~_——a——r—_orlcoerelNcvwreleoerelhL ere Te relerrl ere ererel_ereereererlTl reer erlerelelerelerelerelaerl cere rl rele sen er a eer rele ere eel eerlc owe eer el erel ele ee

Top Level

2

11 1.2 1.3 Second Level

Node Tree Structure

1.24 1.2.2 1.2.3 1.2.4

Third Level

4.2.2.4 1.2.2.2 1.2.2.3

Fourth Level

Figure 4-1. Hierarchical Process Map Structure.

maintenance requirements, glossaries of terms, and material safety
data sheets (MSDSs) can be filed by work step using the process maps.
What you may find when using the process maps is that many prob-
lems are associated with a single work step. It may then be easier to
focus the P2 activity on that work step. This focus is necessary to help
P2 activities succeed in the day-to-day operation of the organization.

While many process map designers simply use pencil and paper,
hierarchical process maps can also be computerized using inexpen-
sive, off-the-shelf software commonly used to prepare organizational
charts (e.g., VISIO®). If the organization decides to computerize the
process information, everyone involved in a particular work step can
have access to all the information on that work step using an Intranet or
other electronic or hard copy means. Using process maps as a tem-
plate helps an organization keep track of resource use and loss by
each work step in a main process, or in supporting ancillary and inter-
mittent processes.

All resources (e.g., energy, water, and materials) can also be tracked
(Reference 4-3) on the same process map (Figure 4-3). The term non-
product use means that the resource does not become part of the
interim or final product. The term non-product loss means that the re-
source is lost in that work step as a waste, discharge, or emission.
Process losses can be classified by medium (air, water, solid waste,
spills/leaks, and accidental losses). Costs can also be tracked by pro-

Using process maps as a
template helps an organization
keep track of resource use
and loss by each work step in
a main process, or in support-
ing ancillary and intermittent
processes.



represents an opportunity not to have that loss or waste. The facility
will have many P2 opportunities visually depicted by the process maps.
You must rank order these P2 opportunities to provide some focus to
your P2 plan. Pareto analysis (also referred to as the 80/20 Rule) is
used in the Systems Approach to separate the vital P2 opportunities
from the “trivial many.” You may want to consider selecting between 8
and 11 opportunities for the first planning year of the program. These
opportunities should be selected with a goal of completing them within
that year. The P2 program needs to have some “quick wins” to help
maintain the interest of management and the other interested parties.
You may want to select a couple of opportunities that will take a bit
longer to complete and consider them with respect to the two-year
window in the planning requirements. All the opportunities that will ulti-
mately be included in the program can also be listed at this point. Next,
you will collect more information on’these opportunities.

The second step (Figure 7-3, work step 2.2) begins the process of
production unit analysis. For each opportunity, an employee team will
work with a facilitator provided by the organization to determine the root
cause for the use or loss of all resources (i.e., materials, water, and
energy). They will use a cause and effect diagram to look at how mate-
tials, methods, machines (technology), and people contribute to the
P2 opportunity that has been identified. This team will conduct the root
cause analysis and then prepare a memorandum version of a defini-
tive statement of the problem. The time spent by the team determining
the root cause is rewarded by the generation of a higher number of

The facility will have many P2
opportunities visually depicted
by the process maps. You
must rank order these P2
opportunities to provide some
focus to your P2 plan.

For each opportunity, an
employee team will determine
the root cause for the use or
loss of toxic materials or
hazardous waste.

The time spent by the team
determining the root cause is
rewarded by the generation of
a higher number of alterna-
tives.

INFORMATION AND OPPORTUNITY ROOT

ANALYSIS CAUSE ANALYSIS

24 2.2

DEVELOP
ALTERNATIVES,

2.3

Resource Accounting
Cost Accounting
Rank-Order Opportunities
‘Select Opportunity

Cause-and-Effect Diagram
Pareto the Causes
Team Memorandum

—— >| SELECT ALTERNATIVE |-—>

24

Start with “Quick Wins*
Feasibility Analysis (if needed)
Capital Justification (if needed)

Figure 7-3. Development of Pollution Prevention Opportunities.

Using’a Quality Model to Implement

Brainwriting of Alternatives
Detail Altermatives



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The CD-ROM should be useful as your organization develops the
P2 Program.

REFERENCES

1-1. Compliance Through Pollution Prevention (CTP2):
Implementation Guide. U.S. Air Force Material Command,
Wright-Patterson AFB, December 2000.

1-2. National Pollution Prevention Roundtable (NPPR) Web Site
hittp://www.p2.ora/

1-3. National Institute for Science and Technology Manufacturing
Extension Program (NIST MEP) Web Site
http://www.mep.nist.gov/

1-4. Small Business Development Centers (SBDC) Web Site
http:/Avww.sbaonline.sba.gov/SBDC/

Other Sources of P2 Information

EPA Environmentally Preferable Purchasing (EPP) Program
https epa.gov/opptintr/

EPA Environmental Accounting Project
https .epa.gov/opptintr/accta/

EPA Design for Environment

hittp:/Awww.epa.gov/dfe/ -

EPA P2 Programs and Initiatives
http:/ -gov/opptintr/p2h ‘ograms/index.ht

EPA P2 Resource Exchange (P2Rx)
http:/Avww.p2rx.org/

EPA Sustainable Industry
http://www.epa.gov/sustainableindustry/

State P2 Programs
ittp://Awww.epa. tintr/p2home/re: /statep2. htm



$s
Safe disposal, 21
Safety, worker, 11-12, 26
Selection grid (criteria matrix), 17, 62
Service intensity, 22
Six sigma, 24
Small organizations, 75-76, 87
SOP (Standard operating procedure), 52
Source reduction, 21
Specifications, 14
Spill prevention, 96
Stakeholders, 71
Standard operating procedure (SOP), 52
State mandated P2 planning, 10, 26
Statement of goals, 31, 34
Strategic needs and P2, 28
Strategic planning, 103
Suppliers, 39
Support from top management, 40-41, 46, 82, 132-133
Sustainable development, 2, 23-24
use of indicators, 35
Sustainable use of renewable resources, 22
Systematic approach, 87
Systems Approach, 3, 49-50
combining with traditional approach, 74-75
Systems Approach tools, 3-5, 49-64
action planning, 64
determining the cost of the lost, 56-57
generating alternatives, 61-62
process mapping, 51-56
root cause analysis, 59-60
selecting an alternative for implementation, 62-64

T
Targets of EMS, 88-89, 90, 98
Team approach, 26, 29, 50
EMS organizational teams, 85-86
multi-functional, 26
Technical expertise, 15
Technology transfer, 43
The Natural Step, 32
Time available, 15
Timing of P2 efforts, 27
Tools, 49-68
checklists, 65
Systems Approach, 3-5, 49-64
action planning, 64
determining the cost of the lost, 56-57
generating alternatives, 61-62


L

Leadership
as corporate citizen, 39
EMS-based program, 124
getting and maintaining top management, 127
as guiding principle, 36-37, 107, 131
management commitment, 37, 46, 93
Quality model, 103, 107, 124-126, 131
tradition P2 program, 124

Lean manufacturing, 10

Learning, 107-108

Legal requirements, 82-83

Long-range outlook, 38

Loss
cost of the loss, 56-57
determining the cost, 56-57
management of non-product, 57
non-product, 56, 57
process, 23, 53
weight vs. cost of loss, 58-59

Low hanging fruit, 63, 72

M
Maicolm Baldrige National Quality Program, 5, 25, 101
Management
leadership commitment, 37, 46, 83-84, 93
program, 17-18
representative in EMS, 85, 99
review by, 95-96
role of, 26, 27, 37
strong guiding team, 29
Systems Approach and, 50
top management support, 40-41, 46, 82, 132-133
See also Leadership
Management by fact, 39-40, 110, 132
Material intensity, 22
Material recyclability, 22, 23
Material safety data sheets (MSDSs), 52-53
Measuring environmental performance, 93-94, 111
Mission statement, 31, 33-34
Monetary metrics, 16
Monitoring P2 performance, 93-96, 111
MSDSs (material safety data sheets), 52-53
Multi-State Working Group (MSWG), 79, 83



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\nternal and external P2 partners should develop longer-term waste
elimination objectives, thereby creating a basis for mutual investments.
P2 partners should address the key requirements for success, means
of regular communication, approaches to evaluating P2 progress, and
means for adapting to changing conditions.

Public responsibility and citizenship. An organization can benefit by
communicating its responsibilities to the public and practicing good citi-
Zenship. These responsibilities refer to basic expectations of the orga-
nization—business ethics and protection of public health, safety, and
the environment. These responsibilities apply to the organization’s op-
erations as well as the life cycles of its products and services. Organi-
zations also can emphasize resource conservation and waste reduc-
tion at the source. P2 planning should anticipate adverse impacts from
production, distribution, and transportation. The plan must provide re-
sponse if problems occur and make information available and provide
the support needed to maintain public awareness, safety, and confi-
dence.

