations to promote the prevention of pollution and resource conservation, as well as the development of a non- regulatory initiative to encourage improved environmental performance and increased efficiency.

AIM MINORITY REPORT

Strong differences of opinion among the Panel members precluded the development of a consensus document describing t h i s new Sumte. Representatives from Associated Industries of Massachusetts (AIM) and Polaroid Corporation disagreed with the other Panel members, including other business representatives, about the continuation of mandatory reporting of right- to-know data, Le. total chemical use and byproduct data currently required under TURA. For that reason, AIM chose to submit a minority report, a copy of which is attached.

THE FINAL REPORT

From this point forward, this final report represents the consensus opinion of all Panel members and participants with the exception of representatives of P J M and Polaroid Corporation.

1

0 Regularop Ini~atives: To refocus regulatory effons so that all sources of environmenLd impact CDolluters and resource users as well as conwinants ) are efYectivel1. regulated in ua)*s Lvhich maximiz? opportunities to meet and exceed compliance uith environmental regulatory standards through the prevention of pol jution and theconservation of resources, i.e. in bvays that protect public heal&, worker health and the environment as well promote sustained compliance. I t was understood that regulator)' I agencies such as the Departments of Environmental Protection and Public Health, as well as the Bureau of Labor and Workforce Development. must be involved in the development and implementarion of such a strategy to effecrivel). address issues related 10 public health, environmental health, and worker hedth

-

and s a f q .

0 Non-ReplatoryNo1untai-y Initiatives - To create a new system which would allow entities in substantid, continuous regulatory compliance, to szf f-identify as having achieved, or agreeing to strive for, improved performance and efilciency beyond that required by the existing regulatory system. Opportunities to receive incentives and rewards would be provided to those compliant entities which self-identify, in exchange for reliable and verifiable public reporting of environmental improvement indicators. It was understood that such a system would be designed to allow regulators to focus increasing attention on non- compliant entities.

Two Strategies - One Package

Panel members varied on the amount of interest and emphasis they placed on the two strategies which would underlie this proposed new statute. Panel members representing the environmental and public health constituencies focused more attention on the first tool (regulatory) while Panel members representing the business c~~mmyni ty focused more attention on the second (non- regulatory). I t was understood by all Panel members that no agreement was asked for, or could be reached, on one strategy or the other. Rather, any changes discussed to existing regulations were viewed as part of a comprehensive package which included proposals to create a new voluntary sysrem to reward increased performance and efficiency. Likewise, any discussion of the Start-up Of a new voluntary system to reward continuous environmental improvement W a s

inextricably linked to changes to existing regulations - forming a comprehensive package.

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Common Understanding Underlying the h e w Statute

The Panel identified a number of common understandings that should form the underl!ky principles of tl-us new statute:

Preventing pollution and conserving resources enhance the protection of the public health. worker health and the environment while supporting the competitiveness of hlassachusens businesses.

U X l e regulatory compliance may be achieved through end-of-pipe controls. preventing pollution and conserving resources are key steps towards, and key measures of, achieving compliance in a manner which enables continuous environmental improvement and provides the basis for sustainable economic and environmental decision-making.

Efforts must be undertaken (regulatory and/or non-regulatory) to enhance our current environmental protection efforts, including:

- The removal of regulatory baniers to the prevention of pollution and the conservation of resources, for example, addressing regulatory “Catch 22’s” which stifle the use of zero discharge technologies and, where appropriate, shifting regulatory standards from maximum discharge limits to total daily loadings;

through efforts like DEP’s INFO 2001;

(polluters and resource users) that have not been the focus of traditional regulatory compliance and enforcement efforts, i.e. universities, research facilit‘ies, hospitals, municipalities/state agencies, the agricultural sector, pesticide applicators, transportation-related entities and small businesses;

such substantial risk to public health, worker health and the environment, that increased scrutiny and challenge (such as lowered reporting thresholds) on their use, discharge and release is warranted;

in which regulations push andor pull changes in behavior; and

and private (TUR Planners).

- The streamlining of paperwork, in particular electronic reporting and permitting,

Increased attention on significant potential sources of environmental impact -

- Increased attention on specific high-risk contaminants, i.e. chemicals which pose

- Increased flexibility in the ways in which entities may be regulated and the ways

Increased provision of technical assistance sentices, both state (OTA/TURI/DEP) -

TUR Planners have a critical role to play - both in the regulatory and non-regulatory initiatives. TUR Planners could provide continued certification and technical guidance of pollution prevention and environmental improvement efforts. TUR Planners afe also potential resources for firms that choose to take advantage of the non-regulatory initiatives.

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e T i e public nas a right to know information needed 10 assess impacts on public htt3ldnl. i t orkc: health and the eni.ironment. including data on chemical use. waste generation. releases arid emissions.

e Businesses have a right to protect from public d~scloscr:: mformation that will, if made public. reveal a trade secret. In addition, re_eu]atoq. agencies must deselop clear policies for the public disclosure of information they collect which is not directly related to regulatory compliance and xjll. if made public. compromise competitiveness.

0 Information the public has a right-to-knoLv. and information businesses need to h o w to promote and track their continuous environmental improvement, are two separate but overlapping data sets. While the information the state and publicneed to know to determine compliance must be consistent. comparable. uniform and transparent; information needed to measure continuous environmental improvement must be flexible enough to meaninghlf y assess improvements in specific behaviors, activities or locations.

e All parts of society share responsibility for protecting public health, worker health and the environment and for conserving resources. Therefore all sources of environmental impact are expected to manage their activities in an environmentally sound manner and should be encouraged, and even rewarded, to seek continuous environmental improvement by preventing pollution and conserving resources.

0 There should be many ways in which the different parts of society (or entities) are regulated and/or encouraged to achieve continuous environmental improvement in recognition of the differing levels of environmental performance among and within the various p q s .

Efforts to prevent pollution and to conserve resources require that public health, worker health and environmental protection be considered in a comprehensive manner. Such a holistic approach challenges the bureaucratic divisions that the existing single media, end-of- pipe laws have created. Cooperation between currently separate agencies such as EPA, EOEA, DEP, DPH, DOE, DOER, BLWD and OSHA is therefore needed to avoid duplication of efforts, to streamline the interaction needed between government and entities, and to ensure that behavior is not encouraged which simply shifts, rather than reduces, risk.

0

e Managing waste in a sound manner to ensure conformance with regulatory requirements is behavior expected of all entities and the focus of compliance and enforcement efforts to ensure a "level playing field". Regulatory agencies should continue to focus their resources on the enforcement of mandatory public health, worker health and environmental standards while recognizing the importance of promoting poIlution prevention and resource conservation as sustainable compliance strategies.

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A new system should be put in place to allow entities that are verifiabiy in subsrm:n!. continuous compliance. to self-identifi as having achieved. or committing to. impro\.ed performance and increased efficiency. Such a system should oger incenti\,es and ma! offer rewards in exchanse for publicly available reporting Lvhich verifies progress in continuous environmend improvement. A separate entit). should be creared by the participating regulator). agencies to evaluate, monitor and potenrially reward the continuous environmental improvement of entities that self-identifi.

The existing regulatov system and any nev. system designed to promote continuous environmental improvement should seek to encourage behavior in accordance filth the conventional hierarchy of environmentally preferred management of pollution. Specificall). this means:; -

Where possible, pollution should be prevented at thesource through source reduction activities, including c the techniques identified as toxics use reduction in TURA as well as resource conservation;

through environmentally sound off-site recycling; and

site recycling should be managed through environmentally protective treatment and disposal.

- Pollution that cannot be effectively reduced at the source should be managed

Pollution that cannot be reduced at the source or effectively managed through off- -

The New Statute - Regulatory Initiatives

The new statute must refocus regulatory efforts to ensure that all sources of environmental impact (universes as well as contaminants) are effcctively regulated in ways which maximize opportunities to meet and exceed compliance with environmental regulatory standkds through the prevention of pollution and the conservation of resources, i.e. in ways that promote sustained compliance. (See left side of attached chart.) To that end, the Panel reached the following understandings:

Efforts such as DEP's Environmental Results Program are potentially excellent opportunities to regulate small businesses more effectively and to promote pollution prevention as a means of lowering their potential environmental impact.

Efforts such as DEP's INFO 200 1 are.excellent opportunities to examine the data collected by DEP to ensure that the government and the public have access to environmental data and compliance information and indicators that are transparent enough and rigorous enough to assure that public health, worker health and environmental protection are not endangered, Le. that entities continue to be in substantial and consistent compliance with the existing regulatory system. INFO 2001 is also an excellent opportunity to streamline unnecessary paperwork and eliminate duplicative reporting.

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0 T h e public reponing of right to know data (1.e. marenals trarking data on chemicai use. product and non-product output which supplements data on releases and emissions) is a critical first steps towards the development of effective strategies to move beyond regularor! compliance towards improved environmental and economic decision-making.

The follouing changes should be made to the existing regulatop suucwe taking into consideration the list deLreloped by the TURA Science Advisor?’ Board of the high hazard and low hazard chemicals currently reported in Massachusetts: lower reponing and planning thresholds and increase fees associated with the use of high hazard chemicals; and reduce the requirements and fees associated with the use of low hazard chemicals.

0

0 Efforts to strEamIine ?zrRrz reporting by eliminating BRI and EBI - calculations should be pursued vrhile consideration is given to alternative means of measuring progress at the faciiity and state levels.

0 While it was understood that data on process level chemical use and non-product output was needed to track and to challenge continuous environmental improvement, consideration should be given to eliminating mandatory annual reporting of process level data.

0 Some form of planning, i.e. a periodic review of opportunities to prevent poIlution and reduce resource use, was beneficial for all entities and should be continued.

0 The existing TUR4 planning requirements should be made more flexible, e.g. to allow entities that see diminishing returns from their planning efforts to plan less frequently andor to refocus their planning efforts on other areas of potential environmental impact, such as energy, water, and solid waste.

The New Statute - Non-Regulatory Initiatives

To new statute must create a voluntary system to allow entities that are in substantial, continuous regulatory compliance, to self-identify as having achieved or agreeing to strive for, performance beyond that required by the existing regulatory system. Opportunities to receive incentives and rewards would be provided to the self-identified entities in exchange for reliable and verifiable public reporting of environmental improvement indicators. It was understood that such a system would be designed to allow regulators to focus increasing attention on non-compliant entities. (See right side of attached chart.) Here are some of the guidelines for this new system:

__

DEP must define what is meant by substantial, continuous regulatory compliance and issue guidelines that will aIlow entities to understand what is required for eligibility into this voluntary system and to enable TUR Planners, other third-party verifiers (OTA or private consultants), and/or DEP to determine eligibility status.

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0 Entities in substantial. consistent compliance with the existing regularop s ~ s ~ e m nili be allowed to self-identifi as having already acheved, or strivinz 10 achieve. continuous emironmental improvement. These self-identified entities would pas. a fee to be eiigibie for ;1 variety of incentives and rewards in exchange for public reporting OF environmental improvement indicators.

0 W-hile DEP would continue to determine regulatory compliance. a new independent body of stakeholders. with DEP representation. would establish indicarors, requirements and rewards for this neu system. as weli as monitor performance and oversee the delivery of technical assistance. research and other services and rewards.

0 Publicly repcrted indicators must reflect the fact that the entity isnot - only in compliance but also has in place a systematic. effective process to promote continuous environmental improvement - a process which identifies and evaluates opportunities to maximize the efficient use of resources, including needed chemicals. please see for example, the attached proposals which track other on-going initiatives to measure corporate performance, such as IS0 14000 and the Sustainable Reporting Guidelines being developed as part of the Global Reporting Initiative. as well as other specific sector-by-sector indicators.] The extent and aggressiveness of this process is expected to vary according to sector, size and level of environmental performance.

Potential areas to be measured in a set of core indicators include: energy use; transportation; building heating/cooling; water - quality and quantity; releases (TRI); waste (including solid); non-product output; chemical and material use (materials accounting); worker, public health and safety such as chemical exposure or hazard; product hazards, elements of environmental management systems (EMS); product stewardship; design for the environment; and chemical exposures.

Q Economically normalized data is critical as an indicator of continuous improvement, and self- verifying (mass balance based on materials accounting data) or third-party verified information is needed in order for entities to be eligible for certain incentives. It was understood that indicators of sustainability generally include environmental, economic and social indicators, but it was unlikely that social indicators would be proposed at this time.

0 Indicators should be stable over time arid include normalized and absolute (raw) data. Appropriate discretion must be used when considering "internal" (entity) indicators vs. external" ('publicly reported) indicators. There must be an appropriate balance between "one- size fits all" and entity-specific indicators. Indicators must be comprised of both operational and management indicators. Other factors to consider when selecting indicators include: relevance, reliability, understandability, comparability; timeliness, verifiability, and appropriateness to the goal of improved environmental performance.

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* Benefits could include financial incentives such as grants. low inreresr guaranteed loanj. reduced filing fees and tax credits: as well as access to techrucal assistance sen.ices such 3s

new technolog. validation. OTA on-site semices, peer-to-peer consulrrition (addressins the neo? for liabiliy relief). assistance v;ith the development of cost accounring or marenais t rzx ing systems, and TUN research assistance. education, training or iaborsrors. senices.

Benefits might also include positive public reco_pnition including th:: possibility of Green Star, preferred purchasing Nith state agencies and public service announcements.

Benefits could also include regulatory flexibilie in reporting, self-permitting soft landings (i.e. a grace period without penalties to ny a new technology), and assistance ~ . l t h federal regulations iiicI uding advocacy or helping to building working relationships. -

The following principles should be considered in any new system which may offer rewards to entities that are already in substantial and continuous regulatory compliance that improve their performance and efficiency beyond that required by the existing regulatory system:

I . Incentives need to be tied to the performance of a given entity and an entity may be more than one site;

2. The level of environmental performance should be based on the performance acheved. not the number of actions taken;

3. When an entity has developed and met an environmental plan objective and new goals are identified, the entity is then at a higher level of improvement and needs to develop a new implementation plan and a progress review methodology;

4, The more flexible the approach to individual entities the more resource intensive the oversight group will need to be;

5. The environmental manager will drive the improvements rather than good policy driving the program;

6. Rewards must be reconciled for small entities vs. large entities; and - Rewards should only be considered when there is suficient reliable and verifiable data to

confirm success in achieving a level of environmental performance and efficiency beyond that required by the existing regulatory system.

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IV. Minority Report of the Blue Ribbon Panel

April 15. 1999

TO: Gina LlcCarth?. Executise Office of Ensironmental ~ f f a i r s .

FR: Robert Ruddock AssociaEd Industries of Massachusetts - -

RE: Pollution Prevention Panel: Views and Discussion

Introduction

In spite of the differences which were apparent at the beginning and at the end of the Panel's meetings, we found participation on the Panel to be a positive experience. While some might have hoped for a resolution of issues separating differing views on the Panel, the meetings provided a place for pollution prevention ideas to surface with more specificity and clarity than ever before. From our perspective, we had the opportunity to discuss such issues substantively in a positive atmosphere you created.

The report of the Panel will reflect the discussions - common understandings and differences - which took place over a four month period. This memo seeks to describe our position before the Panel during that time period. The attached "concept" paper also dated today outlines OUT overall ideas about a new program for pollution prevention, which we were trying to articulate during the Panel sessions, particularly at the last two meetings, to create a positive outcome for the environment and society. An important part of this concept was reflected in the Panel's discussions.

Thank you for the opportunity to submit this memo and the outline of concepts for a new, dynamic pollution prevention program for Massachusetts. I would request that this memo and the attached concept paper be made available to the Secretary as the Panel's report will be. Additionally, I would hope that our previous written communications to you be made part of the record and made available to the Secretary.

Starting Point

In a sense dexreloped during our panel discussions. there is 3 sprc:rum in the process @I' protecting the en\,ironment. I t is:

1 .

? -. 3 .

4.

5 .

Actii.ities not in the r e p l a t o p system. bur should be under curren~ h v s and regulations. Acti\,ities not in compliance. but on track to become compliant. In compliance with applicable e si sr ing regula to Q' programs. Engaging in enhanced environmental performance regardless of regulator) programs. Engaging in very enhanced environmental performance.

Items 1 to 3 are squarely within the existing, mandatov regulatory system. These =e characterized by scienriEcally based standards for results and process. They are clear and predictable. They are the subject, rightly. of intense dispute and debate. assunn, 0 in the end an appropriate airing of differences and a resolution that is best for sociec. These systems over time have resulted in cleaner air and water, better handling of hazardous materials, and more appropriate disposal of solid and hazardous waste. These programs have proven to be essential.

Items 4 and 5 are not in that mandatory system. These are efforts that faciIities or organizations undertake for a variety of reasons. Whatever the motivation. such efforts result in degrees of pollution prevention and enhanced environmental performance. Pollution prevention requires initiative and creative thinking imbedded in the fabric of an organization. Organizations rareiy move to enhanced comprehensive performance by force of mandatory requirements, although some organizations are driven by government enforcement to adopt enhanced performance to avoid penalties - this is a coerced result and more often than not focused on one type of activity affecting the environment.

Enhanced environmental protection beyond mandatory regulatory programs is driven we believe by positive rewards. Those rewards can be internal (e.g., lower operating costs) or extemal (e.g., tax credits), and they can be monetary (e.g., greater sales) or reputationaI (e.g., positive image in the communitJ-). These are all positive things, not negative like mandatory systems with severe penalties for non-compliance.

.?

- -

Afier decades of mandatory regulatory systems, our air and water are cleaner, hazardous and solid waste are handled safely and appropriately to protect the public and the environment. But over the years these systems have revealed unanticipated consequences. Among these are often end-of-pipe technologies to meet environmental standards with a concurrent lack of comprehensive pollution prevention analysis and action, In a way, existing regulatory systems start too late, and responses are too focused on the goal of achieving the mandated standard. This drains resources for broader environ,menta] analysis and action. Having said this, the existing systems remain valuable because they are the bottom line for protection of the environment. The challenge is to move beyond these systems.

2

Challenge

Tnls is thc challenge for the n e u centuq in en\*iromen[:l protrctlon and reduction of lmpacts on natural resources. How to intemaiize overall concern for envlromental enhancement. individual organization en\.ironmental impacts. and 3 commitment to a comprehmsi\'r understanding of actions affecting the environment. Ivlassachuserrs can lead the \\ 3) in

responding to this challense. I t did so with the hazardous waste site clean up reforms beginning in 1992 to the present mith the Brownfields law adopted last year. as \vel1 as Xyith the DEP En\ironmental Results Program begun two years ago. But the same old approach even Lvith some changes dges not respond to this broad challenge.

Penaltj. driven. single issue mandatory programs (like parts of TUEt4, for esample) bleed resources and distract organizations from paying attention to the bigger picture. Positive reward systems lvork by allowing organizations to analyze overall activities and alloLving such organizations to choose actions that are beneficial to the environmenr and cost effective. This has three positive results for Massachusetts - enhancing environmental quality, reducing impacts on natural resources. and improlving economic effectiveness. In a positive system these beneficial results are achieved by "attracting" action (not by "driving" action as in a mandatory system.)

- -

Again. the existing mandatory system must stay in place (although it can and should be enhanced) since it is the bulwark for protecting the environment and the public. The positive program. responding to the challenge of comprehensive action and analysis by an organization, is built on top of the existing systems, and allows organizations to further enhance environmental quality, protect resources and be economically competitive beyond the existing stahdards enforced by the Massachusetts Department of Environmental Protection and the United States Environmental Protection Agency.

Positive Program

The attached concept paper outlines a program that is a multi-faceted blend of enhanced existing regulatory systems, voluntary and incentive rich positive programs, aggressive and coordinated technical assistance and information transfer, and accessible data about environmental quality and impacts on resources. It is a comprehensive program built on reforms of the existing regulatory and reporting systems, and a commitment of resources by both the public and private sectors. Above all it is an empowerment program for organizations and environmental managers. The attached outline builds on discussions of the Panel about positive incentives and access to data.

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Tosics Use Reduction Act

TUR4 has been an interesting experiment. I t \+'as created ter. ?" rs ago as the result o f 3 pQ11u23:

conpromis? to avoid a bea tened ballo: Question n-hlch ifadl--zed \vould h3ve banned the use of certain ckmisals in Llassachusetts. There are a lot of lessoc :? be Ieamrd from ten years of TURA.

Chemicals are integral to economic development. including hlassachuserrs' high technolog\. and communication industries. Recent data shows a s i ab le increase in chemical use bet\f.een 1996 and 1997. no doubt reflecting the robust economy. economic gro\\Th and increased jobs in klassachusens. This increase. reflecting positive economic strength in Massachusetts. occurred notwithstanding-the toxics use reducrion act. Coupled nith this positive data demonstrating economic grou-th. recenr data also shows emissions and discharses into the en\4ronment haLze been continuall:. reduced over the years. This important trend has been the case in other states Lvhich do not ha\.e a TVR4 law at aII. Against this backdrop. there are parts of TUR4 that are important. and should be enhanced and applied in a more comprehensive fashion for pollution prevention. Interestingly enough, the parts that are valuable are those centered on voluntary action.

The centralized operational technical assistance of the Ofice of Technical Assistance created in the act has great credibility and has been effective. The production rechnical assistance available through the Toxics Use Reduction Institute created by the act has also been well received and has had positive impacts. The micro-experimentation concept pioneered at Menimack College with funding from TURA has been very helpfil in efficient use of chemicals and in reducing chemical waste at colleges and universities, and laboratories elsewhere. The expertise developed by consultants during the past ten years is also important and has matured into valuable knowledge \vhich should be leveraged into more comprehensive pollution prevention.

But the rest of TUK4 with its mandatory concepts have run their course and should be replaced with a better program. The planning process is compromised and has been since the beginning. Since i r is mandatory (with penalties for failure to produce the plan and subsequent updates) resources are committed in an organization to satisfy the chemical planning procedure, not to be creative in a comprehensive way for cost effective overall pollution prevention. TURA's exclusive focus on chemicaIs has side tracked better ways to protect the environment and resources. Appropriate and protective handling. use. waste management, and disposal are required under other federal and state laws. TURA adds nothing 10 these protections. The reporting system under TURA is so rarified it requires significant manipulation in order to produce the analysis of data. Under a new pollution prevention dynamic, reliance should be placed on federal toxics release inventory data for Massachusetts. Such data is used universally in the United States to provide regulators. safety officials and the public with emission and discharge data. In addition, facility chemical inventory data is available to public safety officials under federal law and such data is also available to the public.

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Positive programs should be retained and utilized in a more comprehensl\.s. pol1u:ion F r s snriL):: program. (See attached.) It ivould be unfonunate i f TL!J'RS. \sere simp]). amended IO inciu2c. more facilities. Such an action Lyould amplifi inefficiencies. reinforce suspicions and frustrations. and set back more important programs that could drIi\-er cost effective comprehensive pollution prevention and resource protection.

Conclusion

We tried to express the view during the meetings of the Panel that hlassachusetts is in a unique position. I t has pioneered aggressive environmental protection. I t has improved eni.ironmenta1 quality and the quality of life for all citizens. Massachusetts can rake the next step and continue its leadership. States like Pennsylvania are claiming they have foungthe right path. but on closer examination they have only followed where Massachusetts has pioneered. e.g.. 1992 reforms to Chapter 31E and implementing DEP regulations. 15" should choose the ne\v, more exit ing and ultimately more rewarding comprehensive program described in the attached outline.

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April 15. 1999

Concept Paper

Ne\\. Dvnamic for Pollution Prevention

Challenge

,4 11 is time for a unique demonstration of a ne\{ pollurion prevention dynamic. a more comprehensive and creative approach. to improve environmental qualip.

1 ,- Environmental quality is a shared goal of all segments of sociev.

-. Environmental quali? has been sought aggressively over the years.

3. There is in place a shared consensus. commitment of resources, and both a scientific and technical maturity about environmental quality which is constantly evolving.

- - 3

3 . At the same time continued improvement is more difficult to achieve after decades of regulatory action - existing regulatory systems are not nunuring or conducive to creativity, individual consent, and cooperation needed for continued improvement.

.

B. Without abandoning existing standard-based systems and their achievements to date, a new comprehensive approach is necessary to take the next step toward a new dynamic of cost effective pollution prevention and resource protection.

C. The new dynamic:

1. Builds on existing standard-setting regulatory systems,

3 -. Creates new cooperative and creative models and systems,

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3. Credibly and effectively transfers technology and management system information,

3. Makes environmental quality information more accessible for all,

5 . Commits resources to achieve further environmental quality,

6 . Builds on the maturity of environmental managers and consultants outside - government, -

1

- I . Cniquei? empou.ers all participants.

8. Leverages resources for long term emironmental impro\ emenr 3rd prorection.

The ne\\ dynamic is a multi-faceted blend of existing sj'srems. volunraq. and incenri\8e rich programs. aggressive technical assistance and information rransfer. and accessible dat3 abour environmental qualir]lr. I t is. in the final analysis. based on informed and positive empoiverment. Measurement of success is by environmental qual iv improvement and reduction in en~.ironmental impacts of activities. organizations. and facilities.

Ne\v Dynamic f<r Pollution Prevention

The new dynamic consist of the following parts, which together are a new way of keeping hard won environmental quality. improving the environment further. and reducing environmental impacts in the future. The dynamic is vibrant with commitment and empowerment, improving existing systems of regulation, and making meaningful environments1 impact and environmental quality data more accessible.

A. Existing Regulatory Systems - Revitalize and Expand

1. Do not abandon the existing aggressive regulatory permitting, compliance and enforcement with the existing thousands of entities in the system, but enhance it.

-. 3 Implement changes to improve the regulatory system by reviewing both the compliance and agency management data to assess successful activities and areas for improvement (including existing fee structures).

3. Expand the important "environmental results program" (ERP) to add more homogeneous groups o f regulated entities to it. ERP empowers entities to take over their own permitting and compliance, and thereby intemalizes regulatory standards and creates commitments to environmental management in exchange for less agency oversight, waiting, suspicion and confrontation.

__

4. Continue the on-going scientifically based evolution of environmental standards for mandatory programs and effective bottom line environmental criteria and protection within DEP.

5 . Eliminate counter productive regulatory systems which breed frustration, suspicion, and contribute little to environmental protection. e.g. the planning and reporting systems of the Toxics Use Reduction Act.

2

B. Technical Assistance - Coordinare and Enhance

1. More closely coordinate. through c snarecic alliances. sysmns for rechnicai ad \ IC"?

\t.hich are a\*ailable nou in various agencies and entities in state govemmenr for cost effectiL :: pollution prevention. Remo1.e impediments for \ o l u n t q peer-to- peer assistance. information transfer. and consulting.

2. Enhance technical assistance and the benefirs from it by maximizing opportunities to combine single target assistance programs (combining. for example. e n e r g consenation services with chemical efficiency technical assistance) and making such senice opportunities available to all npes of organizations. -

3. Create a vibrant. articulate. and transparent record of technical assisrance that transfers information. techniques, and success-stories to other organizations who could replicate those successes and to the public.

C. Create Voluntary. Incentive Rich Programs for Pollution Prevention

1. Establish a free standing. quasi-public entit). to oversee a new program for pollution prevention that cuts across environmental media. resource use and activities which impact the environment - to attract positive responses improving environmental qualiy and reducing impacts on the environment using tools like cooperation, positive recognition, suspicion free interaction with government, and measurements of success.

2. Create a range of incentives (including hard incentives like tax credits or low cost loans, and other softer incentives) reduce impacts on the environment by an entity, facility or organization agreeing to participate in the program.

Create a process for entities in substantial compliance with existing regulatory programs to identify (using their own creativity and with initial technical assistance) pollution prevention options across all environmental media and resource use, and opt into the incentive programs for specific, realizable and measurable reductions in environmental impacts.

3.

3 . Using the quasi-public entity, allocate incentives for improvements achieved, require pay back of incentives for failure to achieve articulated commitments, and publicize successes - sharing in a technical information transfer the lesson learned with other similarly situated organizations (with appropriate confidentiality protections).

5 . Create within the incentive program, empowerment and creativity opportunities for managers at all q p e s of facilities, including environmental audits and compliance, and good Samaritan type mutual aid agreements.

3

D. Transparen1 Data on En\,ironmental Impacts and Fees

1 . Rel!.ing on existing permitting. reponins and compliance s>'srems. r a r i o n ~ l i z ~ I h e z to present a more comprehensive data rich picrure of:

a. Current environmental qual iy in blasachusens for air, \ \atrr. h u r d o u s \vaste. and solid waste.

b. Individual permitted entity data for emissions (air), discharges (uater) , and Lvaste streams.

- C. Permining systems, efficiencies and responsivmess of state agencies for

environmental quality.

-. 3 Using the nationwide and consistent federal Community Right to Know and Toxic Release Inventory (TRI), more transparently track chemical emissions, discharges and public safe? data. TRI reporting in particular has expanded and i t should serve as the exclusive chemical data program. TRl and federal Community Right to Know data should be available to all state agencies electronicall).

3. Using the federal Community Right to Know data (including among other such data Tier I and Tier II information), make such data more transparent to the community and to appropriate state asencies, including the Department o f Environmental Protection.

Using readily available emission, discharge and storage data, integrate such information into a facility based data system, accessible to government and the public.

3 .

5 . Create within the facility data base the ability for facility operators to comment on data in the facility file system, a method to assure accuracy of the data in the c government files (Q/A and Q/C by filers), a system for notification to a facility that its files have been accessed when someone reviews the facility's file, and procedures for Identification of confidential business information and its protection in the system.

Summary

The goal of this new dynamic is to provide real and creative opportunities for improving environmental quality and reducing the impact of human activities on the environment and natural resources by fostering a vibrant cost effective pollution prevention mentality in society among all types of organizations.

3

The existins mandatop. r e p l a t o p command and conrrol s!’srem is essentia! as SKI=:\ ‘ 5

bottom line mechanism to identi@ environmental quality standards and protect the enirironmrn:. But this regulator?, s\’stem cannot create the positive atmosphere. cooperation. rrus~. and crea!i\.ip necessa? to move to new goals for environmental improvemenr. to reduce individual impacts on the environment. and to eficiently use resources. In shori. we need i~ build on \\hat ivorks. create new models \\.hen n e c e s s q . and replac: what does not ivork. Onl:. 3 posiri1.e empoLvennen1 . model can provide the tools for Massachuserts to Create a ne\\’ environmental pollution preL.enlion dynamic.

Massachusetts citizens. government agencies. regulated entities, and business and environmental advocates have worked hard to create effective systems to reduce impacts and improve environmental qualit?. Effectively setting environmenral standards must continue because these are the core, bonom line protections for society and they should-be changed \\>hen science and data require chanse. But a new dynamic to move to new levels of environmental quality and reduce environmental impacts through comprehensive pollution prevention should be undertaken noiv. I t should be based on proven methodologies of empowerment, third-party expertise, and measurement of results. Massachusetts can be a trail blazer. I t can demonstrate an effective. core regulatory program and an open, rich voluntary program to improve the environment.