Practicing good citizenship refers to the following items: (1) im-
proving education, (2) promoting health care in the community, (3) en-
hancing the local environment, (4) promoting resource conservation
and recycling, (5) participating in community service, and (6) sharing
nonproprietary P2 program information. Leadership as a corporate citi-
zen also entails influencing other organizations, private and public, to
partner for these same purposes. For example, individual organiza-
tions could lead efforts to help define the obligations of their industry to
its communities.

Results focus. An organization’s P2 performance measurements will
benefit from a focus on key P2 results. Results should be focused on
creating and balancing value for all interested parties—customers, em-
ployees, stockholders, suppliers, NGOs, P2 partners, and the commu-
nity. To meet the sometimes conflicting and changing aims that bal-
ance implies, organizational strategy needs to implicitly include all in-
terested-party requirements. This balance will help to ensure that P2
actions and P2 plans meet interested-party needs and avoid adverse
impact on any stakeholders. The use of a balanced composite of per-
formance measures offers an effective means to communicate short-
and long-term P2 priorities, to monitor actual P2 performance, and to
marshal support for improving results. It is important to remember that
the first six criteria drive performance while the results criterion cap-
tures the measurement of this performance. Results in and of them-
selves are not performance.

Using the Guiding Principles

The criteria describe how best-in-class organizations handle each
of the seven areas covered. The guiding principles show how to inte-
grate P2 into any organization. You can learn more about how to com-

Using a Quality Model to Impler

In addition to meeting all local,
state, and federal laws and
regulatory requirements,
organizations should treat
these and related require-
ments as opportunities for
continual improvement “be-
yond mere compliance” or by
attaining compliance through
P2.

An organization’s P2 perfor-
mance measurements will
benefit from a focus on key P2
results.



able to help the P2 team generate as many as 1840+ alternatives in
a short period of time.

To help encourage P2 team members to “think outside the box,” it
is important to get each team member to express the “most outra-
geous alternative that just might work.” This gets everyone involved in
using a bit of creativity to address the P2 problem at hand. Even “wild”
concepts may trigger a search for alternatives that are a bit unusual
but could work in the case under consideration. This technique is called
“provocation.” Employing worker knowledge and a little creativity has
led to many successful P2 projects.

Employing worker knowledge
and a little creativity has led to
many successful P2 projects.

See Figure 4-7 for a listing of brainwriting alternatives for a com-
mon problem. Other examples of brainwriting alternatives can be found
on the CD-ROM that. accompanies this Guide.

Install a closed-loop (fully recycling) system.

Fully automate the system to control drive speed.
Use water-saving nozzles.

Wash less frequently.

Put dehumidifier in room to collect water vapor.

Use high-pressure jet spray (rinse/clean in one step).
Redesign water application.

Hand wash.

Reduce evaporation by lowering room temperature.
Try to collect evaporated water.

Use multistage washing process.

Only use undercarriage spray in winter.

Only wash vehicle once a week.

Dip vehicles in a tub-like device.

Lower temperature of water to decrease evaporation.
Use drying apparatus so vehicles do not drip dry.
Use a switch to activate/deactivate each step.
Close garage door before starting washing process.
Spit shine.

Use a squeegee to scrape off excess water.
Change soap application method.

Use alternative to city water source.

Use fewer absorbent sponges (less water trapped).
Use rental cars (rental agency will wash).

Redesign collection of water.

Drive through faster.

Figure 4-7. Brainwriting Alternatives for an Automated Vehicle
Cleaner.

Selecting an Alternative for Implementation

The bubble-up/bubble-down Selecting a P2 alternative for implementation is facilitated with de-
tool is an excellent means for _cision-making tools such as a criteria matrix (also known as a selec-
prioritizing and selecting an tion grid) or bubble-up/ bubble-down (also known as forced pair analy-
alternative to implement froma is). These are prioritization tools. The bubble-up/bubble-down too! in
long list of possibilities. particular is an excellent means for prioritizing and selecting an alter-

native to implement from a long list of possibilities (Reference 4-7).
When using this tool, the P2 team is allowed to examine only two alter-
natives at a time. They must ask which is best and use general criteria

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Program elements, 3, 40-46, 132-133
cost allocation system, 42-43
opportunity assessment, 41-42
other elements, 44-45
periodic P2 assessments, 42-43, 132-133
process characterization, 41, 132-133
program evaluations, 44, 132-133
technology transfer, 43
top management support, 40-41, 132-133
See also Implementation elements
Program management, 17-18
Program planning, 31-47
core values, 35-40
corporate responsibility and citizenship, 39, 111
designing quality and prevention together, 38
fast response, 39-40
indicators, 35
interested party-driven P2, 36, 107
leadership, 36-37
long-range outlook, 38
management by fact, 39-40
mission statements, 31, 33-34
partnership development, 39
planning, 31-35
statement of goals, 31, 34
valuing employees, 37, 108-109, 131-132
vision statements, 31, 32-33
Project XL (eXcellence and Leadership), 97
Proper treatment, 21
Provocation technique, 62
Public image, 13, 15
Public outreach, 29, 44, 74
public responsibility and citizenship, 39, 111, 125

Q
Quality initiatives, 25
Quality model, 5-6, 26, 38, 44, 101-119, 122-124
action plans, 116-117, 122-123
Green Zia program, 101, 102
guiding principles, 106-112, 131-132
continual improvement and learning, 107-108, 131-132
efficient product, service and process design, 109
fast response, 109, 132
interested party-driven P2, 107, 131
leadership, 107, 131
long-range view, 109-110
management by fact, 110, 131-132

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selected, the traditional approach has the P2 team obtain funding and
initiate work on the alternative. The work is reviewed and adjusted dur-
ing execution to make sure it meets the objectives. There is no require-
ment in the traditional approach to prepare a formal action plan. The P2
implementation team reviews its progress on an informal basis and
makes necessary adjustments to enhance the P2 effort.

The final step in the traditional P2 program implementation is to
measure P2 progress. Data is acquired from the implementation phase
and analyzed. The traditional approach recommends the measurement
of economic results.

MAINTAINING THE P2 PROGRAM

At this stage, the traditional approach shifts to the maintenance of
the P2 program (see Figure 5-5). Five activities are detailed in this pro-
gram component.

This program maintenance begins with the integration of the P2
program into other formal corporate P2 initiatives. These programs could
include safety, quality, preventive maintenance, lean manufacturing, and
so on. Accountability for wastes are assigned to the generating pro-
cess. All wastes are carefully tracked and formally reported in the orga-
nization. The program results are evaluated annually.

Educational training for those who participate in the P2 program
needs to be specified. No tools are taught in the traditional approach;
however, the participants do become familiar with the process. Train-
ing is provided to new employees to orient them to P2. Advanced train-
ing is provided to those most involved with the P2 program. Each year,
every employee needs to be updated on knowledge of P2.

At this stage, the traditional
approach shifts to the mainte-
nance of the P2 program.

Program maintenance begins
with the integration of the P2
program into other formal
corporate P2 initiatives.

Educational training for those
who participate in the P2
program needs to be specified.

INTEGRATE P2 INTO STAFF EDUCATION MAINTAIN INTERNAL
CORPORATE PLAN COMMUNICATION = |}——>
4A 42 43
Assign Accountability for Waste New Employee Orientation Two-Way Communication
Tracking and Reporting Advanced Training *  Solicit/Follow Up on Suggestions
Annual Program Evaluation Retraining
EMPLOYEE REWARD PUBLIC OUTREACH
_ PROGRAM AND EDUCATION [—>
44 45
Performance Reviews
Recognition Among Peers

Material Rewards

Figure 5-5. Maintaining the P2 Program.

‘coach to P2 Implementation



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CHAPTER 1

Introduction

EVOLUTION OF POLLUTION PREVENTION (P2)

Pollution prevention (P2) has evolved substantially in its first de-
cade. In 1988, the U.S. Environmental Protection Agency (EPA) pub-
lished the Waste Minimization Opportunity Assessment Manual (EPA/
625/7-88/003). It contained over 34 pages of checklists and worksheets
and focused on hazardous waste minimization. The first revision, Fa-
cility Pollution Prevention Guide (EPA/600/R-92/088), was released in
1992. It contained only 10 pages of checklists and worksheets, and
added new topics, including energy conservation and the design of en-
vironmentally compatible products. The EPA distributed many copies
of these publications to requestors in the United States and internation-
ally, and the information was well-received by the environmental com-
munity. The EPA prepared many successful project reports and case
studies based on this approach. Copies of these publications are avail-
able on the CD-ROM that accompanies this Guide, and the “traditional”
P2 approach that they describe is covered in Chapter 5 of this Guide.