In past several decades, the Massachusetts environment has improved significantly. Next steps require continued and revitalized mandatory command and control programs AND a new cooperative path to help faciIities and people move beyond core protections and reduce environmental impacts on natural resources. I t must help them look across media and natural resource use, and creatively and holistically assess quality, impacts and efficient results. No command and control program can do that. Cooperation, collegiality and reduced suspicion - coupled w i t h broad and interdisciplinary technical assistance - will build trust, make everyone smarter. and realize both cost effective and environmental beneficial results.

BRODWFIELDS - THE MODEL

The Lesislature, the Govemor, and the Department of Environmental Quality have already pioneered this model in many respects in recently adopted Chapter 21 E amendments. DEP clean up regulations. and the new Brownfields law. Attributes of the new dynamic described above are present in the Brownfields law to assure success.

Esisring mandatory permitting, liability and management systems were kep: for those who are responsible for a hazardous waste site. Standards for clean-up are in place and constantly undergo review by experts to assure that activities at sites result in protection of the public and the environment. Qualified people can opt into a new program, however. On a voluntary basis an ’-innocent” redeveloper can obtain liability limitations for a cleaned site. Such liability limitations were adopted to positively encourage developers to utilize older, contaminated sites for growth, while saving greenfield sites else where.

5

The entire histon. o f t h e evolution o f t h e Brottnfields lau is the model for 3 neu \\a!* to improve environmental quai in . Existing systems to clean up sites, Lvhile protective of the public health and occasionally successful. failed to result in man!' cleaned up sites. The Legislature. the Governor. the Department of Environmental Protection. developers. banks. and the larger business community came together to propose a new way to get resulrs. That new - way built trust. reduced adversarial confrontations. encouraged creativic. and self-starting, empowered people. and provided both soft and hard incentives to arrract action. I t did not, like old models. attempt to drive action by heavy handed. mandatory command and control systems.

Massachusetts can again trail blaze with a new environmental dynamic for pollution prexrention and resource protction. The only limitation in achieving this new dynamic is blind adherence to heavy handed regulatory programs as the sole model for future action. That was rejected in the Brownfields law when a new opt-in system was created together with the existing and enhanced mandatory program. I t can be done again.

I 1 April. 1999 - Associated Industries of Massachusetts

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V. Flow Chart for a Future Model of P2 Regulation

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VI. Attachments

Ted Schettier - Greater Boston Physicians for Social Responsibility, Science and Environmental H d t h k t w o r k

Hospitals, medical or d c d of im, nursing homes, and homehealth a_nencl= p W & b ' provide seM=s and consume resources and marcriais. The h d t h and environmental impact of resource and materid use in these facilities is btst estimated through life CVCIC d y s c s including purchmug use, rc@mg, and disposal prsctices. Opportunines for pollution c_ prtvcntion and resource conscNaDon arc distributed throughout.

- Spectrum of Concerns - -

Resource deplction, environmental contxmi&on with c h e m i d and biological agcnts, stratospheric ozone depletion, global warming, acid rain, c u t r o p h i d ~ ~ & and photochemical oxidation. Ea& of these has the potential to afFd human and ecosystem health over varying rime fr-ames.

Medical facility aaivitcs which contrjbute to polhuon and resource depletion - Direct air, water, sod, food contamination through discharges to the environment Materids purchasing, use, disposal Energy use Transportation Water consumption

Background - Hospitals and ohm related facilities (medical and dental offices, m i n g homes, home- hcalth care, research facilities) arc responsible for signiticant natural rewurce consumption and environmental contamination. ~ o s p i t a l s alone generate approximately 2 million tons of trash annually. Although this q m s e n t s only about 1% of the total solid waste stream, disposal practices and the contents of thc trmh account for its disproportionate toxicity. For example, according to t he US EPA, medical wg te incinerators are the third leading source of cnviron"tal dioxin missions from combustion sources and are responsible for about 1 W ? of anthropogenic mercury emissions to the environment.

In the aggresate, the healthcare sector is second only to manufacturing in electricity consumption. In many communities, the, IO& hospital is the largest single employer, and with 24 hourdday operation, several shifts of staff navel to and from work daily affecting the environment through transportation choicts or options.

Historically, envkonmuatal pcrfor-ce bas mely been a core business value for hospitals. The primary performance criterion against which healtheare institutions bavt

Hdthcarc instirutions have had linfc incentive to monitor or improvc &cir cnvironmcntd performance beyond regulatory r e q u k m a t s The emphasis on quality of cart, as measured by p&mt outcome, in addition to the need to provide a m e of matcnals and services for healthcare professionals, conmiutcd to a c u k " which bcuscd p m a d y on the availability, affordability, and puformarxe of materials and medical dcviccs. t W ~ a l l y no aftemion was paid t o the mvironmcnrd impact of mtaidsmanufacture, use, and disposal. Many hospitals disposed of rcplatcd and some or all non-replated waste In on- Ute incinerators which often iackcd air pollution controls. Inasmuch as medical waste incinerators were temporarily cxcmptcd From CAA emission requirements, rfus practice was common until proposed regulations were developed by the EPA in 1997.

Factors influencing healthcare waste disposal practices:

1) Rsulations - Regulated medical waste must be disposed of or rcndcred non-infectious via approved technologies, including medical wastc incinerators, autoclaves, microwaves, ac. Thc dcfinidon of regulatcd medical waste differs somewhat fiom state to state but gcncrally includes that component of the waste stream which is potentidy infectious, including sharps Pathologkal waste (body parts) and chemotherapy waste must be incinerated.

CAA emission rupirements for MWIs - In response to the proposed medical waste incinerator emission Iimits, often couplec~ wjth community pressure, many hospitals c l o d their incinerators and contracted with outside vendors for waste disposal services. Much regulated medical waste continues to bc disposed of in larger commercial incinerators of varying design and efficiency, although comcrciai and on-site autoclaves and other dlt-tive technologies arc increasingly uscd. [Ma a phase-in period, dl medical waste incinerators will be subjest to emission requirements established by the EPA or, if stricter. to stare requiremcms. The timing of implementation is somewhat uncmain because of a lawsuit brought t g a h t the EPA by NRDC which alleges that the proposed emission h i t s do not reflect maximal achievable control technology as rquired by the CAA.]

2) Financial considerations - Disposal costs of regulated medical waste vary fiom 18-30 centdb depending on location, vcndor, and tectmology. DisposaI costs of non-rcgulatcd waste (ordinary trash) is roughly 5-6 teorsflb. Hazardous waste disposal costs arc well in ~;CCSS of SIAb giving strong financial incentiveb to minimize the regulated waste stream and to recycle hazardous materials when possibie.

2

4) EPA/AHA Memorandum of Undcntanding - In June, 1998, a memorandum of undmrandiry Y O U ) was entered into by the USEPA and the Ammc~n Hospiral .ksuciation This publidprivatc volumary partnership calls for the e h n a t i o n of mcrcury- contru+ waste fiom haspitds' stream by 2005 and reduction of the overall volume of waste by 33% by 2005 and by 50% by 2010. It also calls for the parties to work together to investigate P2 opportunities with respect to ethylene oxide and PBT pollutants In EPA Region I, an effort to achieve the mercury reduction god is underway with considerable support from outside the healthcare secfor, in part because of a r e o n wide commitment from New England governors and their counterparts in the Maritbcs 10 substantidy reduce mercury emissions.

Current status:

At the present time, cnvironmurtal performance by healthcare facilities varies widely. Some, both large and s a have shown 0utstandin.g leadership cnvironmmtal performance, often because an individual or small co"ittee within an institution havc priorib'rztd the issue and kept it on the agenda. A somcvlhar krger number have taken early s t e p s to reduce the voumc of regulated waste:, primarily because of cost considerations But many hospitals and other related institutions have done v q little to mprove t h m performance Therefore, the tiered approach discussed by the Blue Ribbon committee is directly applicable to hospitals, medical and dental offices, nursing homes, and home health agencies.

Tier I

improving

___

Currently, healthcare instimrims must comply with standards or regulations established by EPA (CAA, CW.4, RCRA), OSHA, DOT, and CDC. Although JCAHO is an accrediting organization, it hnc t ions as a virtual regulatory agcncy since hospitals must be JCAHO amedited in order to rective f d m d k n d s The JCAKO standard for msnagemcnt of the environment of care says that the god of this h c t i o n is to provide a safe, f i~ndons l , and effective cnvkonment for patients, staff, and other jndividllals in the hospital. It says nothing about the facility's impact on the environmmt ouxsicle the walls of the instirution.

3

This srandard tom- thc requirrment for a hazardous marends and wasr- manq="nt

elm Spcdically mentioned is compliance with rcicvant laws and rqpiauons r c - w d k ;xnti.fvins and evaluating hazardous marerials used or g t n m t r d It includes c h a n i d r i s e , chtmo?hcrapatic waste. radiwake waste, rc_rmlarcd or ~ n f d o u s W a ~ t c ,

inciuding sharps, and hazardous gases and vapors.

Heafthczlre institutions must d s o amply with state and POTW v u i r t m e n r s These various requirements are rcsponziblc for thc pcrfomance standards which address hazardous and infatious waste "gunen;, workcr safety, sewage discharge, and rhc like.

Sohe of these requires healthcare r r m q e r s or practitioners tojook upstream at general rnazmials policies. life-cydc mdy-scs, or to spec i f idy considS errvrronmental unpact outside the instirusion, except to the degree that they may be forced to do so in order to come into compliance.

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Tier U:

Some healthcare instirutions are moving beyond compliance, driven primarily by economic incentives and, to some degree, by community pressures. Tney are reducing the volume of r q d a t c d mcdical waste (by better waste segregation and intensive educational efforts), dcveloping recycling p ropans (paper, cardboard, glass, fluorcscmt bulbs, wood and tab chemicals, &e solvents, which must otherwise be disposed of as hazardous waste), and bcfiing to address purchasing practices which strikingly inftucncc the volume of the waste stream.

When adx-inistratars and purchasing agents are also concrmcd about the public h d t h and cnviromcntal impact of their purchasing and disposal p d c e s , they may, for ccample, choose to phase out use of mercury-currtaining devices, polyvinyfchloridc plastics (PVC) where possible. &n clcantrs (e.g, phenols), and glutaraldehyde without sacrificing quality of care. However, even here, economic considerations often ovenide concern for pubiic health and the environment.

- h rummary, some hospitals, large and small, have moved beyond compliance to more comprehensive materials manasmcnt policies which begin to look at We-cycle analyses and idennfy oppomniries to reduce, reuse, and recycit. However, they are largely driven by ecanomic incentives and are unlikely to be sustained if they do not have a neutral or positive e€€m on the bottom h e . (see "Greening Hospitals - An analysis of polIuuon prevention in America's top bospitals" - HCWH)

Tier LII

M o h g from T i a I1 to III rtquircs not only B more comprehensive search for P2 opportunities, but also institutional commitmat to environmental per fomnee as a core w h e . Ethical considerations, in addition to cconomk factors. become primary " h x t o ~

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I planning cnviromentd performance evduauon

A Select indicators, collect da.4 analyze and assess data, rrport and communicate. change bemvior to improve peg- I '""Ct

Consider: fnpurs - materials, energy (amount source), trampomtion, services

Materials - Dyect and indirect parient care, organizational suppofl En- - Transportation - staff, patients . Wstcr S d u s - cleaning, janitorial, groundskccping, maintenance, transport,

d c l i v v , kfonnatiun and communicatian, - securiq, food, Waste disposal, pest connol

. -

Outputs - services, wastes (hazardous, replared, unregulated, recyclable, reuseable), emissions (to air, water, land - chemicaI, biological. rsdioacrive)

B Specifically consider: 1 local, regional, national, and global cnvironmcnral facton when s d q

priorities - describe rhe condmon and character of the environment in which the facility exists and idenrjfy unique qualities which m y influence the choice of indicators and actions to improve environmental performance.

2 material purchasing. use, disposal 3. energy, water use 4. air, iand, water discharges - nut only those that occur fiom thc facitrry but also those that result from the activities of waste disposal vendors. For example, if a hospital chooses to close an incinerator because of wnccms for impact on public health and c n v k o m c ~ but contracts with a waste disposal vendor who autoclaves the waste and ?hen ships disinfected waste to a municipal waste incinerator, there is no gain. 5 . The views of all stakeholders 6 Life cycle analyses - diredindirect e f fens , varying timeframes 7 Legdregularory rquirements

C. Evaluating environmental perfox-mance is part ofthe reguiar business hnction of the organization - at all levels

II. Potential enviromentd indicators:

Emissions - quantity of specific missions to air and water each year; landfills; emissions with local, regional, or global conscqucnccs.

E n e r a UK - for some types off&kies this may bc normalittd by consumption per daybed occupancy. However, better normalization metric needed.

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providers ;

Transporr-aarioc - staff and patients, usc of public t r anspowion . m s transit opponh t i e s

W’asre gcneration - pounds of red bag waste per patient day; c6mpbson of d i s p o d Costs and volume (in each category) from year to year, percent waste recycled (in ea& category)

Note: Environmental indicators for hcalthcare arc in early stages of development and, as With orher sectors, mctrics need to be devclopcd which enable comparison of institutions in m c a n i n w ways. Activities within hospitals vary considerably (e.g. tertiary cafe facilities provide services that diffcr &om those in primary and secondary facilities) and mctrics will need to rcflem those dSkrences in order to fairly judge environmental performance. As data are gathered on c~v i ro r~” ta l pufonnance, options for no- those dara will bccomc more epparmt.

Mamx:

Economic incentives - discussed above - Regulatory incentives - will vary fiom community hospital, to large teaching hospital, to pure restarch institution. JCAHO could expand its environment of care standard to include public heahh and environmental imp-. Labelling requirements would make it possible for purchasers and waste managers to make more informed choices. Stop the practice of distributing mercury thermometers for home use.

Regulatory impediments - Makc it possible for a hospital to collect mercury thermometers from the without getting into problem with hazardous waste management.

Flaming issues -

Mission statement - Healthcare facilities should re-examine mission statements for evidence of concern about public h d t h and environmental impacts. The institution should examine the social contract t h t is implicit or explicit with the community in which it is located.

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Accounting and b u d g w practices It is not unusual for a dcpamncm head who develops a budger to be totally unurfomtd about waste c : : : s o ~ costs in t'nt same department. Waste disposal COSTS may show up in h o u s e k p n g or cnvirunmcnral senices budge

Education - Healthcare staff and profession& arc often poorly t&.ned in undcrstandlng the relationship between human health and the environment This could be addressed throu@ existing conttnuing education programs.

- - services - -

Enormous opportunities for P2 though improved purchasing practicts are often offset by barriers that res& from group punhasing through iargc GPOs, well beyond the ConrroI of individual institutions. Assistance from TURI or the SL:xajnable Hospitals Prujcct at

UMass Lowell in idcnhfjnng those opportunities and hciping to bring pressure on ( 3 0 s which sewe clients nation k e n insensitive to enviro periornanct.