This Guide presents an alternative approach to implementing P2 in
your organization. As you will see, it documents how P2 is moving from
a specialized environmental initiative to a mainstream business activity.
Employees can now become increasingly involved in P2 and reduce
their reliance on “outside experts” using defined checklists and data-
bases of “proven solutions” that may overlook P2 opportunities. Em-
ployees can use process mapping to better understand the
organization’s main and supporting processes and widely accepted
problem-solving and decision-making tools to find new P2 opportunities
and prepare cogent, written action plans. Many business managers are
already familiar with these tools since they are already used to improve
operations. No matter what method is selected to implement P2 activi-
ties, these tools should help improve communication within an organi-
zation and communication with other interested parties. This Guide is
intended to assist any organization in developing, implementing, and
maintaining a P2 program. It should help your organization decide which
program elements to include and the general approach for sustaining
this important business practice.

During the evolution of P2, some environmental professionals have
continued to focus on regulatory compliance. This has been a reactive
focus, as compliance activity is usually undertaken in response to a
new or changed regulation at the Federal, state, or local level. Preven-
tion, on the other hand, is anticipatory. Action is taken not on the waste
or use of a regulated material, but on the circumstances and conditions
that may generate waste or a regulated material. The focus in P2 is on

Includes:

D Evolution of Pollution
Prevention (P2)

O Benefits of P2

O Impediments to P2 Use

O P2 in Steps

O Organization of This
Guide

0 References

This Guide presents an alter-
native approach to implement-
ing P2 in your organization.

P2 is moving from a
specialized environmental
initiative to a mainstream
business activity.





In the traditional approach, the
purpose of the P2 program is
to meet these pre-set goals.

The EMS approach selects
significant aspects and sets
objectives and targets after
studying the environmental
impacts of the organization's
activities, products, and
services. Objectives are the
overall environmenial goals
that an organization sets out to
achieve.

In the quality-based P2 ap-
proach, the goals are not
formally set until after the
action plans are prepared.

Many believe that stretch
goals of zero waste and
emissions are best since it will
take both continual improve-
ment and some breakthrough
thinking to get there.

128

SETTING P2 GOALS

In the traditional approach, senior management sets the goals for
P2 before any formal information is gathered. This is based on the
philosophy of “management by objectives.” The purpose of the P2 pro-
gram is to meet these pre-set goals. Much of the literature on goal
setting supports this approach.

The EMS approach selects significant aspects and sets objec-
tives and targets after studying the environmental impacts of the
organization’s activities, products, and services. Objectives are the over-
all environmental goals that an organization sets out to achieve. Action
plans (EMPs) are written to meet the goals and objectives in the planned
time frame.

In the quality-based P2 approach, the goals are not formally set
until after the action plans are prepared. Each action plan has perfor-
mance goals set for each step. The sum of the performance goals
listed in the action plans are the goals for the period of time set forth in
the planning sequence (i.e., typically one year). It is possible to have
some action plans cover a longer time span, so that two-year goals
can be set. It is important to set only continual improvement goals.
Many believe that stretch goals of zero waste and emissions and con-
tinual improvement will increase the likelihood that significant strides
will be made.

FOCUS ON RESULTS

Results will demonstrate whether goals have been met. Continual
improvement is based on careful measurement and trending of the
actual results. Maintaining top management support is based on achiev-
ing these results. A focus on results is an important part of any P2
program.

The traditional approach involves the collection of results from the
various P2 activities and placing them into reports that are prepared for
each effort. Sometimes the results are plotted, such as reduction in
the use or emissions of certain regulated chemicals. In some cases,
financial savings are given.

The EMS approach requires procedures to monitor and measure
environmental performance, to record information that tracks opera-
tional controls and conformance with the objectives and targets, and to
evaluate compliance with environmental regulations. Top management
reviews these results on a periodic basis.

In the quality-based P2 approach, results represent the most im-
portant element. It is weighted with nearly one-third of the total evalua-
tion points provided in the seven categories. Results are segmented
into three items: environmental results; customer, supplier, employee,

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4-6. “Identifying P2 alternatives with brainstorming and
brainwriting.” Pojasek, R.B. (1996). Pollution Prevention
Review 6(4): 93-97.

4-7. “Prioritizing P2 alternatives.” Pojasek, R.B. (1997). Pollution
Prevention Review 7(1): 105-112.

4-8. “Implementing your P2 alternatives.” Pojasek, R.B. (1997).
Pollution Prevention Review 7(2): 83-88.

68 Chapter 4



Safety has always had its
focus on preventing incidents
and exposures.

Many states have legislatively
mandated programs that
require P2 planning while
others have programs that
encourage voluntary P2
planning.

For maximum effectiveness,
workers need to be directly
involved in P2 program devel-
opment.

Safety

Many environmental managers are gaining some oversight of the
safety function in their organizations. Organizations track safety closely
because it impacts worker compensation rates and related insurance
costs. P2 training and safety training are often combined in organiza-
tions to stress the prevention message. Safety has always had its fo-
cus on preventing incidents and exposures. There is information on
safety available on the Internet (Reference 2-8).

Insurance/Risk Management

Insurance companies and organization risk management profes-
sionals frequently audit organization processes and facilities to pre-
vent property loss and other forms of insurable risk. P2 programs should
collaborate with risk management personnel, whether in the company
or sent by the insurance company.

WHO SHOULD IMPLEMENT P2?

Many states have legislatively mandated programs that require P2
planning (Reference 2-9) while others have programs that encourage
voluntary P2 planning (see the CD-ROM for further information on these
statutes). The focus of most state P2 planning programs is the envi-
ronmental manager. However, it is becoming clear that operational
changes not commonly controlled by the environmental manager are
needed to make P2 work. Recognizing this point, many organizations
are establishing multi-functional teams to provide oversight of their
waste-elimination efforts. These teams often include environment, op-
erations, accounting, and a variety of other internal service providers
and functions. Representatives from upper management are often es-
sential members of such P2 oversight teams.

Although a commitment to the P2 program should begin with man-
agement (i.e., top-down approach), line employees can often suggest
valuable improvements in operations and procedures (i.e., bottom-up
approach). For maximum effectiveness, workers need to be directly
involved in P2 program development. The Quality model (Chapter 7)
stresses this need by dedicating one of its seven performance criteria
categories to worker involvement. Many organizations use P2 tools to
give everyone a common frame of reference and to enhance problem-
solving and decision-making skills. Management can authorize and give
responsibility to worker teams to implement the P2 program. Manage-
ment should also monitor all P2 efforts periodically. Whether an organi-
zation runs a service business or operates in a manufacturing setting,
it can implement a successful P2 program.



EEE EE  E_ I LI SOO ell Oo Oolewreseleleereee ee Ve Ve Vee VV VV Vee V VV VeV VV Vee Vee eS

An EMS identifies, translates, and communicates applicable envi-
ronmental and voluntary requirements to affected employees, suppli-
ers, and contractors. Voluntary requirements may include those ad-
dressing P2, company or corporate initiatives, health, process safety
management (PSM), and sustainable development. Health and PSM
tend to be mandatory requirements of the Occupational Safety and
Health Administration (OSHA). EPA's Green Lights, Climate Wise,
Project XL, Design for the Environment (Df€), Environmentally Prefer-
able Purchasing Program (Reference 6-9), and the American Chemis-
try Council’s (ACC) Responsible Care® are examples of voluntary ini-
tiatives. Refer to the CD-ROM for more information on these programs.
Standard operating procedures ensure that the employees, suppliers,
and contractors can meet the EMS’s requirements.

Compliance with Environmental Regulation

The EMS specifies procedures for how compliance will be achieved
and maintained organizationally. For example, it defines the compli-
ance roles and responsibilities of environmental managers, establishes
how they and management will be held accountable for achieving and
maintaining compliance, and describes how environmental performance
and compliance information will be communicated to relevant employ-
ees, suppliers, and contractors. The EMS establishes a mechanism
for receiving and addressing environmental and ‘compliance concetns
raised by individuals, organizations, or other interested parties.

The EMS includes procedures for identifying changes to applicable
environmental requirements—including new ones that may
apply as a result of process or material changes—and addressing these
changes through the EMS process. For those organizations that are
already performing environmentally, the EMS should establish objec-
tives and targets that promote leadership and ensure continued achieve-
ment of compliance.

Prevention of Pollution

Identifying all aspects and determining their significance is usually
the largest gap in most organizations’ current environmental systems.
The EMS establishes and maintains a procedure to identify all of the
environmental aspects of the organization’s activities, products, and
services that it controls and influences. Current procedures to identify
existing process waste streams and review new customer work re-
quests can be used as starting points for identifying all aspects. Also, a
procedure to identify which of these aspects have significant impact on
the environment is needed, and significant impacts must be consid-
ered in setting objectives.

Many organizations focus almost exclusively on negative environ-
mental impacts. Positive environmental impacts are also important.
These might include company-sponsored community recycling pro-

EMS Approach to P2 Implementation |

An organization's EMS policy
needs only to focus on the
three guiding principles and to
drive the accomplishment of
the EMS’s objectives and
targets through training and
involvement.

Standard operating proce-
dures ensure that the employ-
ees, suppliers, and contrac-
tors can meet the EMS’s
requirements.

The EMS establishes a
mechanism for receiving and
addressing environmental and
compliance concerns raised
by individuals, organizations,
or other interested parties.

The EMS should establish
objectives and targets that
promote a leadership and
ensure continued achieve-
ment of compliance.



Ee eee eee eee eee eee wee Vee Ve Vee we VV VeVwVeweVe we

m=The USPS is committed + d
that protects human health and the envir
In éstablishing environmental policies and |
"as appropriate, promote the sustainable use of natural resources and

= protection of the environment through conservation, recycling, and reuse
of material in its own operations.

#2:~ The USPS encourages the use of non-polluting technologies and
F== waste minimization in the development of equipment, products, and op-
= erations. Awareness of environmental responsibilities and adherence to
"sound environmental practices is encouraged.

Reference: http:/Avww.usps.gov/environ/textmirr/iwebpages/envco.htm#INTRO-

Mission Statement

The second component of a P2 plan is the mission statement.
This statement needs to “send forth” the people in an organization to
take P2 actions that will accomplish the vision statement. A good mis-
sion statement should include all of the essential components of an
organization's future thrust and communicate a positive feeling that will
guide others to action. Think of the mission statement as providing the
overriding purpose of P2 in the organization. An effective statement
should explain how P2 could be integrated into other business initia-
tives.

As with the vision statements above, there are many ways to ex-
press an organization’s mission. Some examples are provided here to
help your organization begin the task of preparing a mission statement.
lf your organization already has a mission statement, how would it
change with some P2 or sustainable development clauses added to it?
Does the P2 program ‘s mission reflect the mission of the organization
as a whole?

:nvironment, Health, and Safety Program will be implemented :
will provide reasonable assurance that the corp

«complies with all applicable governmental and internal health, safety,
and environmental requirements..
les pl i

‘develops and
meewm=Borted, used,
“recognizes and responds to community concerns about chemicals
-» and our operations.
makes health, safety, and environmental considerations a priority in
£ planning for all existing and new products and processes.
' © reports promptly to officials, employees, customers, and the public
information on health or environmental hazards, and recommends
protective measures.

P2 Program Elem

The second component of a
P2 plan is the mission state-
ment. This statement needs
to “send forth” the people in an
organization to take P2 actions
that will accomplish the vision
statement.

Think of the mission state-
ment as providing the overrid-
ing purpose of P2 in the
organization. An effective
statement should explain how
P2 could be integrated into
other business initiatives.



Pareto analysis helps identify
the most obvious opportunities
for improvement in present
operations.

10,
9
8
7
6
$:
4
3
‘ |
3 = =
A B CGC DbD E F GH

Non-Product Losses

Figure 4-4. Pareto Diagram Showing True Cost Versus
Waste Type.

some aspect of their work (Reference 4-4) to help focus their efforts.
This tool dates back to 1897 and has the greatest staying power of any
of the tools presented in this Guide.

Quality improvement experts advise concentration on the “vital
few” sources of problems and avoiding distraction by those of lesser
importance. The term for this process is called rank ordering. Pareto
analysis is a rank-ordering tool. However, the fact that you have
rank ordered your P2 opportunities does not mean you shouldn’t
address the easier opportunities early on. Early in a P2 program,
projects must be carefully selected to ensure the greatest chance
of success. P2 teams may be tempted to immediately tackle
projects that are too large or too diffuse for them to handle. Too
often, these projects may seem necessary to gain and maintain
management approval for the P2 program. The resulting frustration
only dampens enthusiasm for the prevention effort. Avoid bogging
down in P2 opportunities that offer minimal cost benefits. Instead,
focus your long-term efforts on the 20% where the true cost sav-
ings may be found. This approach maximizes the value of the P2
program to the organization. Pareto analysis helps identify the most
obvious opportunities for improvement in present operations.

Itis interesting to note that focusing on wastes by volume or weight
may cause the P2 team to overlook some important wastes. In some
cases, small volume wastes may be responsible for the highest costs.
An example of this involves laptop computers that become contami-
nated when used in radiologically controlled areas. Contaminated laptops
represented only a very small volume of the mixed radioactive waste

0OSO OOO OOOOH HOOHHOEHDHSOHOHHSOHOHHOHHHHHOHHHO688HHOHOHHOO



Implementation elements
employee participation, 129-130
extent of planning, 121-124
focus on interested parties, 130-131
focus on results, 126-127
goal setting, 126
guiding principles, 131-132
information and analysis, 127-128
leadership, 124-125
P2 program elements, 132-133
process management, 128-129
See also Program elements
Improvement
continual (see Continual improvement)
continuous, 13
incremental, 67, 75, 107
opportunities, 57-58
P2 plan, 112-118
Incremental improvements, 67, 75, 107
Indicators, 35, 94-95
Inertia, 15
Information analysis, 38-39, 105, 114, 115, 127-128
EMS-based program, 127
quality-based program, 127-128
traditional P2 program, 127
Information sharing, 43
Information sources, 19
See also Web Sites
Insurance/risk management, 26
Integrated Environmental Management Systems Implementation Guide, 87
Integration into core business practices, 24-26
environmental management systems, 24-25
insurance/risk management, 26
preventive/predictive maintenance, 25
quality initiatives, 25
safety, 26
Interested party-driven P2, 36, 107, 131
Internal partnerships, 39, 110-111
International Organization for Standardization (ISO), 24
ISO 9000, 25
ISO 14001, 24, 79, 80, 82
ISO (International Organization for Standardization), 24

J
Juran, J. M., 58



REDE EEE IE LL LIES eee Ve Ve Ve Ve Vee Ve Ve VV Vee Vee ee eo

ft ha pter, Everyone will be]
“How will things ‘be better with the change?" f Al P2

cts must fit the vision, and Dust, be re

at is ‘offen missing ina P2 program.
ickly! Mans “successful P2 programs gain

noted

econc omic benefit are demonstrated. P2

“Zation. All organizations can support value-added programs.

““éven be treated as a profi it center ina private aioe or organi-

Communicate, then communicate some more. You_can

never do enough to get the P2 message across to all inter-

“ested parties—workers, suppliers, regulators, customers,

the community, and all other interested parties. Keep the”

‘Ommunication simple so everyone can understand what

going on. “Walk the talk” at all hes rau of the firm, even top

“age Waste reduction. ~
Build a strong, committed management P2 guiding

“team. This high-level oversight team should sponsor all P2
~ “efforts while articulating the P2 vision, fostering communi-

cation, eliminating obstacles, coaxing the short-term wins,
serving as mentors to the worker P2 teams, and embed-

*-ding new approaches into the organization’s culture. Gen-

erally, whenever such a team is present, the P2 program
has a much higher level of success. Implementation of P2

~*through the intervention of only vendors, consultants, and

technical assistance providers reduces the chance of suc-
cess. The P2 program must be internalized, continuously
reinforced, and rewarded by management in order to yield
long-term results.

Add some level of complexity to the P2 program. This
may sound counter-intuitive, but breakthrough complex
change may be easier to accomplish than incremental
change. Integrating P2 into core business practices instead
of relegating it to environmental personnel is one way to ac-
complish this goal. To maximize integration, change every-

Finding the right vision will be
challenging. However, once
found, it will provide the rallying
call that is often missing in a
P2 program.

You can never do enough to
get the P2 message across to
all interested parties—work-
ers, suppliers, regulators,
customers, the community,
and all other interested parties.

The P2 program must be
internalized, continuously
reinforced, and rewarded by
management in order to yield
long-term results.

To maximize integration,
change everything at the same
time.



~_——_  weereleresereeverseaeerereVer ere See ewe Se Vee Ve VV VV eV eT Vee wee Vee Ve Vee ee Vv eee Vee Vee eS

Generating Alternative Solutions

Every P2 approach has some method of deriving alternatives for
solving the P2 problem. Some P2 practitioners restrict themselves to
only a small number of P2 alternatives for a given problem because
they have not performed root cause analysis (and thus may lack key
information) or because the P2 team members are not adequately in-
volved in the process of deriving alternatives. P2 literature (i.e., case
studies and success stories) provides only some ways to address each
problem. An expert may offer limited tried-and-true solutions. Your
organization’s P2 team should feel confident that it may develop equally
effective alternative ways to address the situation.