Mass, Hospital Association and Mass. Medical Society - Each of these organitations could educate their respective constituencies and promote P2 in a variety of ways (coordinate programs, share expertise, economies of scale, etc) Each could help bring pressure on GPOs to improve product selection and choices for inStinttion~ wishing to improve environmental performance.

o d d be u s 4 in changing 8 culmre which has historically

Impacts beyond todcs - scc above

TozCics in products - need for labelling. education: importance of purchasing as well as reduction and recycling

Reponing - Most hospitals a r t below current TUR thresholds. Hazardous waste r e p o h g already required

Data - see above - Ticr I11

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Common~..edth of hlassachusem P2 Blue Ribbon Panel

haATIRIX RESPONSES: HIGHER EDUCATIOS INSTITUTIONS

Ken Geiser, Universir>* of Massachusetts. Lo\?cell December 1.6. 1998

Background - Higher Education institutions in Massachusens have a significant impact on natural resources. Many universities. colleges and professional schools operate ~ i t h environmental permits, usually for sewer discharge and air emissions where incinerators or chemical vent stacks are concerned. Some far-sighted university administrators have gone beyond compliance and promoted highly visible approaches to environmental management. At a minimum this involves materials recycling. energy efficiency, and awareness in grounds maintenance. More proactive approaches include solid and hazardous waste management. pesticide use reduction. chemical tab programs and student and staff education.

-

In considering higher education institutions, it is wise to note the limits of an academic culture. Universities typically have a weak or "informal" management structures that makes comprehensive, campus-wide planning and management dificult. The independence-oriented nature of academic life creates a culture resistmt to authoritative directives or consensus decision making. While higher educational institutions are often strapped for resources, 'financial efficiencies are not immediately recognized as virtuous. Although environmental protection is an easily accepted value on most campuses, few administrators recognize it as a core institutional responsibility.

Initial exploration of the current status of university environmental management conducted by Gary Siege1 indicates fair awareness on the part of managers of larger universities and that "active P2 assessments and planning are being done by a number of campuses ..."

Sarah Hammond Creighton has written an excellent book, Greening the Ivory Tower (MIT Press, 1998) reviewing the environmental management options for higher education institutions. Some universities--Tufts, Brown, George Washington--have well recognized environmental performance programs.

Using this book, Gary's memo and my own experience at Tufts and the University of Massachusetts, I have tried to respond to the Panel's Matrix with. the comments that follow.

MATRIX

Economic Incentives

Cost savings are the primary economic incentives for higher education institutions. Such incentives are vpically not as efiective as they are in the business world. because these institutions do not compete heavily on the basis of price. Fieighborhood relations and the same public interest concerns that motivate hospital administrators. may be equally important incentives.

- Regula to Incentives

Unlike many businesses, universities deal with hundreds of chemicals in quantities so small as to be well under regulatory attention. Waste water and air emissions from incinerators are often the only permitted requirements. Some reguiatory relief (streamlined permits, permit avoidance, and compliance cost avoidance) could be achieved by more careful attention to reducing air or water releases.

Regulatory Impediments

With the exception of some POTW regulations there does not appear to be regulatory impediments for institutions of higher education.

Planning Issues

Although some larger institutions have developed environmental performance planning-- the University of Massachusetts campuses were involved in the Clean States Program-- smaller institutions with limited administrative staff have little capacity for such planning. Even some of the best planning efforts do not meet the standard set by leading corporations. As with many businesses ten years ago, colleges and universities seldom have a central authority for environmental issues, adequate information to judge performance, knowledge of "best practices" at other institutions, or a full awareness of options for improvement.

It appears that requiring higher educational institutions to prepare a comprehensive environmental performance plan could dramatically raise awareness and result in voluntary initiatives to improve performance. To be effective, such plans should be certified by the facility's highest administrator. Allowances would be needed to address the inadequate capacity at some (smaller) institutions. Perhaps, a shorter, environmental performance review document might suffice. Efforts to require planning will need to be introduced sensitively as most likely there will be a mixed reception among the institutions regarding the merits.

. ....

Services

In many CLSCS higher educational institutions could us:: assistance. Second Kature otrcrs trainins to universi? facdr). bur this is more directed at cumculum. bationd ii7ildlife Federation has a useful guidanc:: manual for campus management. The f e d e d EPA has an X L Project focused on universities. -41 a minimum. assistance senices should involve staff training. TUR Planner-tvpe trainings could be of si, unificant benefit to college and unkersity personnel. but the proper inducements uill need to be there. Site- based a s s i s u c e could be valuable in manv cases. The OTA experience uith school chemistry labs has demonstrared the value 0.f such seniccs.

Fees o r FundiGg -

Most higher education institutions can afford a modest annual fee. The fee would need to be easy to compute and reflective of the range of environmental impacts. A simple formula could be based on a Surrogate indicator such as number of full time students or fu l l time student equivalents enrolled per year, with deductions available for implementing various environmental protection programs. For example, a reasonable annual fee could be set at twentv cents per student kvith S50 reductions each for a paper recycling program. an energy efficiency program. a stafftraining program. a lab chemical management program, etc.

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Impacts Beyond Toxic Use

Higher education institutions have many impacts beyond toxics use. These include:

energy use lighting efficiency, equipment and motor efficiency, building climate control, vehicle maintenance and efficiency , drinking water conservation, grounds irrigation conservation, sewage pre-treatment, rain water management, materials reuse and recycling, organic waste composting, product procurement policies, packaging and container reuse and recycling, waste reduction programs,

integrated pest management in buildings and grounds awareness and training programs, volunteer service programs

water use

solid waste

hazardous waste waste reduction programs pest management staff and students

Tovics in Products

Higher education institutions purchase large quantities of products, ranging from laboratory chemicals and cleaning supplies to paper, books, food, clothing, appliances, vehicles, and furniture. Purchasing inventories and environmental procurement programs

as well as emission and waste prevenrion programs.

Reporting Issues

Conventional niR4 reporting procedures will reveal little about most higher educational institutions environmental performance or use of rosics. largely because few universities use toxic chemicals above current thresholds.

Data

Feu. institutions collect much environmental performance data. Gw Siegel's memo suggests some sample indicators that might be useful units for data collection. Indeed, these institutions have no experience with collecting such data on an annual basis, reporting such data to the state, or making such data accessible to the public. Some initial resistance to state reporting should be expected.

Indicators and Benefirs

Benefit: Reduced priorin. for inspections

Indicator you may deserve the benefit:

Evidence of an EMS in place Evidence that audits are t&ng place Evidence that corrective action is taking place Evidence that the EMS is adequate to ens-e compliance

Faciliqi has been inspected recently and did well

Evidence that facility has done a good job reducing toxic use and bjyroduct Evidence that facility is continuously updating TURA plan Evidence that facility has used emergency planning to reduce r isks at the source

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Some of the above can be accomplished ~ j t h 3rd party certification Some of the above could be accomplished with self-cenification Department could provide audit upon request to qual ib facilities for

Recognized Environmental Performer (Good REP) track

Benefit: Reduced monitoring reports on drain discharges or stack emissions:

Indicator that may get you the benefit:

Real time continuous monitoring, continuously transmitted or remotely readable at election of agency

Submission of use information balanced with output

Reductions below certain thresholds

For consolidated, one-stop reporting arid/or permitting:

Submission of mass balance information, TUR plan, and certification that all feasible TUR has been implemented

Draft P2 hletrics for Eiectriciw Generat ing Facilities in i'klassachuset~s

Merrics for these facilities should be ou;--x; b z e d ;; -romo[r energ)' eficienc? and poiiullon prevention. Mosr meuics can be stated 1 , rota] pc--. 13 ?s uell as the m o u n [ of L k pollutmi - generated or the ~ Q W K of chemical used, per me; . .,m-hour (b ib%) of ener2' produced. The focus on elecmcit) out-put is consisrent v,jth EPA cunent way of fookng at utiiir! pe5ormmce. We may want to consider measuring/evaluating some memcs aft-.: Controls 35 well before controls since many of the chemicals h a 1 are reportedtracked by utiliries are manufactured d u n g the combustion process. and then "integrally treated" before leaving the power planr's exhaust stack. Eo, generatiowemissions is an example.

Additionally. power generating facilities could repon TRI emissions, solid waste generation (including bottom and fly ash), and the percentage - of renewable energy generation in the company's portfolio; if applicable. P2 planning for these facilities would include the evaluation of new technologies which would help produce energy more eficiently. decrease emissions, decrease thermal poIIution, and provide options for less resource and chemical intensive methods of producing deionized water, treating cooling process water. and treating boiler water.

- - -

The amount of energy conserved as a result of demand side management and by improvements made in transmission and distribution efficiency - MWh produced fMWh billed may also be reported if appropriate (utility deregulation separares generarion from distribution). Some other possible metrics for power generating facilities include:

%of NO,/ MU% +of SO,/ M % h i: of CO/ MWh U, of CO,/ MWh U, of voc/ MWh $of NH3 emitted," $! of particulate/MWh U, of metal & metal compounds produced (ash and emissions)/h/iw Facility-wide Gal. of H,OhiWh U, of chemical used/MWh (DI water production) e of chemical used /Mwh (cooling tower disinfection) U, of chemical used in pollution control/MWh Thermal pollution (heat loss) to air - Trillions of BTUs Thermal pollution (heat loss) to water - Trillions of BTUS

Facility energy production efficiency - ratio of energy produced divided by energy input (fuel) into the generating facility - MWh/BTU's

Facility energy use efficiency - Facility electricity, oil, natura1 gas and fuel for vehicles, divided by MWh generated - Energy use/total MWh

,., c-2

Sector Re cu la t o m C overage Po r en t i a I kl e r n c s

Large Industrial Facilities Mandatory Reporting Mandatory Plannin_e

Jtility Facilities Mandatory Reporting (Power Plants Ody) Mandatory Planning

mall Industrial Facilities

cademic Institutions

.r_ee Non-Industrial cilities

Mandatory Reporting Mandatory Plannins

Mandatory Reporting Mandatory Planning

Mandatory Reporting

Mandatory Planning

TRI Reports Chemical Use

-

Fuel Consumption Producr Information Trash Generated

Fuel Consumption

64 Product information Trash Generated

I ,

TRI Reports Normalized Chemical.Use Normalized Fuel Consumption Product Information Trash Generated

Fuel Consumption Chemical Use Trash Generated

Fuel Consumption

Trash Generated

1

edical Facilities Fuel Consumprion

overnmental Bodies

Mandatory Reponing Mandatory Planning

Mandatory Reponing Mandatory Planning

Chemicd Use Trash Generated Patienr Census

Fuel Consumption Chemical Use Trash Generated

mall Non-Industrial acilities

Jery Small Business

Transportation - ns t i tuti o nal

Voluntary Reporting

Voluntary Planning

Voluntary Reporting Voluntary Planning

Mandatory Reporting

Mandatory Planning

Transportation - Individual Education

Individuals Education (Households)

Fuel Consumption

Trash Generated

Fuel Consumption Chemical Use Trash Generated

Fuel Consumption

Chemical Use Trash Generated

Fuel Consumption NOx Emissions Vehicle Miles Traveled

Fuel Consumption Trash Generated

ENVIRONM ENTAL M ETRICS, BY SECTOR

rYCL

; Y V C [ ~ I ~ ~ C J [ Z [ [ ~ Q & & 1 )

System of Melrics lhal can be used as indicators of environmental performance of all societal sectors

Minimization of reporting burden on regulaled community

2 )

3)

TRI reporting is a given

Performance indicators are needed, not complete inventory of environmental impacts I

TURAFlETRlC

Yes Chemical usewidget

Chemical ReleaseNVidget

Concentration of chemical

Process BTUNVidget

Heating BTUlfQ

at release

Solid WasteWidget

I Commuter mileslemploy ee IS0 14001 Certification ? EMS in Effect 7

NECESSARY INF 0 R MAT I 0 N

Widgets manufactured

- Widgets manufactured Chemical released Quantity of "carrier" Fuel burned (Quantity 8. type) Widgets manufactured Fuel burned (Quantity 8 type) ' Building floor area Pounds of solid waste Widgets manufactured Number of employees Commuter miles traveled

Chemical use (acid, chlorine, causlic, elc )

Chemical Release (acid, chlorine, caustic)

INFORMATION SOURCE

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facilily Reports

Facility Reports

Facility Reports Facility Reports

1

Medium

Small

YeslNo

.

.

1 .

. . No

. '

'

. 0

.

. I '

Chemical usemidget e

Chemical ReleaseMTidget

Concentration of chemical at release Process BTUMidget

Heating BTUlft;!

Solid Wastemidget

Commuter mileslemploy ee I S 0 14001 Certification ? EMS in Effect 7

Chemical uselwidget

Chemical ReleaseWdget

Concentration of chemical at release Process BTUNVidget

Heating BTU/ft2

So I id Wa s t e Wid g e t

Commuter mileslemployee IS0 14001 Certification 7 EMS in Effect 7

8

*

' e

' . .

e

e

' . . e

e

'

I Chemical use (acid, chlorine, caustic, etc.) Widgels manufactured Chemical Release (acid, chlorine, caustic) Widgets manufactured Chemical released Quantity of 'carrier" Fuel burned (Quantity 8 type) Widgets manufactured Fuel burned (Quantity & type) Building floor area Pounds of solid waste Widgets manufactured Number of employees Commuter miles traveled

Chemical use (acid, chlorine, causltc, elc ) Widgets manufactured Chemical Release (acid, chlorine, caustic) Widgets manufactured Chemical released Quantity of 'carrier" Fuel burned (Quantity & type) Widgets manufactured Fuel burned (Quantity & type) Building floor area Pounds of solid waste Wtdgets manufactured I

Number of employees Commuter miles traveled

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports Facility Reports

Facility Reports

Facilily Reports

Facilily Reports

Facility Reports

Facilily Reports

Facility Reports

Facility Reports

Facility Reports Facility Reports

fJ EC E $ SARY IN FOR MAT10 N I N f.'O R MAT ION SOURCE

2

l l l i l i ty Fossil Plants Yes

Nuclear Plants Yes

0

e

0

0

! .

Hydro Plants NO *

NOdMWHr e

C02/MWHr

HglMWHr 0

Concentration of chemical at release 0

Chemical uselMWHr e

BTU/MWHr

Commuter 0

I S 0 14001 Certification 7

EMS in Effect 7

e

0

Chemical uselMWHr

Concentration of chemical at release C02lMWHr

RadiationlMWHr

Commuter mileslemploy ee IS0 14001 Certification ? EMS in Effect 7

NOx emissions MWHr generated

C02 emissions MWHr generated Hg emissions MWHr generated Chemical released Quantity of "carrier" Chemical use (acid, chlorine, caustic, elc.) MWHr generated Fuel burned (Quantity 8 type) MWHr generated Number of employees

Chemical use (acid, chlorine, causlic, elc ) MWHr generated Chemical released Quantity of "carrier" C02 emissions MWHr generated Radiation emissions MWHr generated I

number of employees Commuter miles traveled

IS0 14001 Certification ?

3

Facility Reports

Facility Reports

Facility Reports

Facilily Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports Facilily Reports

Facility Reporls

e

Unmanned Jets NO

Work Centers No

Substations NO

\

e

e

l

EMS in Effect 3

BTUlMWH r

NOxlMWHr

Concentration of chemical at release C021MWHr

IS0 14001 Certification 7 EMS in Effect 7

Heating BTUlft2

Commuter mileslemployee IS0 14001 Certification 7 EMS in Effect ?

IS0 14001 Certification 7

EMS in Effect ?

e

MWHr generated Fuel burned (Quantity 8 type)

e . NOx emissions MWHr generated Chemical released Quantity of 'carrier" C02 emissions MWHr generated

. .

Building floor area Fuel burned (Quantity 8 type)

number of employees Commuter miles traveled

e

e

e

e

I

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports Facility Reports

Facility Reports

Facility Reports

Facility Reports Facility Reports

Fazility Reports

Facility Reports

I 1 4

Federal NO

.

Slate

Municipal

.