The Systems Approach operates on the theory that “the only way
to find a good P2 alternative is to have many P2 alternatives.” A good
method for generating alternatives is “brainwriting,” a technique similar
to brainstorming, but tends to be less restrictive (Reference 4-6).
Brainwriting is a written form of brainstorming that uses forms like that
shown in Figure 4-6. It takes advantage of the fact that many people are
much more likely to write down their ideas than say them. This
brainwriting technique allows resource people (i.e., those not on the P2
team, vendors, or technical assistance personnel) to lend their exper-
tise in generating alternatives. Brainstorming is a very widely used tool
for generating alternatives. Some organizations use a tool known as an
affinity diagram. No matter what your preference, the quantity of alter-
natives is what counts. Experience has shown that brainwriting is often

1 2
3 4
5 6
7 8
9 10]

Figure 4-6. Form Used for Brainwriting Exercise.

The Systems Approach
operates on the theory that
“the only way to find a good P2
alternative is to have many P2
alternatives.”



An EMS establishes specific
objectives, targets, and time
frames for implementing P2
initiatives, improving environ-
mental performance, and
maintaining compliance.

EMP requirements specifically
include designation of respon-
sibility for actions and the
means and time frame by
which the objectives are to be
achieved.

The EMS identifies and pro-
vides for the planning and
management of all the
organization's operations and
activities, including facility
maintenance, in order to
achieve operational contro!
and maintain compliance.

The EMS also establishes
documented procedures for
mitigating any adverse im-
pacts on the environment that
may be associated with acci-
dents or emergencies.

grams and household hazardous waste collection days. An EMS can
develop approaches to procurement, processing, and delivery that re-
duce or minimize significant environmental impacts for organizations,
customers, and interested parties.

An EMS establishes specific objectives, targets, and time frames
for implementing P2 initiatives, improving environmental performance,
and maintaining compliance. These should be documented and up-
dated. An EMS ensures that the organization has skilled employees
and financial and technical resources to achieve its objectives and tar-
gets and maintain compliance. In setting objectives and targets for each
relevant job within the organization, it is important to consider pollution
prevention goals; any additional significant impacts; legal and other re-
quirements; technological options; financial, operational, and business
requirements; and views of interested parties. These considerations
are important in EMS planning and are used for capital improvement
decisions, product and process design, training programs, and main-
tenance activities.

The organization establishes environmental management programs
(EMPs) to achieve its EMS objectives and targets. EMP requirements
specifically include designation of responsibility for actions and the
means and time frame by which the objectives are to be achieved. The
EMP must review new activities, products, equipment, or services and
address environmental changes through the EMS. For measuring per-
formance-based improvement, targets must be quantifiable and use
metrics that are related to the organization's overall goals. Most organi-
zations have set some quantitative goals for various process waste
streams, for example, reducing sludge production 10% by 2002 based
on amount of wastewater treated. The EMP establishes the frequency
at which the objectives and targets will be reviewed.

Continual Improvement

In many organizations, operational controls have been implemented
for achieving waste reduction goals, although responsibility for achiev-
ing these goals has not always been designated. The EMS identifies
and provides for the planning and management of all the organization's
operations and activities, including facility maintenance, in order to
achieve operational control and maintain compliance.

The EMS establishes documented procedures for preventing, de-
tecting, investigating, promptly correcting, and reporting (both internally
and externally) actual and potential accidents, emergency situations,
and environmental violations. The EMS includes procedures for track-
ing any preventive and corrective actions that are taken. If an environ-
mental violation or accident resulted from a weakness in the system,
the EMS is updated and refined, ensuring that similar situations are
avoided. The EMS also establishes documented procedures for miti-
gating any adverse impacts on the environment that may be associ-



Not only can an organization
score itself, but it can also
score all of its suppliers.
These scores can be com-
pared on an “apples-to-apples”
basis. In this manner, the
entire life cycle of a product to
a customer can be scored for
environmental excellence, P2,
and product stewardship.

Your ISO 14001, Global
Reporting Initiative, CERES
Principles, Responsible Care
Program?®, balanced
scorecard, six sigma, ISO
9000, and other environmental
and quality initiatives will help
you score points in each of the
criteria. They all help contrib-
ute to environmental excel-
lence.

MEASURE PROGRESS
——»| TOWARD ZEROWASTEAND }—>
EMISSIONS:

5

Prepare Green Zia-type Application
Score Application Using Trained Examiners
Determine How P2 Influenced Feedback Report
Continual Improvement of P2 Program

Figure 7-6. Measure Progress Toward Zero Waste and
Emissions.

to continually improve the P2 plan and other initiatives aimed at
attaining zero waste and emissions.

Not only can an organization score itself, but it can also score all of
its suppliers. These scores can be compared on an “apples-to-apples”
basis. In this manner, the entire life cycle of a product to a customer
can be scored for environmental excellence, P2, and product steward-
ship. Improvements can be weighed against the effect they had on the
trending of these scores in time. While scoring may not be for every-
one, it can be a useful tool for measuring continual improvement.

USING THE QUALITY MODEL TO IMPLEMENT P2

The use of the Systems Approach and the quality model provides
a means of creating a sustainable P2 plan for your organization. Is it
worth the effort? If your organization already has a quality program in
place, the effort is not great at all. It is likely that there is already a
program in place that you can build on. The quality model criteria and
guiding principles simply emphasize good business practice and should
be easy to implement at any rate. Your ISO 14001, Global Reporting
Initiative, CERES Principles, Responsible Care Program®, balanced
scorecard, six sigma, ISO 9000, and other environmental and quality
initiatives will help you score points in each of the criteria. They all help
contribute to environmental excellence. This program simply provides
a means of integrating these approaches with environmental perfor-
mance in your organization.

The P2 plan should be integrated with the core business prac-
tices. “Oh, that is something that the environmental coordinator is do-
ing!"—such an attitude can only limit results. By making the P2 plan
more businesslike, the possibilities for P2 within the organization and
across the country are significantly enhanced.

SSPOOOHOSHHOSSSSOGSOHHOHOHSHSSSHSOOSSOSOHSHOOSSSHOSSCOOSESCHOOOSCE



EE EE EE LE IE I IEE Ose ee ee VS Ve VV VE Ve VVVeEVe EVV VeEV Vee VeVT Ve eV eee eS

When an organization has this information, it has positioned itself
to monitor its progress efficiently. It can then compare its performance
to that of competitive or benchmarked organizations and evaluate its
P2 action.

Partnership Development

Successful organizations build internal and external partnerships
to help them accomplish their overall P2 goals. Examples of internal
partnerships include better labor-management cooperation, employee
development, cross-training, and the creation of worker P2 teams. Some
organizations have concerted training programs and active employee
involvement. This engenders good communication between manage-
ment and workers. Employee involvement needs should be assessed
often to ensure that sufficient resources are provided to assist these
programs in their P2 efforts.

External partnerships include cooperation with customers, sup-
pliers, regulators, and other outside organizations and interested
parties. For example, hotels and hospitals can create partnerships
to improve their similar work processes and benchmark their gains
with each other. Many trade associations have created partnerships
for P2 best practices. Strong partnerships with key suppliers that
are mutually beneficial can improve cost competitiveness, quality,
and overall responsiveness, as well as minimize toxics use and
waste. Key suppliers can participate in the development and design
of shipping and packaging materials that incorporate good ergonom-
ics and reduce or eliminate other wastes. It is helpful for the exter-
nal partners to have a financial or other stake in the achievement of
the organization’s goals for the P2 program.

Corporate Responsibility and Citizenship

Successful organizations always address their corporate and
citizenship responsibilities. Corporate responsibility refers to the
basic expectations of the organization and includes business eth-
ics and the protection of public health, safety, and the environment.
Corporate citizenship refers to the leadership and support of pub-
licly important purposes, such as education, environmental excel-
lence, improved industry and business practices, and the sharing
of nonproprietary P2-related information. Leadership as a corpo-
rate citizen also entails influencing other organizations, private and
public, to partner for these purposes.

Fast Response

Permits and regulatory compliance often add significant time to
organizational decision-making. Success in globally competitive mar-
kets demands ever-shorter cycles for introductions of new or improved

P2 Program Elements

Successful organizations build
internal and external partner-
ships to help them accomplish
their overall P2 goals,

External partnerships include
cooperation with customers,
suppliers, regulators, and
other outside organizations
and interested parties.

Corporate citizenship refers to
the leadership and support of
publicly important purposes,
such as education, environ-
mental excellence, improved
industry and business prac-
tices, and the sharing of
nonproprietary P2-related
information.



GETTING STARTED: POLICY AND PLANNING >
RECOGNIZED NEED COMMITMENT
1 2 3
—>| IMPLEMENTATION EVALUATION AND
MANAGEMENT REVIEW
4 5

Figure 6-1. Implementing P2 Using an EMS Program (Top-level Process Map).

derstands, and it will keep top management's attention through involve-
ment. The EMS provides a systematic approach for integrating envi-
ronmental protection into all business functions and management strat-
egies.

The EMS provides a system-

atic approach for integrating

environmental protection into
One important way the EMS standard promotes integration ofenvi- _ all business functions and

ronmental and organizational management is by requiring top man- | management strategies.

agement to define the environmental policy. However, the EMS approach

to P2 encourages several initial activities prior to setting up the policy:

id management techniques) a

> Reviewing the policies in place and environmental concerns

-=u#for the future H

-@ . Ensuring that all relevant information is up to date

*. © Generating an environmental plan for continual involvement
and improvement for the future

Figure 6-2 is a process map that shows these initial steps in the
EMS approach to P2.

As an initial step in developing a comprehensive EMS, most orga-
nizations find it helpful to complete an objective gap analysis of their
existing environmental system. This enables the organization to dis-
cover its current status regarding environmental performance andcom- The scope of the gap analysis
pliance and highlight areas that require attention under an EMS. The —_gudit should include all areas
results of a “gap” analysis will provide a benchmark for the ofthe organization related to
organization’s alignment and conformance to the ISO 14001 standard. —_ environmental systems as well
Many organizations are developing useful gap audit tools, including fa-_as the interfaces between a
cilities, consultants, and technical assistance providers. The scope of specific facility and its corpo-
the gap analysis audit should include all areas of the organization re-__ ate environmental depart-
lated to environmental systems as well as the interfaces between a ment.
specific facility and its corporate environmental department.

pproach to P2 Impleméntatio



Resource conservation
* Enhanced public image

There are a number of impediments that P2 programs must address. These include:

Speci ications
PA OSM NA HR BO EAA

gL julatory i issues «

: od ct quality is issues

‘* Customers’ acceptance

- -¢ “Immediate production concerns _

* Organization image concerns

+ Available time/technical expertise

A five-step model is presented showing an alternative approach using the P2 tools discussed later in
this Guide (Chapter 4). This is contrasted to the traditional approach to P2.

E.2 Getting Started With P2

Chapter 2 provides information on getting started with the P2 program process. First, set the bound-.
aries around the program by deciding how P2 will be defined. Definitions from the EPA, United Nations
Environment Program, and the World Business Council for Sustainable Development are presented. The
user can choose to add elements from cleaner production and eco-efficiency to create a unique P2 defini-
tion that is broader than EPA’s definition.

Itis possible to use the P2 program to’ help an organization attain a goal of sustainable development.
In addition, itis possible to integrate P2 into core business practices like six sigma, zero waste, and other
company programs such as:

oe “Preventive maintens
+ Health and safety programs
+ Insurance/risk management
Although a commitment to the P2 program should begin with management (i.e., top-down approach),
line employees can often suggest valuable improvements in operations and procedures (i.e., bottom-up
approach). The P2 tools presented in this Guide are well suited for encouraging employee participation as
well as management recognition.



FOREWORD

The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's land,
air, and water resources. Under a mandate of national environmental laws, the Agency strives to formulate
and implement actions leading to a compatible balance between human activities and the ability of natural
systems to support and nurture life. To meet this mandate, EPA’s research program is providing data and
technical support for solving environmental problems today and building a science knowledge base nec-
essary to manage our ecological resources wisely, understand how pollutants affect our health, and pre-
vent or reduce environmental risks in the future.

The National Risk Management Research Laboratory (NRMRL) is the Agency's center for investiga-
tion of technological and management approaches for preventing and reducing risks from pollution that
threaten human health and the environment. The focus of the Laboratory’s research program is on meth-
ods and their cost-effectiveness for prevention and control of pollution to air, land, water, and subsurface
resources; protection of water quality in public water systems; remediation of contaminated sites, sedi-
ments and ground water; prevention and control of indoor air pollution; and restoration of ecosystems.
NRMRL collaborates with both public and private sector partners to foster technologies that reduce the
cost of compliance and to anticipate emerging problems. NRMRL’s research provides solutions to envi-
ronmental problems by: developing and promoting technologies that protect and improve the environment;
advancing scientific and engineering information to support regulatory and policy decisions; and providing
the technical support and information transfer to ensure implementation of environmental regulations and
strategies at the national, state, and community levels.

This publication has been produced as part of the Laboratory’s strategic long-term research plan. Itis
published and made available by EPA’s Office of Research and Development to assist the user commu-
nity and to link researchers with their clients.

E. Timothy Oppelt, Director
National Risk Management Research Laboratory



N

National Park Service vision statement, 32
National Pollution Prevention Roundtable, 44
Non-product loss, 53, 56, 57

Non-product use, 53

Nonproprietary knowledge, sharing, 43
Nothing to Waste, 49, 75-76

Nothing to Waste program, 75-76

ie)
Objective gap analysis, 81
Occupational Safety and Health Administration (OSHA), 97
Olin vision statement, 32
Opportunities
80/20 rule, 57, 59, 115
assessment, 41-42
developing, 115-116
Pareto analysis, 57-58, 115
rank ordering, 58, 115
selecting, 57-59
Options. See alternatives
Organizational waste, 10
Organization image, 15
OSHA (Occupational Safety and Health Administration), 97
Overhead allocation, 43

P

P2 (pollution prevention)
alternative view of, 15-18
benefits of, 11-13
decision-making, 17
definition, 21
as environmental program, 28
evolution of, 9-11
impediments to use of, 13-15
implementation with quality-based program, 118-119
improving P2 plan, 112-118
lessons from past programs, 27-28
maintaining P2 program, 73-74, 117
as mindset, 27
opportunities, 16
planning (see Planning)
problem solving, 17
program elements, 3, 31-47
program evaluation, 44
program management, 17-18
starting P2 efforts, 27
steps in, 15-18



Each element of the
organization's P2 program
should link itself with the
organization's core values.

This core value recognizes
what various interested parties
would like to gain from a P2
program and ensures to it that
they get what they want.

By comparing your program
with other P2 programs, your
organization’s commitment to
P2 and sustainability can be
differentiated from that of the
competition.

36

you integrate key business requirements within a results-orientated P2
framework. These core values are also referred to as guiding prin-
ciples. They will help bridge the gap between the various components
discussed previously by identifying the fundamental, underlying beliefs
that guide the actions within the organization. All organizations have a
set of core values, although in some cases they do not exist in written
form.

Each element of the organization’s P2 program should link itself
with the organization’s core values. Certainly, there are no prescriptive
ways to do this. Each organization must approach these core values in
a manner that fits the local organizational culture.

Following are examples of several core values that could be re-
flected in a P2 program. Paying particular attention to how these core
values relate to the organization’s core values is a very important com-
ponent of a P2 program (References 3-2, 3-3).

Interested-Party—Driven P2

This core value recognizes what various interested parties would
like to gain from a P2 program and ensures that they get what they
want. If P2 saves money, managers and shareholders will support it. If
P2 helps an organization stay in compliance, regulators will support it.
If P2 helps improve working conditions, employees will support it.

AP2 program should work to build trust, confidence, and loyalty by
not just meeting interested party requirements, but going the extra dis-
tance to reduce waste and conserve resources.

By comparing your program with other P2 programs, your
organization’s commitment to P2 and sustainability can be differenti-
ated from that of the competition. This unique focus, which probably
fits well within your organization’s culture, should leave the interested
parties delighted—not just satisfied—by the P2 program.

Interested Parties Include:

SUPP tS naan
rae Regulators se was
ublic groups and non-government organ
* Community Groups

Leadership

All senior leaders in the organization must create an interested-
party orientation. They must set clear and visible P2 values and have

Chapter





Continual improvement is important to focus the organization on
P2 success. Organizations strive to improve, but few understand the
difficulty in trying for continual improvement. Frequently, organizations
initially set percentage improvement goals beyond their reach with too
little information. P2 is based on achieving many successes over time.
Many of the problems of organizations have evolved over many years
and cannot all be solved at one time. The organization can use Sys-
tems Approach tools to generate the information effectively and use it
to set goals during the development of the action plans. Although it is
important to focus improvement efforts on critical issues (Pareto dia-
grams), improvements can be made little by little until these major is-
sues are resolved.

Organizations strive to im-
prove, but few understand the
difficulty in trying for continual
improvement.

Incremental improvements can lead to breakthrough improvements.
This is accomplished by learning from the improvements and seeking
to make larger improvements. Incremental improvements also allow
for “quick wins.” These little victories, when accompanied by cost data,
help maintain management approval for the P2 effort. Continued fund-
ing of P2 projects also provides the time for breakthrough improve-
ments to materialize.

Checklists are useful tools for gathering information and data and
tracking progress of the problem-solving and decision-making method.
However, they are relatively ineffective at communicating that informa-
tion to management and other interested parties. Each of the Systems
Approach tools has a visual output that is much more effective in this
regard.