NO ;

. No

4

e

e

Heating BTUlft2

Solid Wastelemployee

Commuter mi lesl e m ploy ee Business mileslemployee

Heating BTUlft2

Solid Wastelemployee

Commuter mileslemployee Business mileslemployee

Heating BTUlft2

Solid Wastelemployees

Commuter mileslemptoy ee Business mileslemployee

e

e

. . e

e

e

e

e

4

e

e

e

0

a

e

* e

e

e

Fuel burned (Quantity 8 type) Building floor area Pounds of solid waste Number of employees Number of employees Commuter miles traveled Number of employees Business miles traveled

Fuel burned (Quantity 8 type) Building floor area Pounds of solid waste Number of employees Number of employees Commuter miles traveled Number of employees Business miles traveled

Fuel burned (Quantity 8 lype) Building floor area Pounds of solid waste Number of employees Number of employees Commuter miles traveled Number of employees Business miles traveled

INFORMATION SQWRC E

Facility Reports

Facility Reports

Facility Reports

Facilily Reports

Facility Reports

Facilily Reports

Facility Reports

Facility Reports

Facility Reports

Facility Reports

'Facilily Reports

Facilily Reports

I

11 b -Set t O[ TURq METRIC EC E SS ARY 1 N F Of? MATI ON INfORNATlON SOURCE I- t I

No Healing BTUK2 Fuel burned (Quantity 8 lype)

Solid Wastelemployees Pounds of solid waste or students Y Number of employees

Building floor area

5

Facilily Reports

Facility Reports

Commuter 0

mileslemploy ee Business mileslemployee

Chemical uselemployee 0

or student e

Chemical * Releaselemployee or student

Number of employees Facilily Reports Commuter miles traveled Number of employees Facility Reports Business miles traveled Chemical use (acid, chlorine, caustic, etc ) Facility Reports Number of employees or students

Chemical Release (acid, chlorine, causlrc) Number of employees or students

Facilily Reports

SECTnR Medical

SU b - s W NECESSARY INFORMATION - INFORMATION SOURCE

No Heating BTUlft2 Fuel burned (Quantity 8 type) Facility Reports

Solid Wastelemployee or e Pounds of solid waste Facility Reports

Commuter Number of employees Facility Reports

Building floor area

patient 0 Number of employees or patients

mileslemployee Commuter miles traveled

zGIa.3 m M E T R l c ; NECESSARY INF ORMAT ION - INFORMATION SOUR%

Agriculture No Heating BTUlft2 Fuel burned (Quantity & type) Facility Reports

Solid Wastelunit of Pounds of solid waste Facility Reports

Chemical uselacre Chemical use (acid, chlorine, caustic, elc ) Facility Reports

Chemical releaselacre Chemical released (acid, chlorine, caustic) Facility Reports

I

Building floor area

I produce Quantity of produce

Number of acres

' 4 Number ofacres

Trans porta t ion Air ports No BTU 1 square foot

C 0 2 l y e a r Commuter mileslemployee

, Chemical uselflight

Chemical releasedlnight

BusiTrain No BTU / square foot Terminals

C 0 2 l y e a r

Commuter miles/employee

NECESSARY INFORMATION

e

0

0

0

Building area Fuel burned (Type 8 quantity)

Fuel burned (Type & quantity) Number of employees Commuter miles traveled Chemical use (ethylene glycol, etc ) Number of flights Chemical released (ethylene glycol, ctc.) Number of flights '

Building area Fuei burned (Type 8 quantity)

Fuel burned (Type 8 quanlily)

Number of employees Commuter miles traveled

INFORMATION SOURCE

Facility report

Facility report Facility reports

Facility reports

Facility reports

Facilily report

Facility report

Facility reports

RetaillComme rcial

Slrb- s e € t ~ TUerZMETP_IC

SIoreslMalls No Heating BTU/fU

Solid Wastelcustomer or

Commuler employee

mileslemploy ee

1 I N FOR MATI ON SOURCE CESS ARY INFO R MATI 0 N

. .

7

Fuel burned (Quantity 8 type) Facility reports Building noor area Pounds of solid waste Facility reports Number of customers or employees number of employees Facility reports Commuter miles traveled

Office Buildings No Heating BTUlft2 Fuel burned (Quantity 8. type) Facility reports

* Solid Wastelemployee Pounds of solid waste Facility reports

Commuter number of employees Facility reports

Building floor area

4 Number of employees

mileslemploy ee Commuter miles traveled

SECTOR Sub-- ,- Individuals Transportation NO NOXIVMT

COlVMT 0

Miles I Gallon *

Residence No . NOx I Residence I Year

BTU / Residence I Year

NECESSARY INFORMATION

NOx emissions Vehicle Miles Traveled CO emissions Vehicle Miles Traveled Fuel burned Vehicle Miles Traveled

Fuel burned Number of Residences Fuel burned Number of Residences

INFORMATION SOURCE

I/M data - DMV DOT1 DEP I/M data - DMV DOT/ DEP Fuel suppliers DOT/ DEP

Fuel suppliers

Fuel suppliers

\

8

Elements of an EMS for various size businesses/enterprises

The intent is that the environmental aspects of the enterprise are managed to minimize environmental iiiipact. Tlie acliicvenlenl of environmenlnl iiinnagcnieril can be described in three broad categories of environmental activity, superior environmental performance, modest, and nothing more ( i f anything at all) than the basic requirements.

Program Objectives

Generate P2 and EMS awareness in smaller companies * Mandate P2 evaluation and EMS programs in larger companies

Identify good actors Identify bad actors by their absence Create EHS awarddrecognition system Generate usable public information geared to business size Allow for redistribution of enforcement resources

Any enterprise can use a wide variety of environmental tools that can ,e use to in a modest or superior way. These tocds include: EMS D E

Design for the Environment Design for ReusdRecycle Design for Demanufacture Design for X -those criteria that are environmentally significant

Ranging from informed use to End of life direction

Purchase with environmental consideration Environmental considerations are in the purchase specification

Product Stewardship

Vendor and Supplier programs

Environmental reporting Environmental cost accounting Community outreach - expanding communication beyond e report Environmental performance assessment Environmental benchmarking Continuous improvement of the management of environmental impact And others

I Draft For Comment 1/5/99

I

Out comes of successful application of these and other similar tools are: Environmental efficiency and/or effectiveness A basis for green marketing Preferential treatment for

Purchasing decisions Permitting

Cost reduction or marketfperception improvement Superior environmental performance Superior enterprise performance Recognition Etc.

Business Size Stage1 Stage 2 Impact Small

Range of Environmental Response:

1 Meeting Basic Compliance Requirements

Stag 3

Large

I I I Medium

NOT ALLOWED

i

I

Legal and other Requirements I I DWO of the legal and other requirements [tie enterprise nus st nteet. Cornldinnce wi ih l q : ; i l

Training, Awareness and Competence

requirements is the base line from which an enterprise hegins. ( I f legal requirerricnts ;ire a problem, then they should be addressed first, but looking beyond this base line is required.)

I

As apprapria[e, but i f training is done, record? s t i ~ ~ l d lx k q .

Environmental Management Program DWO of the way the enterprise plans to achieve its objective(s)

Structure and Responsibility Assigned responsibility as appropriate, can bc infornlal, ~ ( K S not have ( 0 k written.

~~ ~-

-.___- Conir i\un icatioi\s ? h e policy and objectives should of the program will be us@ to communicate achievernent of (tie sei ot)jcctive flrief regiscration/cerlificaric)n s " m t i letter i l ) a i ihey coritpIetctI [ l i e poiicy ; i r i t I 111.111111itg requirements (half page, written or eleclronic).

publicly cornniunicated. Iriforrii:ilioii ticrivcd ~ I O I I I ( I I I I C I I I ~ L ~ I $

_-

_____ _- ______ Environrncntal Documenta\ion

- -. . .... . h l

.. . .

. .. ..

I

. . .

3 Draft For Comment 1/5/99

...... - __

. . . .

..... .- .....

I * [F u1 JOJ U!

-I

I

IEWAI<D(S) Positive recognition as a srriall enterprise with environriientnlly beneficial ohjcclivcs iii tlic enterprise's program. I<edticed i nspect i on s 'Tax benefits for energy conservation, recycling o r q u i piiicnt invcstriieiit rclnlive to tlic

Compliance relief for work relative to the objeclive. Compliance relief From concentration based limits through use of inass based limits

objectives.

VERIFICATION

s UCCES s Awareness or an EMS that works to reduce the enterprise's impact on h e environment.

-_

All stsgcs

3 2 and 3

I Desiratile I - 3 2 2- 3

I Elpments of an EMS for various size

' busiheaxs . * -

ID#,a:isaTRIReporlkr. !.!'I ,!.,; 1 Anyone with mwrc t h ~ 100 enlployees and nm OF the above rcgulatory rkquirhents.

Environnientiil Policv Written Statement of Environmental Objective(s) signed o f f by top niaiiageirient. --

Pi a n n i n P

Description, written , of how the objective will be met. This includes a process to set the M objectives based on a review of the enterprise's environmental impacts, prioritizing tlic liiglicsi ininacts first.

1 2 pal and ot t I er Rea u i r eiii e n t s Written description of the legal 2nd other requireriients [lie enterprise rniisi nicet. C ' o i i i p l i m x

with legal requirements is the base line from which the enterprise begins. ( I f legal rcrliiireliicrit5 are a problem, then they should be addressed first, but Icmkiiig beyond this h a w line is required.) . ___-

En vir on mental M ana zein en t Ron am Written description of Lhe way the enterprise plans to achieve its objective(&). 17iis rlescrililioii wilt include the resources needed to achieve the objective, including budget and personnel. 'Ilie plan can be held by the enterprise, but must be verified by an independent reviewer.

----I--- Structure and Ilesponsibiliry -- Assigned responsibility as appropriate, will be formal, d t m have i o tw written tw c x t tx tlclti b y (lie enterprise for external verification. -__ . . . . . . . .

__ . . . - .

. - -. Training, Awareness arid Corripetence I I As appropriate, but must done and records kept to denionstrare that each r i ie r i i t x r of the -

6 Draft 1% Comrnent 1/5/99

Environrneritai Docurnentation

Control I’rocedures for Ik~ur ine Onerations

Monitoring and Measureriicnl

1 I Noricorif~~rriiance, Corrcctivc Aclion

‘Ilie policy and objectives should be publicly coiriuiunicated. I i i for i i int ion tlerivctl rrorir other parts of the program will be used to coniniunicatc achieveincnt or the set olljective. ‘Ilic communication will be public, inclutlinc, cnoucli inforinntion to descritx tlic o\)jcctivc(s) a i i t l i1:it;i - - to show progress or success. Confidential business information (Ct31) is protcctctl. Brief registration/certification statement letter that iticy completed the policy, pliiiiiiirig :iii(I lcgzl requirements; TRl reports (or TRI like), form S like use balnnce (CUI) (written (x clcctroriic).

As needed to verify the steps to reaching the ot)jeciive(s). This infornintion will Ix: nv:iil:il)le fo r third party verification.

Formal, paper or electronic. Needs to exist, bur may be part of CIY

Formal. written and managed. Reflects the steps needed to achieve the objective.

As needed and as is appropriate for the enterprise. This is a formal process [hat examines [lie risks and emergency scenarios that could happen and prcpares response plans to deal with lie emergency.

I

As needed to actiievc [lie objective and demonstrate success or provitlc t l i r e c i i o n in acliicvini; rlic

objective. The r ~ ~ e a ~ u r e n i e n t ~ or data used rimy be CDI. so provisions sl~oultl Ix: ~ r ~ a t l e to Tor o i l i c r n m n s to dernonstra\e success in external cor1iiiitlnicntion. miis i s prirrinry an intcrn;iI ttxl l. I t will

I

_-

--I__ I__ __ .- bc subject to third party verification.

I and Preventative Action Forrnal arid appropriate to correct problems in achieving the objective(s). 'Iliis i q aii i n l e t iinl riiechanisni that uses monitoring data to track progress and rrlake necessary progrniii atljiistiiicnlr, along the way.

Records I 1

_-

Audits I===

pub1 ici zed objectives. Reduced inspections. Tax benefits for energy conservation. recycling or equipment investrrient relative lo t h e o bject i ves.

__

-- -

Management Review

--_____

Ektemd to thekogram

IEWAKD(S)

I I

t \

AS needed to demonstrate achievement of the objective and existence of thc ~ U I I I C ~ ~ I I S parts of l l i~ management program. Records will be formal, available and managed.

Will be formal, not by the group being audited, and an adequate sampling to give awrance tha t the area being audited is performing as designed in the management system.

Done by management at a set review period to examine the program and objectives, corrccl problems, and assess achievement andlor establish new objectives.

: j . , . . . . . . . . . . ..., . :. .;..*!;,, i , ; ,* :~ . f~Ok#f-6~' f l . .,:.'.,!., '. ...; p..;: :.,'.;'. .:_ . . . . . . . . . , , : , ' . . . ' : . . . ,

Sariie as i n section Srllall

1 - / - ! ) u ~ i n e s ~ Positive recognition as a medium enterprise with environmentally beneficial program5 anti

- _ V ERI I'IC AT1 ON

Self certification with periodic agency audit. ____- -

-

8 Draft For Comment 1/5/99

Use of independent Third Party Use of established trade association prograrn. Use of established P2 entity, OTA, TUN, etc.

I

Written description of h e way the enterprise plans to achieve i ts objective(s). ?lii$ dcscr i p t i ( i i i

will include the resources needed to achieve the objective, including butlget a n d perztiriiicl l l i c plan can be held by the enterprise, but musl be verified by a n independent revicwcr.

--__A

I'lnnnin 1

I_ -_ .- .

.

I

Ihxriptioii, written , of how the objective will be met. Xiis includes a prtmss 10 set [lie objectives based on a review of the enterprise's environrnenlal irnpacls, prioritizing the tiiglicst impacts first. A listing of tlie environrneutal ttxds lliat will tx used in the rnnnngciiiciit progrniti and the reason why. .. . .....

- - Written description of the legal and ollier requirernenis the enterprise must riicet Coiiipiixitc wirh legal requirernents is the base line froin wliich the enterprise txgins. ( I f 1eg;il retjuirciiiciit\ are a problern, Uien they should be atldressed first, bur looking beyond th is tnse line is reclciirctl ) 'Ihe other requiremenls include pollution prevention and l i fe cycle nssessrnent of the oprrntioris and products of the enterprise. l-

Environmental Management I ' r o p n m 10 Draft For Cornment 1/5/99

__- Structure and Responsibility

Assigned responsibility as appropriate, will be formil, t lws have to be written Out c;111 Ix: licltl Iiy the enterprise for external verification. ---

Doc 11 111 e 11 t Con 1 rot

Formnl, p p c r or elcctroiiic. Needs to exist, but may be part of CIII

Control Procedures for Routine

Training, Awarcness and Conipetence I L-_____ I I AS appropriace, but must done and records kept to ctenioiistr;ite t~iat e:ic\i iiierlilxr of i ~ i c ciitcrpr isc

th i rd party verification. These d c a " t s will derail the steps, inclutling training tiiat a re i l w i to achieve the objective. __--

__-

1

--

Corniiiuriicntioiis The policy and objectives should be puhlicly con~rtiur~icated. lnforitiatiori tlcrivctl froiii oilier parts of the program will be used to c~iii i i i i~~iicnte achievenient of the sei thjective. ' 1 1 1 ~ cornmuiiication will be public, including enough iriforrnation to (lescritz the ot)jectivc(s) ; i r i r l t h t : i

to show progress or success. At a niinimunr, tire enterprise will issite an enviroiii~ient;~I rcptxt. Confidential business information (CBl) is proiected a n d i f neetletl in tltc enviroririiciit;~l rcpcn t will be reported as indices or other appropriate itieasureiiierit. Rrief regislration/certificacion statenlent letter i l lat they conrpietecl the jwlicy, pliiiiniiig ;111tl I [ b v i \ I requirements; TRI reports (or TIU like), forrn S like use balance (CI31) (written or elcctroriic) ____

h.1

I--- Emergency Preparechess - I 1 AS needed and as is appropriate for the enterprise. T > i s is a formal prmcss t i i a c exatiiirics i ~ i c -1- .

3

i - l

- .. . . -. . . .

. . ..

1 1 Draft For Comment 1/5/99

- I

I VERIFICATION

I Self certification with periodic agency audit. I Use of independent Third Party, such as an 1SO 14001 Registrar.

SUCCESS A robust EMS h a t continually examines the progress of managing the environnicntiil a\pcct$ o f the enterprise to best manage the enterprise's impact on the environnient. Reduced environmental impact. Superior environiiiental performance.

End of file shg 12/31/98, 1/4/99, 1114, 116 last edits

13 Draft For Comment 1/5/99

3 3

3 1-3 2 - 3

.___

Measuring Environmental Performance

L:'ncrW/(;lo bal Warming 0 Pounds of Carbon emitred

Gk'P (Global Warming Potentid of p ~ l l ~ t s n t s mcasured relative to the effect of C02) % of.energy as a renewable energy source energy use per unit of product (process & embedded)-

Hcali h/En viromeniai Impact POCP .- Photochemicd Ozone Creation Potentid measure relative to the effect of ethylene. AP = Acicfification Potential measwe relative to the effect of SO2.

.I Eutrification (e .g biological oxygen demand of effluent) water use per unit of product

Chcmicai/Toxiciry 0 Ibs of TURA chemicals usedlshippd/byproduct -- % change non-nalizcd Over . time .I measure of material toxicity (e.g., m A SAB lishng)

lbs of endocrine disrupting chemicals

Prodrr cis % takeback of product

e

% product i s recyclable

e solid waste per pound of product 0 % organic raw materials .I % organic products

energy use to transport raw materials and products rcduction in particulatc or CO emissions

Yo recycled content in product

Other

[Jnits absolute normalized

e.0 annual numbers expressed as a rate

ODDS and EXITS: Here are some additional thourhts - which build upon ideas generated b:. Barbar3 Kelley. Ijnfortunatel).. time did not alloiy us to research th; issue beyond a \‘en. cursory look nor did we have a chance to talk to Some keq’ people who may offer some real support to this effort. Measures of Success:

Compliance with environmental laws for specified period of time Articulation of an environmental policy for the toivdcity at the highest levels of - government and the setting of environmental goals. Delineation of P2 responsibility w i h n the management and employment SUUCture reaching all levels. Coordination of oversight of purchasing, leading to materials tracking and accounting, the purchasing of environmentally preferred products, the use of state contracts for more environmentally friendly services or products, the close scrutiny of toxics use and periodic examination of alternatives, BMPs and ITS. Training EducationlOutreach on environmental issues/concems Active recycling program (recycling report card) Inflow and Infiltration program Emergency Preparedness Plan and active LEPC Spill Control and Prevention plan Master Plan or other bylaws for growth. including I aquifer protection bylaw, and other open space initiatives such as land trusts. conservation easements, etc. Stormwater Management Plan Water Conservation program Energy efficiency efforts P2 committee Fiscal initiative to examine full life cycle Costs of equipment and product purchasing Active in watershed initiative Use of ITS Active underground storage tank management HW Collection Days DPW and other maintenance garages f o l l o ~ ~ steps outlines in CR4SH course booklet Employee accidents reduced Compost program

1. POLICY AfuT RES30NSi3ILITy.

A. Eave they established responsibility within management and the employm=.r,; structcre?

r ~ l e of the employee o r manager? 5. Does responsikility reach all levels? Is it appropriate to the

r o r exaxiple, Upper management has the responsibility of Creating a ?2/EMS policy and ensuring that it is a priority.

Financial managers have the responsibility of conducting cost evaluations of P2 alternatives that take all costs of current practices int considsration, including potential environmental and public health harms.

Purchasing agents have the responsbility of considering the cost of disposal when buying hazardous materials, ensuring MSDSs are obtained, and arranging for trials of environmentally preferable alternatives.

Line supervisors have the responsibility of ensuring hazard communications, evacuation and response training, and p2 actions are conducted.

I\IEASURES Include:

Existence of environmental compliance monitoring activities

of these duties.

2. Materials Accounting

Qi 0 V I IJ

1J id Isl a, c m id

rl r-i a, 3

m m aJ U 0 7 m >I 0

tI.1

m $

a1 U d

..

F'2 Blue Ribbon Panel Kovember 19,1998

Possible P2 ObjectivedGoaIs

Universities

Background

Universities have a significant impact on resources. The breadth of their operationslservices, along with their size make them equivalent to small cities. The major difference, and an advantage relative to P2, is that these services are more centrally provided to a concentrated population. - -

Many of the opportunities and corresponding metrics that are available to large institutions and state agencies, are applicable to universities and colleges as well.

However, there are a variety of factors that make P2 assessment and measuring more practical and effective then with state agencies. Examples include:

*

*

*

More direct and measurable financial incentives; More centralized and structure management structure; Increased environmental awareness and commitment of the students and

faculty in comparison to the general population; and

The potential for transference. universities can serve a s potential pilot sites for assessment of societal ~2 strategies. Successful program strategiei can be

developed in.a semi-controlled environment such that the means for

transferring them to cites and communities can be understood.

Potential Performance Indicators

M y discussions with university EHS managers and a review of available literature indicate that active P2 assessments and planning are being done by a number of campuses, but no common metrics are being used. Based on my experience and discussions, possible indicators of a university's performance have been separated into two categories. The first consists of metrics that already exist or are easily obtainable and can be used in direct comparison with other campuses. The second category consists of useful metrics that could be devefoped that would provide the university with ongoing performance information, but would be difficult to use in a direct head-to-head comparison.

Comparative M etrics

Catecroq

Worker safety

Metric Possible Goal

< average rate lost work days (workers comp)

Solid waste % of solid waste recycled > '00 statewide soat Energy EPA Green Lights program Green Lights PaiC:ner

Purchas:ng Air Pci:s;ion Ride Snare Program

% of zcst-consumer recycled products curchased

Non-comDarative Metncs

Cateaorv . - - Metric

Energy conservation - Energy consetvation

Solid waste

Hazardous waste

BTUs consumed / heating degree days

KWHs consumed / cooling degree days tons / person (students, faculty, staff) / year

chemical use / waste ratio Water conservation

Chemical use Chemical use

Purchasing

Air pollution

Air pollution

gallons / person / year Ibs. fertilizer and pesticides / acre / year laboratory chemical purchasing program?

Ibs. of paper / person / year

## of staff and student parking permits

Ibs. of VOC from solvent based paints applied

* The general model for implementing and measuring would be the Clean State Initiative. The universities would evaluate all or a selected set of the Ctean S!ate categories and for those areas determine the financial and environmental impact and set goals accordingly. A plan could be made available to the university community for comment and input.

The k e y s to success would be linked to:

*

*

A comprehensive, yet flexible program; A reliance on internal pressure from students and faculty to facilitate change; and

Methods to recognize and reward the best programs. Rewards could be in providing a higher priority to research grant applications, state funding incentives, reduced regulatory reporting andlor relaxed enforcement.

From: Harry Fatkin charryfratpin~email.msn.wm> To: Gina McCarthy Cmgina mccarthy@state.ma. us> Date: Tuesday, January 12, 1999 7:07 PM Subject: Global Reporting Initiative

-

Gina:

I have FAX& you copies of several pages from a. recently released (Jan. 7 1, 1 B99) draft of the Global Reporting initiatrve (GRI) entitled 'Sustainability Reporting Guidelines'. This document is 42 pages long, so I have pulled out and sent you those 13 pages that seem most relevant to the current discussions of the 'blue ribbon panel' regarding 'environmental performance indicators'.

As you may recall from my discussion of the 'Greening of Industry' conference, GRI is a currently active international effort to develop giobal guidelines for 'sustainability' reports. The Jan. 11 draft guidelines reflect GRI work since 1997 and are being circulated for involved with GRI. These draft guidelines will be updated and used throughout 1999 by various parties before being finalized early in 2000. One of the pages I am sending to you contains a Iirrt of GRI steering committee members. As you c a n see this is a broad and diverse coalition from many parts of the world who, in tum, work with hundreds of others on this subject.

While these guidelines are broader than many 'environmental p e r f ~ r " c s . indicators' currently being discussed by the blue ribbon panel (and, I have not included 'sustainability guidelines'), these may be useful to help frame our discussion. If successful, GRI will become widely used throughout t h e world.

merit by those

Harry Fatkin

I I IZ IYY

PiiEAMBLE 1 WHY THESE GUIDELINES HAVE BEEN BEVELOPED

3 WHO IS ENCOURAGED TO USE THESE G U I D E L I N E S ? 4 THE VALUE OF THE GUIDELINES 5 STRUCTURE OF THESE GUIDELINES 6 GENERAL REPORTING PRINCIPLES 7 8 9 10 CONTINUING EVOLUTION OF GUJDEUNES

2 WHAT THESE GUIDELINES PROVIDE .

SPECIFIC ISSUES TO CONSIDER WHEN USING THESE GUIDELINES INDEPENDENT REVIEW / VERlFlCATloN OF SUSTAINABILIM REPORTS RELATIONSHIP WlTH OTHER REPORTING GUIDELINES

G UI GELINES

PART 3. PROFILE AND FINANCIAL PERFORMANCE PART 4. POLICIES, ORG IZAT1ON* AND MANAGEMENT SYSTEMS PART 5. STAKEHOLDER RELATIONSHIPS PART 6. MANAGEMENT PERFORMANCE PART 7. OPERATION& PERFORMANCE PART 8. PRODUCT PERFORMANCE PART 9. SUSTAINABILlfY STATEMENT ruCLovQD)

APPENDICES A. GENERAL REPORTING PRINCIPLES 8. EXPLANATORY NOTES TO THE GUIDELINES C. DEFINITIONS (FORTHCOMING) D. GRI STEERING COMMITTEE MEMBERS

These qualitative characteristics are discussed in more detail in Appendix A.

Underlying Assumptions

financial reporting also has adopted a set of assumpbons and pnnciplea that underpln all reporting and have, wlth some necessary modifications, b m adopted by the GRI as underlying assumpt ions for sustainability reporting. These are: - The entity assumption-a clear definition of boundaries of the reporting entity

Tnese ur&rlying a s s u m p t l m am discussed in mum detail tn Appendw A

Hierarchy of Performance Roportlng Elements GRI h a s adopted the following hierarchy for organizing and presenting environmental i ~ f c ” t i 0 n in sustainabillty reports:

Catagory (i.e.. general class or grouptng of ~ S S U ~ S of concern to stakeholders), e . g . , sir, energy, labor practices, local ewnomic impads.

(I

Aspect (Le., specific issue about whicf, infomation is to be reported), e.g., s m W preCUn;Ors, greenhouse gas emissions, e n e q y w n s u m d by swne, ene rgy sffclenq. child labor practices, corporate giving to host communities.

7. SPECIFIC IS Disclosure id Reportlng Principles

he principles applied in preparing and in the reported infomation,

* That they have been prepared Sustainability Reporting Guidelines

sented in accordance with the GRI

d previously, and (e.g., significant changes in composition Clf

company, change of be rslperiods, nsture of business, measurement methods);

The basis for any con s of, e Q ~ mass, volume, energy, or currencies;

ur8ment rules a p p l j d to data compilation and how the principle has been applied in deciding what to report, W h a t

on joint venturas, operations of partially owned subsidiaries, utced operations and other situations that can s igni f ian t l~

period to period €Ind/Of b e b e e n companies.

PART 1; CEO STATEMENT :

Linkages beween sustainsbllity and financial pertormence. Challenges of sustainability for global operations, if sppficable.

Discussion of verification.

Ad<nowledgement cf suCt88ses and failures.

Performance on benchmarks versus ampet i ton and previous Years.

Major sustainability challenges for your business sector 8s a Whole.

PART 2: K E Y INDICATORS

3.7

3.9

5.2

6.2

7.1

7 .2

7.3

7.6

7.9

7.12

7.14

7.16

7.18

Total fuel use. Total materials use other than fuel Total water use, excluding cooling water.

Quantity of NPO retumed to process or market by recycling or muse type by material type (hazardous O r nut hazardous under applicable national, sub-national. or local laws Or fegUiation) and by on- and off-site management type (me., mcycled, reused, remanufactured).

Quantity of NPO to land by material type (hazardous or not hazardous under appllable nationall sub-national, or local laws or regulation) and by on- and off-site management type fe.g.+ lnclneraled with energy recovery, landfilled, deep well injected).

Routine emissions to air, by type

Routine discharges to water, by type

3.4

3.2

3.3

3 4

3.5

3.6

3.7

3.8

3.9

3.10

3.11

3.72

3.13

3.14

3.15

; p n w s e s intended to futfiil that commitment. I

4 .2

4 .3

4 . 4

4.5

Implementatton of management systems, praci~ces g procedures, e.g., environmental nsk a S S ~ S m " , emploYW onentation and wareness programs, emergency response training, wmplianw auditing End reporting, environmental accounting, performance evaluation F f o c a 8 3 6 S , intf" communK3tions, compensation linkages, and countries of applicability.

Management systems for supplier and supply cfrajn (incfuding outsourcrng), including selection criteria, training, monitonng, and other pmwdums'and practicas, and countries of applicability.

PART 5: STAKEHOLDSF? RELATIONSHIPS

1 Information on t he procEss and me!hods by whi th stakeholders are c n g a g d by t h e =mPany 1 to help achieve r?s sus ta inabi l i ty goals.

5.5 Plans for strengthening stakeholder wnsuttation.

6.3 Reeponse d management to improve pr fomanca noted in items 6.1 and 6.2.

P E ~ T A I N I N G TO INTERNAL POLICIES AND STANDARDS A N D VOLUNTARY ~NITIATIVES

6.4 Performance regarding internal policies and s t a n d a r d s , and voluntary initiatives discussed in Part 4 (excluding supplier issues).

6.5 Response of management to shortfalls noted in item 6.4

EXTERNAL RECOGNITION AND ACTIVITIES

6.6 Awards received in the reporting period regarding environmental, social, ethical, ecoflomic~ Of

similar performance and activities. Reasons for such awards.

6.7 Status and date, by country, d environmental, social, ethical, economic, or similar external certification (e.g., EMAS, IS0 14000, ISEA, SA 8000).

6.8 Other external activlties.

SUPPLIERS 6.9 Supplier performance per item 4.5.

6.70 Indicators of management performance na a d d r e s s e d e l sewhere arising from stakeholder engagement discussed in Part 5.

Cr rrncr rr~c ,uS

PART 7: OPERATIONAL PERFQR MANCE

1 inaicators of the reporting entity's operaionaj performance regarding kay aspezs of '

HEALTH AND SAFETV 7.1' Standard indicators of cccupatiorwl health and safety.

ENVIRONMENTAL PERFORMANCE Energy - m e s in Joules

7.2' Total electricity use. Amount purchased, by primary fuel source. where known. Amount S d f -

generated (describe source)

7.3' Total fuel use. Vehicle and non-vehicle fuel, by type.

7.4 Other energy use (e.g., district heat).

7.5

Materials - vstlves in metric tons

7.6'

7.7

7.8

Objectives, programs and targets regarding energy use and progress toward same.

Total materials use other than fuel, including definition and how calculated.

Obpctivas, programs and targets regarding materials use and progress toward same.