Making P2 a way of life in order to achieve success takes more
. than words; it requires action. Action plans provide documentation for
these actions and a means of tracking P2 progress over time.

REFERENCES

4-1. Nothing to Waste Manual
http:/;www.nmenv.state.nm.us/ (see Special Projects)

4-2. “Understanding a process by using process mapping.”
Pojasek, R.B. (1997). Pollution Prevention Review 7(3):
91-101.

4-3. “Materials accounting and P2.” Pojasek, R.B. (1997). Pollution
Prevention Review 7(4): 95-103.

4-4. “Selecting P2 opportunities.” Pojasek, R.B. (1998). Pollution
Prevention Review 8(2): 103-110.

4-5. “Using cause and effect diagrams in your P2 program.” Pojasek,
R.B. (1996). Pollution Prevention Review 6(3): 99-105.

I EL iL ___ eee erelerelerelerelerelererelwrwereew ewe Vr eee eV VV eVVV Ve Vee Vee



It became obvious that these
small organizations could not
afford any waste.

States that have adopted this
model have been able to
make better use of their
technical assistance providers
by having them “visit” with
many small organizations at
once instead of making many
trips to separate operations.

loan. When the group determined that a member was qualified for a
loan, the group had the power to grant that loan. The bank stipulated
that if the person missed any payments, everyone in the group was
dunned and could not get-a loan for a specified period of time. This
stipulation made the members of the group work together better so
that everyone paid back loans. Banks were very happy with the results.
Previously, typical loan defaults for this segment were as high as 60%.
Using this model, loan defaults dropped to less than 10%.

It became obvious that these small organizations could not afford
any waste. Their initial loan could only be $500. If an individual borrower
wasted any of this money, the entire group would be less successful.
For example, a small furniture maker needed to know that finish
overspray led to the loss of some of the valuable finish that was pur-
chased. The furniture maker had to find out how more of that finish
could be placed on the furniture to reduce the waste.

In the Nothing to Waste program, leaders from very small organi-
zations still meet regularly in off-work hours in teams of five to seven
companies. They use the Systems Approach tools under the guidance
of a group facilitator trained in the use of the tools. They map each
other's processes, apply the tools to identify opportunities for P2, and
derive and select alternatives for dealing with the losses. The group
facilitator also helps provide the group members with P2 information
and resources that may be needed to implement the selected P2 alter-
native. States that have adopted this model (e.g., New Mexico, Maine,
and Massachusetts) have been able to make better use of their techni-
cal assistance providers by having them “visit” with many small organi-
zations at once instead of making many trips to separate operations.

Very small organizations may not have the technical capability to
follow the formal traditional approach on their own. However, they can
master the problem-solving and decision-making tools quickly and use
them to communicate effectively with one another, even though they
do not actually work together. They can learn how to communicate
better with their customers, suppliers, and lending institutions as a
result of learning how to use these tools. Action plans allow the group
to track each other's progress. These plans are reviewed at each
meeting.

Nothing to Waste has been formally adopted for use in the Green
Zia Program in New Mexico (Reference 5-1). This publication is avail-
able on the Internet and can be found on the CD-ROM. It can be used
by P2 teams in larger companies to help worker teams get an under-
standing of the use of the tools in the Systems Approach without an
expensive training program.

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ion

event





ence Talmanenioton in other .

include employees i
involve vendors, su

For al action plans developed to support process analysis and im: | im-
provement (P2) efforts?

mpployees included in the development of action plans?
i and ot

f other organizational programs, ask these questions

‘How are:

Action plans ‘implemented, tracked, modifi ied (ior ‘continual improve-

ment), and communicated to all interested parties? _

The action plans linked to the strategic planning process of the organi-

zation?

Resources aligned to support improvement (P2) efforts?

+ All the results from the programs disseminated to support organiza-
tional learning and improvement of the environmental management pro-
cess?

+ Environmental management processes formally maintained and im-

proved?

The quality-based P2 approach and the EMS approach require writ-
ten action plans. The EMS-based approach requires environmental
management programs (EMPs) as written action plans. These docu-
ments are used to track progress made during the year on all sched-
uled P2 projects and activities. They are auditable by independent third
parties. The Systems Approach tools help gather the information needed
for comprehensive action plans. At the end of the year, it is possible to
perform a “lessons learned” review of each of the action plans or EMPs
and a decision can be reached on what to do in the following year.

Finding Your Own Way to-Amplement P2

strategic planning

action planning

integration and implementation

with other organizational
programs

125



arch Laboratory
1987-1996



NOTICE

The U.S. Environmental Protection Agency through its Office of Research and Development funded
and managed the research described here under Contract #68-C7-0011, Work Assignment #3-20, to
Science Applications International Corporation. It has been subjected to the Agency's peer and adminis-
trative review and has been approved for publication as an EPA document. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.



CHAPTER 7

Using a Quality Model to
Implement P2

INTRODUCTION

This chapter presents an approach to preparing a P2 plan that is
business-oriented, while still meeting any state or local P2 requirements.
P2 has sometimes suffered from its reputation as something that the
environmental personnel do or direct others to do. A more effective
approach is integrating P2 into your organization's core business prac-
tices. This approach allows you to communicate the value of P2 to
both senior management and workers. Your P2 plan also can be main-
tained and improved on an annual basis. This chapter presents a proven
quality model that is based on the highly successful Baldrige Quality
Program.

The Malcolm Baldrige National Quality Award is bestowed each
year by the President of the United States on organizations that have
demonstrated proficiency in the use of this quality model. The award
was established by the U.S. Congress in 1987 to raise awareness about
the importance of quality and performarice excellence. When this award
was established, the organizers believed that quality was no longer
optional for American companies but was instead a necessity for doing
business in an ever-expanding and more competitive world market.
Nearly 50 countries now offer awards based on the Baldrige quality
model, and 43 of the 50 states in the United States offer awards based
on this model.

In 1998, the State of New Mexico began the Green Zia-program,
which adopted this quality model to measure environmental excellence.
Environmental excellence is a term that describes the ultimate goal
sought by using a quality program for environment, health, and safety
(EHS) management. An environmental excellence program sets a
“stretch goal” of attaining “best-in-class” status in those areas that best
support a prevention-oriented approach to EHS management. No longer
are short-term goals with percent reduction targets accepted by upper
management and other interested parties. Results from these goal-
driven activities are only “outcomes” of EHS performance and not a
measure of the performance itself. Also, results by themselves offer
little diagnostic value (i.e., were “good” results well below those of your
competitors?). Green Zia shows an organization how to use a 15-item
list of performance characteristics that can be modified to enable fast-
paced EHS program improvement and thus contribute to the results.
By focusing on performance, the organization can both help encour-
age P2 program development and provide a metric to show how effec-
tively that P2 program is working.

Using a Quality Model to Implement P2

Includes:

Introduction

Seven Quality Model
Criteria

Eleven Quality Model
Guiding Principles
Five-Step Process to
Improve Your P2 Plan
Using the Quality Model
to Implement P2
Supplemental Reading
Web Sites

HO O8 @ 8 20

The Malcolm Baldrige National
Quality Award was established
by the U.S. Congress in 1987
to raise awareness about the
importance of quality and
performance excellence.

In 1998, the State of New
Mexico began the Green Zia
program, which adopted this
quality model to measure
environmental excellence.
Environmental excellence is a
term that describes the ulti-
mate goal sought by using a
quality program for environ-
ment, health, and safety
(EHS) management.

103



When getting started with a P2
program, look around to see
what other types of “preven-
tion” programs already exist in
the organization.

This Guide will provide some
methods you can use to
emphasize P2 within an EMS.

sions (Reference 2-4). For some organizations, this goal may seem
unrealistic. However, many organizations reach these goals by con-
verting previously unused wastes into other products and driving their
programs to near zero waste. This zero concept is very popular in the
quality movement and more particularly with a program referred to as
“six sigma’ (i.e., attaining the goal of only 3.4 defects per million opera-
tions instead of the 35,000 to 60,000 defects per million operations that
most very competitive organizations now tolerate). This number of de-
fects is very close to zero. Some organizations have extended the six
sigma approach to regulatory compliance issues where they consider
a “notice of violation” a defect. However, more progressive organiza-
tions use six sigma to prevent regulatory compliance issues.

INTEGRATING THE NEW P2 PROGRAM INTO CORE
BUSINESS PRACTICES

Organizations considering a P2 program may already have com-
patible programs in place. When getting started with a P2 program,
look around to see what other types of “prevention” programs already
exist in the organization. Box 2-4 lists some prevention-oriented pro-
grams that currently exist in many organizations. Can the P2 program
be tied to any of these or similar programs? The integration of the P2
program into existing core business practices can help small organi-
zations find resources to start a new P2 program and large organiza-
tions consolidate existing programs, allowing each to remain competi-
tive in the global marketplace as they implement P2.