Objectives, pmgrams 8nd targets mgardlng procurement and use of virgin and reclaimed materials and progress toward same.

Water - yj~lues hr liters

7.9 Total water use, excluding cooling water.

7.10 Total use of water for cooling.

7.7 1 Objectives, programs and targets regarding water use and progress toward same.

Non-Product Output - values In metn ' c tons

Non-product output (NPO) is defined as waste prior to treatment, off-site recycling, or disposal.

Nan-Product Output Retumed to Pmcess or Market

7.12 Quantity of NPO retumed to process or market by recycling or reuse type by material type (hazardous Or not hazardous under applimble national, sub-national, or local laws or regulation) and by on- and &-site management type (e.g., recycled, reuaed, remanufactured).

Objectives, programs end targets rsgadng non-pmduct output returned to process or market and pmgress tward same.

Quantity of NPO to land by material type (hazardous or not hazardous under applicable national, sub-national, or local laws or regufation) and by on- and off-site management type (W., inanerated with energy recovery,.landfiIled, deep well injected)

Objectives, programs and targets regarding non-product output to land and progwss t0wa-d same.

7.13

"-Product Ootput to Land

7.14

7 14

Non-Produd Output to Air

7.16'

7.17

Routine emissrcns to air, by type.

Objectives, programs and targets regarding routine air emlsaions and P W F s t o w a d same.

Nan-Product Oufput to Water

same.

Indicators of operatiomi performance not address& elsewhem anslng from stakeholder engagement discussed in Part 5.

STAKEHOLDFF? INDICATORS

7.20

PART 8 : PRODUCT PERFORMANCE

8.1’

8.2

8.3

8.4

8.5

Mapr pOSltiv@ and negative impacts associated with the life cycle of products and S B r ” wrth qusntitative estimates of sufi5 1mpac:s.

Formal, written commrtments requiring en evaluation uf life cycle impads associated wrth the use of new and existing products and SepIcBs offemd, end proce~lurws in place to moni:cx this commrtment.

Programs or prmedures to prevent or minimue potentially adverse impacts af products and services.

Procedures to assist product and service desimers to create produds or 36NIC85 w t h reduced adverse life cycle impact

Indicators uf product pcsrfonnance not addressed elsewhere ansing from stakeholder engagement discussed in Part 5.

G GO E Roger Adams. Association of Chartered Certified AnOUntantS

Ani1 AQawat, Centre for Scknce and Environment Msrk Bsrtetman, Investor F?esponsibility Research Center Nancy Benne!, United Nations Environment Programme

Maria Emilia Correa, CECODES (Colombian Business Council for Sustainable Development)

John Elkington, SustainAbilrty Magnus Enell, ITT Flyst Toshihiko Goto, Environmental Auditing Researcfr Group Heinnch Hugenachmrdt, U B S AG

Fmm Knecht, E2 Management ConsuRtng Markus Lehnl, %rid Business Council for Susteinable Devetopment Robert Kinlach Massie, Coalition for Envimnmentaliy Responsible Economies Judith Mullins, General Motors Amy Muska, Council on Emnomic Priorities Janet Ranganathan, World Resources Institute

Allen White, Stockholm Environment Institutfietlus Institute

Alan Willin, Canedran lnstitute of Chanered Accauntanrs Simon Zadek, New Economics Foundation

- .

Hazardous Waste Management Program

EnviroStan Rating S W m

11/18/98

For your business to receive the Green Star it must comDiete a minimum of twdve of me

follo\h..ig eighteen &ndards. These standards were designed for all businesses regardless of see or typo Detailed Informahon on h w to implement these standards is provided in our booklet (Reaues t a b o o k l e t )

- - FIRST. CO MPLETE ALL 0 F THF FIRST SIX

1. A ~ p o a t , u d & c u h t a h G r s r , S t u p d l c y ~ (a yarr m-&nl of It) tu an yw snpbybsr.

2. DaslgndsaGrmnSbsMnrtoraTarn.

3. c w d u d a n ~ w a c s ~ ~ .

4. PIwidathnsincdms NtraidngDppaBntba ‘tt.st v ” w l = l t M d - p U t i Q p d t b n l n h plqpam.

11/18/98

LEVEL TWO

1. Energy Cwwrvatioa .

11/18/98

REA GREEN BUSINESS PROGRAM

- §ERVATlOh AND

POLLUTION REVENTION CHECKLIST FOR THE Co

March, 1997

1. Have your lDcaf energy utility or an energy service company conduo a commercial energy assessment of your facility. Use informadon from the assessment 10 develop a w ” n plm ta implement suggestiom.

2. Perform regular maintenance on and 3a. Demonsnare a 15% reduction of your annual energy use. or 3b. Impkment TWO akemauve technologes and five k h a v i o d changes.

h e a w , ventilation and air conditioning (HVAC) syxtem.

Exam+ of dtrrnatfvt ttchno-: s 4 s

5 5; .S S Useceilingfans. S $ S

*

InstalI bghting fiures that were recommended in your energy &esxn”e. use energy efficient light bulbs and timer controls. Use Iighrlng output controls such as txcupancy sewrs, bypaddelay timers, photocell. time clock. Use office equipmenr with energy saving f e a m . Use both emporative cooling ad ice making to reduce cooling costs during summer months. Use n a d gas instead of elecn-fcfty for hearing.

Replace or supplemenr your air conditionkg system with an evaporative cooler. Use economizers on the air conditioner to increase air circulation. Use window fllm to reduce solar heat gain or when replacing old/broken windows install e-

Planr trees and plants, especially in areas wit& high sunligfit impact to help reducing your need for air conditioning. (Check for the native plants that are used to the climate in order to k q your water usage down as well.) Mention where information can be obtained. Install transparent swinging doors to separate large work areas were possible. with ihfs, work areas with less traffic are not influenced by Mgh traffic lines, and the demand of coohfleating can be reduced. Use standby option or ramfit your old photopmessot/press unit with standby optlon. (Not for very small units.)

Exampfcs of bchavkxd change: 9 Disconnect unused ballasts in fixtures that are not currently in use and replace burned out lamps

quickly to avoid ballast damage. $ Make a shop policy to turn off lights and machinery when not in use. 5 Clean Iighting f k ” s once a year. $ Plug all equipment that can be tum& off into time switches to make sure It Is turned off after

hours. $ Insulate hot water pipes to and from the boiler system and check for the right setting. (warm

water for lavatories or kitchens does not have to be boiling.) a Reduce the use of boilers in the m e r months. $ Insdate all indoor and outdo~r heating and co~ling @@ducts and add insulation to the

buflding where “/possible. s hs‘cd Witches on ndiant space hearers.

windows. (Cl!erk if it;lt?rc. 2m O ~ I ~ I S for di5co:oruJt.s.) l

*

*

March, 1997

2

1. 2. and 3a. Demonsnare a 15% reduction of your annual water use. or 3b. Implement three water consenation measures.

Simpie water conservation meaffures: s S $

5

Conduct an indoor/outdwr water M m c e Gi assatssmenr of y o u facidiy. Implement all applicable simple conservatizc measures listed below.

h a m how to read your water meter. Understand your water bill and monitor it monthly for early indications of problems. Regularly check for and repair afl leaks in your facility (toilet I& can bc derecred in tank toilers with leak detection tablets). Properly maintain and use your irrigation system:

Repair all broken or defective lines and emitters or sprinkler heads. Adjust sprinklers for proper coverage. Adjust irrigation timeddurations according to seasons; water during non-daylight hours. -

Examples of a d d i t i d water conservatkm measures: If you clean floors with water:

- use high-pressure, low-volume cleaning equipment; use a recycIing filtered system such as an electronic powered cleaning machine; use mop and bucket rather than hosing; convert to dry clean-up methods.

Use air cleaning methods where appropriate. Document clean-up policies: include water saving plans. Use wafer displacement devices or quick closing flapper valves for tank toilets *installed prior to the mid 1980s. Note: some water utfIltIes provide these fiee-ofcharge to customers. Use volumereducing diaphragm kits for valve toilets installed prior to the mid 1980s. Note: some wafer utilities provide tfiese fiye-oficfrarge to customen. Also note that the tolief is already water conservtng JY an AS@ or AL@ is printed on top of the toilet valve lid. Use toilets with ultra-low-flush (ULF) features. Adjust the water level in toilet tanks to one inch below the top of the overflow tub. use sensor-operated fixtures for employee and visitor rest" wash stations. Use low-flow faucet aerators: 2.5 faucets; 1.5 gpm or lesson lavatory faucets. use low-flow 2.5 gpm or less showerheads. Use positive shut-off nozzles on all hoses. InStall rain shut-off devices or moisture sensors to override automatic irrigation when adequate moisrure is present. Limit the number of days lawns are irrigated to a maximum of three days per week during summer, two days per week during spring and fall, and none during winter. Limit the "her of days trees and shrubs are irrigated to a m m u m of two days per week during s u m " , one day per week during spring and fall, and none during winter. . Install a drip irrigation system, especially fn areas that are difficult to irrigate such as narrow

per minute (gpm) or less on kitchen and break-room

March, 1997

4

7

ccononii: activity

Y cs

Y c s

Step 2 - Wti:if is Cu:ii or YZ?

I -

C O M O D I ~ SPECIFIC DEFINEIONS

Edited by: Craig S. Hollingsworth, William M. Coli & Ruth V. Hazard university Of Massachusetts E x b s i o n Ifltebmted Pest Management Pmgram

. . . ; , . .'. .. . . t ', .- . . . . .~ ,

r;. :' ' _ c - . J ;. . . . . . 9 . . .: ': ,. . , .. . .._ .

.--. . . . . - . - . . . .

I -

. .

ki

SWE? Of

Massachusetts Integrated Pest blanagemcnt Guidelines: CO m modi f5ir 5 p e c i f ic D efin i ti o n s

htegra ted Pest Management. is a svs tem aDproach to pest management that considex 25 factors affecting the crop health, Indudlng plant nutrition and hor t id t -urd pracbces, as well as elements of insect, disease and weed suppression. Pest control tactics may include biologica!, chemical, and cultural or nechanical methods. While an given crop will incicde some essential elements, some practices u d not be appropriate in all situations. Thus, a commodity spec3ic definition of LPM must be flexible.

ProFam for a

These g u i d e h e s are designed to help farmers and others document - whether a specific crop has been grown using an IPM svstem. The guidelines were developed for use in two IPM verification programs in Massachusetts: t he USDA Farm Service Agency (FSA) Integrated Crop Management (ICM) cost-share program (SP-531, and the Massachusetts IPM certification program, Partners with Nature, a collaboration of University of Massachusetts Extension, Massachusetts Department of Food & Agriculture and USDA E A . Guidelines have proven useful in describing the scope and ccmplexity of IPM to farmers, government officials and to the general public, and for UMass Extension to determine educational program needs. Whether a grower is enrolled in a verification program or not, guidelines can be used as a checklist to identify areas where pest management efficiency might be improved.

As a measure of grower implementation of an IPM system, the guidelines use a point system. The intent of this approach is to provide flexibility while encouraging growers to gather all appropriate information and to.&e-this . . information in making management decisions which are most suitable for a specific situation.

Guidelines were developed by consulting with growers, university faculty, extension specialists and private consultants to obtain a list of best management practices. Additional grower input was solicited from con-”j.Ity associations and participants in II‘,M verification programs and IPM short Courses. Practices were evaluated for practicality and weighted bv their difficulty and importance to II‘M The guidelines have been tested and adjusted for up to five Seasons (1990-1995) through the E A ICM cost- share program and three years (1993-1995) through the Partners with Nalure program. Glidelines for peppers and pumpkin/winter squash are to be evaluated for the first time in 1996.

1

These guidelines represent the best management options currently available to ihlassachusetts growers for nine frui: and vegetable crops. We expect these guidelines to evolve with the development of new IPM t e h o l o p e s .

In using the guidelines for qualification in the Massachusetts for E A ICM cost-share and/or Partners with Nature programs, the following criteria are used:

Crop must accumulate 70% of the total points from applicable practices. -

Some practices will have no applicability to a specific farm. These practices are .preceded with such phrases as "If ..." or "Where appropriate,...". Points for these .

practices may not apply to presented by the grower.

Partial credit can be earned appropriate practice.

the "total possible" points, if suffiaent justification is

for a given practice by completing a percentage of the

Bonus points are given for experimental practices. Bonus points are not included in "total possible," but do count toward the total points earned. . .

Points must be earned in each category.

' To leceive Credit, practices must be documented by M t t e n , I records (e.g. dates and . .

rates of applications of fertilizer, dates of sprayer calibrations and pest scouting records), where appropriate.

.,., .. /.

Soil and Nutrient Management and Cultural Practices

1. Trees are pruned during dormancy so that spray penetration and air circulation are

adequate. 10 pt: 15 pk

5 pts

10 pts

10 pts

10 pts

2. Summer pruning is done on densely foliated, vigorous trees.

3. Prunings are removed or destroyed such that no residue is present after one year.

4. A complete leaf tissue analysis is-performed in the current year. -

5. Fertilizer amendmerits are applied according to previous year's leaf tissue analysis.

6. Orchard renovation (4% of the orchard or greater) includes size-controlling

Pesticide AppIication and Records Only pesticides approved and registered in the state will be used. Records of pesticide

rootstocks in the new plantings.

applications (including date, block idenfificntion, targeted pest, pesticide name and EPA number, rate and numbtr of acres treated) are maintained. Pesticide drift is minimized.

1. Orchard sprayer is calibrated accurately at the start of the season.

2. Herbiade sprayer is calibrated acmrately at the start of the season.

3. Orchard sprayer is recalibrated at mid-season.

10 pts

10 pis

10 pts

10 pts 4. The grower has calculated tree-row volume for each block and appfications conform

Insect Management

Insect Monitoring Monitoring must be carried out in a scientifically valid manner. Records should be kept of all

to tree-row volume calculations.

monitoring informatio?z collected.

1. Tarnished plant bug adults are monitored by w h t e visual traps 10 pis

2. European apple sawfly is monitored by white visual traps.

3. Fruit is monitored for plum curculio injury.

10 pts

20 pts

4. Foliage is sampled for mites and mite predators.

5. Apple maggot is monitored by red sphere traps.

18 pts

20 pts

3

6. Leafminers are monitored by i d visual traps or foliar monitoring of first generation mines. 10 pts

7. Terminal foliage is monitored for aphids and a p k 5 predators 10 pts

8. Foliage is monitored for leafhoppers. 10 pts

9. Bark of trunk and limbs are monitored for san Jose scale, woolly apple aphd and borers, where appropriate. 10 pts

10. Monitor fruit and/or foliage for codling moth, fruitworm and leafroller larvae or injury, where appropriate. 5 pts

Insect Suppression -

1. Application of insecticides corresponds to pest thresholds ranges specified in State apple IPM pubbcations. 25 pts

2. One application of dormant oil is applied. 10 pts

3. A second application of dormant oil is applied. 10 pts

4. Border spray is used for one or more of the pesticide applications against plum

5. Biological control by naturally occurring predators is used for control of aphids,

6. Mite suppression:

. curculio and/or apple maggot. 10 pts

when conditions pennit. 10 pts

a. Biological control by naturally occurring predators is used for control of mites: 10 pts

' OK b. Summer oil is used in part as a substitute for other acaricides in suppressing

10 pts

20 pts

no miticide is applied.

mites after petal fall.

mites and wooly aphids. 7. Synthetic prethroids are not applied because they are likely to induce outbreaks of

9. Where appropriate, application of pesticides for mites, aphids or apple maggot are reduced by one-half of the labeled rate, as defined Sn the Nao England Apple Pest Management Guide. 10 pts

10. Orchard is surrounded by odor-baited red sphere traps at a rate of 3 trap per 15 f t in lieu of pesticide application in lieu of pesticide application against apple maggot.

BonUS: 30 pts

11. All abandoned apple trees within 100 yards of the orchard border are removed to prevent codling moth immigration. Bonus: 15 pts

4

i

1. First fungade spray is delayed an appropriate time accordmg to ascospore development and from previous year's ascospore density and scab incidence.

15 pt:

2. For each of fhe/o~~auring scab " g t m m t Q F p i C k , the apmoprzkte m" of fingicrde appfiurtions p u season may vary between 2 and 6 per !em, depending on Condltlons.

a. Unless visible infectiors develop, fungicides for scab management are applied only until the end of primary scab season (as defined by ascospore maturity and release) 15 pts

b. A combination of tree phenology, ascospore maturity and Mill's infection periods 10 pts

15 pts

. OR

are - used to guide fungiade application deasions. OR -

c. Grower uses a delayed sterol inhibitor fungicide program.

3. Trees are monitored for cedar apple rust. Where cedar apple rust is a problem, red

4. Litter chopping or urea treatment is practiced so as to reduce scab residue.

5. Treatments for fire blight follow blight forecast in Fruit P s t Message.

cedar and juniper within 100 yds sunomding orchard are removed. 5 Pts

Bonus: 5 pts

Bonus: 5 Pk

.

6. Experimental block of disease-resistant trees is planted. Bonus: 10 pts

Weed Management

I . Herbicides of the same clzss are not used in successive years. 10 pts

2. Nonchemical weed management techniques (e.g. , mowing, mulches) are used. 5 ptS

3. Agents toxic to predatory mites are avoided, except for spot treatment of noxious -

weeds (e.&, poison ivy, bindweed) is permitted. 5 pts

Vertebrate Management

1. Where deer pressure is high, soap or appropriate fencing is used. 5 P h

rodenticides. 10 pts 2. A monitoring program for rodents is conducted to determine the need for

3. Where rodenticides are applied, bait stations, rather than broadcast treatments, are used. 5 prs

5

P

4. Appropriately positioned scare-eye balloons are used to reduce bird pressure, where appropriate. Bonus: 5 pts

Weather and Crop Monitoring

1. Grower monitors h g h and low daily temperatures, and leaf wetness (modified

2. Records of the stage of tree development are maintained on a weekly basis.

hygrothennograph or equivalent). Records are kept on a daily basis. 15 pts

5 pts

Education c

1. One or more UMass Extension IPM workshops is attended during the current year. 5 Pts

2. Grower possesses current N m England Apple Pest Management Guide. 5 pts

3. Grower subscribes to UMass Extension Tree Fruit Newsletter and March Message. 5 Pts

440 TotalPoints 70 Bonus Points

6

Pesticide applicaiors have been r e q w to repon what pesticides they use, wher:: and for what purpose, since 1990 in the state of California. E infomarjon is available to the public, recent "ralysiS(summ&ed below) demonsnates how useful the data Can be. Meanwhile, Massachusetts residents remain in the &k when it comes to learning more about bssible pesticide exposures in the Commonwdth.

Pounds of Pesticides per Person Pesticides' use in Ibs/person/year:

rlg-gregate Use Statewide Sutewide pesticides use in 1991: Sutewide pesticides use in 1995:

Trends in Pesticides Use Percentage increae in pesticides use '91-'95:

Use of Pestiade by Health Risk Acute systemic toxins in pesticides used in 1995: Carcinogenic pesticides used in 1995; Reproductive toxins in pesticides used in 1995: Nerve toxins in pesticides used in 1995:

Use on Particular Crops Pesticide use on strawbenies/acre/year: Pesticide use on grapes in 1995:

Use of Particular Pesticide T o d ~ Use of the nerve toxin diazinon in 1995: Use of the carcinogen arsenic in 1995:

Use by Location County with greatest pesticide use in 1995:

California

6.5 Ibs.

161 million Ibs. 212 million Ibs.

31 X increase

30 million Ibs. 23.4 million lbs. 18 million Ibs. 8.6 million Ibs.

300 ibs. 59 miilion Ibs.

2.4 million Ibs. 125.000 Ibs.

Fresno (39 mill. Ibs)

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To: Gina McCarthy

Fr: Ken Geiser -

Dt: January 11, 1999

Re: Indicators

Gina: Here are some of my thoughts about indicators.

i f i d d around the concept of indicators of sustainability and indicators of corporate envlronmcntal pcrformance. Those corporate leaders that are pushing this believe it is a way to achieve some form of transparency without revealing confidential business information that pennits firms a wide range of program flexibility while trying to mctt end points that are "relevant" to public concerns. Non-governmental advocates appear t o like indicators because they focus attention on "red" outcomes, permit performancc trends to be monitored by the public, and allow I-e,oulators to differeritiatt: between those entities doing well and those who arc in nccd of attention,

Indicators of Corporate Performance are way to go. Thcrc is a rapidIy rising intellectual

6 In general, appropriate indicators need to be harmonious across reporting entities SO that condirtons in various sectors can be compared against one another. At the same time we need to recognize that different sectors will require different indicators. What w e %'ant to stay away from is institutionalidng indicators individually tailored to each reportins entity.

-

...

Ken Geiser January 11, 1999

E g h e r educarion institutions should bc cncouraced .- to dcvclop indicators ofcnvironmcntal and public health performance that reveals to the CommonwesILh Lhe effects o i ind iv idud programs tu improve performance, Somc of these indicators should bc raw scores and other should be normalized against a w m o n metric. The most [ikely common metric is "number o f h u t h e equivalent (€TEE) studcnts enrolled". This is a common metric calculated i n highcr education insiirutions. It accounts for growth and rarenchment Over the years. It accounts for institutions with full, part-time and non-matriculated students. I t does not accouilt well for those institutions thet are heavily invested as research i,rlstimtions,

A. Indicators with un-normaiized metrics

Amount of pollutant release to the environment (TRI data) Amount of carbon (green house gases) released to the environment Amount of water used Amounr of solid and hazardous waste generated Amount of cars employed for commuting

B. Indicators w i t h normalized metrics

h o u n t of pollutant released to the environment per FTE Amount of carbon (green house gases) released to the environmcnt per FTE Amount of solid waste generated per FTE Amount of solid waste generated per residential room Amount of hazardous waste generated per square foot of Iaboratov floor Amount of toxic chemical used per square foot of laboratory floor Amount of chemical spills per square foot of laboratory space Amount of hazardous chemical stored on site pcr square foot of laboratory space Amounr o f pesticides used per FTE or per acre of campus Amount of pesticides used indoors per square foot of building floor space Amount of paper used per F E Amount of paper recycled per FTE Amount of water used per F E Amount of cars per FTE haunt of miles traveled to commute per FTE Amount of conventional energy (from 03, gas, coal or nuclear) used per FTE haunt Of dtemative energy used per FTE An-"t of organic waste composted per F'IE or per meal served h-m-m" of leaf and yard waste eomposted per acre of campus

: 'ON X W

P2 Blue Ribbon Panel: Emironmental Leadership in Transportation Sector

The following components of the transportation sector could demonstrate environments1 leadership by adopting the following practices. most of which go beyond complimce Qith l a v s and regulations.

Clean Aimorts

3 Instirure programs to encourage people to move out of SOV (single occupancy vehicles) by making multi-modal transportation more attractive.

3 Replace gasoline driven luggage dollies with electric-powered ones. 3 Adopt engrgy efIrlcient system-wide measures for heating/cooling planes at the gate. 3 Replace ethylene glycol w 3 h propylene glycol for deicing. - 3 Set an environmental performance standard per unit of activity.

Fleet Operators

a Go beyond the I&M Program by (1) testing vehicles more frequently and (3) fix or replace vehicles that fail rather than seeking waivers or extensions.

3 Use the cleanest vehicles possible. c7 Switch to alternative fuels. CI Manage routes of vehicles to improve efficiency. CI Adopt a diesel retrofit program to install equipment on buses and trucks to capture

emissions. CI Establish a “clunker” program for employees giving them incentives to turn in older

vehicles.

Sqstem (EMS) orke: and communit]. hcalth and safety conditions

Innovative or Aggressive EMS

complianct" targets's, but rathe: to EMS targcts that smvc for susumcd compliance

Printed Wire Board Industry Green Track Program I "SUSTAINED COMPLIANCE TRACK" Program Flexibility or 0th Benefits

ce for using the BOLDER consolidated emergency response plan

December 8, I997 Drafi 2

0 b L S ~ ~ t ~ i n e d Compliance” track: T h i s track is the e n 0 level track designed to attract companies that strive for reIiable and sustained compliance With existing regulatory program requirements.

0 “Beyond CompIiance” track: This track designed to attract companies that stn’ve for performance beyond that required by the existing regulatory system

o “Cutt ing Edge” track: This track designed to attract companies that use more innovative cutting edge approaches to achieving environmental excellence .

Ail three tracks are centered around the use of environmental management systems, continuous improvement, pollution prevention, and collaboration processes as the preferred approaches to improving environmental performance. However, each uack presumes a different level of environmental, health, and safety program maturity in each of these areas. It is anticipated that the benefits offered to companies in the green track program will be available within the existing regulatory framework.

Green Track Target Companies: The Printed Wire Board green track program is open to a broad range of facilities to encourage improvements in environmental, health, and safety performance. The program will be designed to accommodate hundreds of participants.

W h o Determines the Requirements and Benefits for Each Track?

1 December 8, 1997 Drafi

* Pnonty for tecnnical assistance programs

Compliance I compliance audit within SIX months I]

December S, 1997 Drafi 2

>ompliance

Environmental ilanagement System (EMS)

ixamples of nnovative or iggressive EMS +a rg ets

lonitoring & .eporting

ommunity ivolvement

>attem Of sustained compliance No significant remat violations within the pas: 2 'ears or any major violation (including criminal) Minor violations corrected and no p e n civil actions or unpaid penalties These include state or local enforcement actions

4n Established EMS that includes pollution prevention. waste minimization. imployee involvement, and clear targets and measurement nclude some innovative or aggressive targets that result in Eyond compliance performance EMS targets met pnmanly through pollution IrevenQon rather than treatment.

-he facility's EMSs commits to meet Some of the targets below, based on local liscussions to determine the appropriate mix of targets for a given facility and :ommunity -

The EMS must

-

Reduction in emissions and waste - - - - - Reducbon in sludge generation - -

xx reduction in metals emissions over 1992 baseline xx% reduction in organic TRI emissions over 1992 baseline XX% reduction or elimination of air Hazardous Air Pollutants (HAPS) xx% reduction in hazardous sludge disposal over 1992 baseline

Identification of pollution prevention opportunities and bamen Review environmental performance of facility's hazardous waste handler (TSD)

Human or ecological nsk reduction - - -

worker and management training and skill development program xx% reduction in worker exposure to releases of hazardous materials over 1992 baseline Exposure reduction plan for workers

Energy, water, or resource conservation - xx% metals utilization - - - - - product performance improvement

xx% water reduction over 1992 baseline xx% reduction in energy use over 1992 baseline Recycle, regenerate, or reclaim etchants. semi-aqueous cleaners Increased recyclable content of products and packaging

Facility shows leadership in pilot testing cutting edge approaches for cleaner manufacturing (see Table 1 )

Third party of peer review of EMS Monitoring and reporting is timely, accurate, and publicly available

Communities and workers participate in EMS goals Targeted stakeholders participate in an advisory role. Meetings are held at convenient times and places with a neutral facilitator. The community has locally available access to monitoring results, reports, and inspections sent to requlatow aqencies

December 8. 1997 Draft 3

* Streamlined reporting

Expedited permitting to allow f o r rapid process changes Use of mass-based effluent limits

* Amnesty for self-reported, single instance violations (plant upsets).[must defin

?he mix of benefits received are determined locally and are based on extent to which a facility strives to achleve superior performance beyond that required by the environmental regulations or existing performance

December 8. 1997 Draft 4

ZUTTING EDGE TRACK'" Prosram Requirements

UI Of the 'beyond compliance' track requirements plus no violabons that resclt ir, in enforcement action tn the past three yean

i n Established EMS that includes pollution prevention, waste mtnlmzation. ?mployee Involvement, and clear targets and measurement iclude some innovative or aggressrve targets that result In Eyond compliance performance EMS targets are met pnmanly through pollution xevention rather than treatment.

-he facility's EMSs commits to meet many of the targets below, based on locdi Lscussions to aetemine the appropriate mix of targets for a given facility and :ommunlty

The EMS must

- Reduction in emissions and waste - xx% reduction in metals emissions over 1992 baseline xx% reduction in organic TRI emissions over 1992 baseline XX% reduction or elimination of air Hazardous Air Pollutants (HAPS) xx% reduction in hazardous sludge disposal over 1992 baseline Reduction in sludge generation Identification of poliution prevention opportunities and bamen Review environmental performance of facility's hazardous waste handle VSD)

Human or ecological nsk reduction worker and management training and skill development program xx% reduction in worker exposure to releases of hazardous materials over 1992 baseline Exposure reduction plan for workers New chemical use based on precautionary principal

Energy, water, or resource conservation xx% metals utilization xx% water reduction over 1992 baseline xx% reduction in energy use over 1992 baseline Recycle, regenerate, or reclaim etchants. semi-aqueous cleaners Increased recyclable content of products and packaging Product performance improvement Participate in electronic product reuse & recycling

Facility shows leadership in pilot testing cutting edge approaches for cleaner manufacturing (see Table 1 ).

Third party or peer review of EMS Emissions expressed pe r unit of production where possible Data and reports electronically filed, available on line and consolidated report on the Web

Communities and workers participate in EMS goals Comprehensive outreach to stakeholders that participate in a MnCenSuS decision making process. Technical asstance provided to ammuni ty partiipants where needed.

December 8. 1997 Draft 5

“‘CUTfiNG EDG Program Flexibility or Other Benefits

ie porting

Demitting or ?iegulatory Relief

Monitoring

Inspections

Zompliance

Streamlined reporttng less Frequent reporting

*

- Facility-wide permits * Negotiated covenants * Flexibility waivers

Permit bubble that allows limited changes within specified emission boundanes for plant expansions or process changes A self-permitttng agreement or other expedited permitting system Access to sector-wide, expedited delisting program-

* Self-pemitting * Permit by rule

Self-certification * Longer permits

Self-reporting, self-monitoring program (which could include a selfcertificatlon, peer-review program)

consolidate inspections and put on Web

consolidate inspections and put on Web

December 8, 1997 Drafi 6

-

Table 1 : €xamples of cutting edge approaches for cleaner manufacturing in thePWBhdusbv .

.

t

.

full scale imolementation of successful Sematch pilot prorects I

Cleaner approaches that lead to - zero discharge

continuous emissions moniasnng

use of design for the environment, Total Cost Assessment, and /or life cycle analysis

innovative customer/supplier relationships

smaller firm training and mentoring programs

supplier and customer performance assurance programs

community & worker involvement programs in which goal identificatiohand achievement are collectively set, reviewed and evaluated

\ - -

Use design for the environment, Total Cost Assessment, or life cycle analysis

Innovative customer/supplier relationships

Facility shows leadership in pioneering one or more new technologies, such as: - New additive PWB manufacturing processes lead free solders dry cleaning processes such as plasma cleaning develop safer adhesives (water based, epoxy acrylic, or isocyanate) use low or no VOC fluxes or plasma assisted soldering design for disassembly and recycling replacing brominated materials solvent recovery

December 8, 1997 Draft 7