. Insurance/risk management

Environmental Management Systems

One program that may be compatible with a new or revised P2
program is an environmental management system (EMS). One popu-
lar EMS format, known as ISO 14001, has been issued by the Interna-
tional Organization for Standardization (Geneva, Switzerland). ISO
14001 is a management system standard, not a performance stan-
dard, providing a general framework for organizing the tasks neces-
sary for effective environmental management. This approach may prove
effective in encouraging the organization to take an active, preventive,
and systematic approach to managing its environmental impacts. This
Guide will provide some methods you can use to emphasize P2 within
an EMS (see Chapter 6). An EMS protocol requires the organization to

Chapter 2

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targets for the significant aspects. The potential for exchange between
an EMS and state P2 facility planning requirements is generating inter-
est among environmental regulators in several states. As part of the
MSWG initiative, the state of Washington studied organizations using
ISO 14001 and concluded, “EMSs are proving to be a superior approach
for implementing P2 assessments and planning activities.” They allow
the EMS to meet the organization’s planning requirements if the waste
management hierarchy is followed in setting objectives and targets.
The EPA's Environmental Performance Track program has developed
a matrix of several other state programs that have modified their re-
quirements, and it can be found on their Web site (Reference 6-4).

ENVIRONMENTAL POLICY, MANAGEMENT COMMITMENT,
AND SCOPE OF THE EMS

Based on the current environmental assessment and performance,
it is management's responsibility to develop a shared vision and direc-
tion for the organization’s EMS policy and to commit to its implementa-
tion (Figure 6-3, work steps 2.1, 2.2, 2.3). In the policy, management
defines its scope and ensures consistency with the organization’s vi-
sion, core values, beliefs, and other goals. Management may use the
new policy to expand the organization’s environmental perspective. The
environmental policy for an EMS contains the following commitments:

|

ammitment to compliance with all applicable requirements

ind other requirements to which the organization subscribes

»... Commitment to continual improvement of the system itself

--and not specifically continued improvement of the required
environmental performance criteria.

a

a

The state of Washington
studied organizations using
ISO 14001.and concluded,
“EMSs are proving to be a
superior approach for imple-
menting P2 assessments and

planning activities.”

Internal Communication

EMS Approach to P2 Implementation '

DEVELOP DEVELOP SCOPE AND
SHARED VISION ENSURE CONSISTENCY COMMIT TO IMPLEMENT
AND DIRECTION WITH CORE VALUES AND THE POLICY
FOR POLICY OTHER GOALS
22 23
Prevention of Pollution
Compliance
Continual Improvement
COMMUNICATION OF >
EMS POLICY
24
External Communication

Figure 6-3. Policy and Commitment: Define Environmental Policy, Scope, and Commitment.



©SOOCHCHOOHOOOOHOOLLOOOOOOOHOOOSHHHHOHHHHOHHOOOHOHOHOODD


In order to increase the performance score, organizations must demonstrate how they leverage the
various performance activities with other performance criteria. The organization also needs to find a way
to integrate each of the eleven guiding principles with the proper criteria in the model. This facilitates the
integration of the P2 program into the organization.

A five-step process is offered to improve or develop a P2 plan using the quality model concepts. The
steps are as follows:

imple lement your F P2 program alternatives
ede cnt tS untsrnnneed mine risus fel fon Aes an gb th Ba “ 4

Maintain your P2 program
5. Measure your progress toward zero waste and emissions

The use of the Systems Approach and the quality model provides a means of creating a sustainable
P2 plan for your organization. Your ISO 14001, Global Reporting Initiative, CERES Principles, Responsible
Care® Program, balanced scorecard, six sigma, ISO 9000, and other environmental and quality initiatives
will help the organization score points in each of the criteria. All these programs help contribute to environ-
mental excellence. This quality model simply provides a means of providing a common thread on how they
are related and allows you to see just how effective they are at driving environmental performance in your
organization.

The P2 plan should be integrated with the core business practices. “Oh, that is something that the
environmental coordinator is doing!” — such an attitude can only limit results. By making the P2 plan more
businesslike, the possibilities for P2 within the organization are significantly enhanced.

E.8 Finding Your Own Way to Implement P2

Three approaches to implementing a P2 program have been presented in Chapters 5-7. This chapter
discusses some of the items that are covered in these approaches to provide you with some ideas for -
planning and implementing a P2 program that is specific to your organization’s requirements and culture.
The following categories a are presented that a P2 program could choose to address:

Po goal setting
Foous on 1 results” , wee
ranalysis ee

a ig

* * Focus on interested parties
* Guiding principles or core values
+ P2 program elements

E-9. CD-ROM

This Guide has been issued with a companion CD-ROM. It provides supporting information on all the
topics and additional materials that may be required to plan and implement a P2 plan for your organization.



YYTITIT ITT lili



Often, it is the employees
most familiar with the
organization's production
processes who are in the best
position to identify P2 projects
for improving environmental
program performance.

The EMS is designed to

continually improve system

and environmental perfor-

mance through creation of an

environmental management
* program (EMP).

way up to the week of the ISO 14001 registration audit. This approach
was excellent for several reasons: (1) it built on a system already in
place, (2) the regular meeting established and reinforced the impor-
tance of knowing this information, and (3) the employees knew where
to go when the auditors asked them questions about these areas of the
EMSs.

By providing environmental awareness training for all employees,
an organization can count on the technical know-how of employees on
the production floor to help find creative P2 strategies to reduce their
environmental impacts. With respect to training competency, the EMS
standard asks that the organization determine what qualifications (edu-
cation, training, and/or experience) are necessary and to ensure that
each employee completes these requirements for his/her job. Often, it
is the employees most familiar with the organization’s production pro-
cesses who are in the best position to identify P2 projects for improv-
ing environmental program performance. Just as an organization uses
incentives to boost employee productivity, management should pro-
vide incentives for developing useful ideas to reduce waste.

Environmental Management Programs (EMPs)

The EMS is designed to continually improve system and environ-
mental performance through creation of an environmental manage-
ment program (EMP). The EMP is the last element of the EMS plan-
ning phase (Figure 6-4, work step 3.5). It sets up action items, assigns
responsibilities at all levels of the organization for plan execution, sets
specific time lines, and determines the resources needed for imple-
mentation to achieve the objectives and targets. With the goals estab-
lished, the subset of activities defined, and the accountabilities in place,
each person with specific responsibilities must now develop EMPs for
implementation. One person or several people are assigned the ac-
countability for meeting the goals and objectives in the planned time
frame for each task in the action plan and for maintaining the current
level of performance on each of these items.

Although setting objectives and targets is treated as a separate
function from EMPs in the planning phase, they are related. You have
to have an idea of how you will accomplish an objective and target
before you set it up as a program in your system. This is the process
many organizations now use in their P2 planning effort to accomplish
specific projects. After P2 assessment and planning, projects are initi-
ated to implement technically and economically feasible P2 opportuni-
ties. Without the continual improvement component of the EMS, how-
ever, P2 planning and implementation may be an end point instead of
the ongoing process of setting new objectives and targets for other
aspects that impact the environment.

The number of EMPs that an organization sets up can vary. One
company uses one EMP to address all of its objectives and targets.

Chapter 6



CHAPTER 5

Traditional Approach to P2
Implementation

INTRODUCTION

A number of models are available for implementing your P2 pro-
gram. This chapter will focus on a “traditional” model based on the
previous editions of this EPA Guide (Waste Minimization Opportunity
Assessment Manual, EPA/625/7-88/003 and Facility Pollution Preven-
tion Guide, EPA/600/R-92/088). Chapter 6 will examine an implemen-
tation model that utilizes a formal environmental management system
(EMS). Chapter 7 will evaluate the use of a quality model for P2 imple-
mentation. This Guide will not prescribe or recommend any one of these
P2 implementation models. Instead, you can mix and match compo-
nents to derive a P2 program implementation model that works best in
your organization. If you do this, your organization’s P2 program is far
more likely to be implemented and maintained. This concept will be
presented in Chapter 8.

At the top level (Figure 5-1), the traditional P2 model offers a logical
path for implementing P2. First you establish the P2 program using the
information provided. Then, you prepare a written P2 plan to describe
how the program will be implemented. Next, you execute the program
implementation. Finally, you must maintain the P2 program over time.

ESTABLISH P2 WRITE P2 PROGRAM
PROGRAM > PLAN
1 2
P2 PROGRAM MAINTAIN P2
IMPLEMENTATION PROGRAM
3 4

Figure 5-1. Top-level Depiction of the Traditional Approach to
Pollution Prevention Implementation.

Traditional Approach to P2 Impler

Includes:

O Introduction

O Establishing a P2 Program

O Writing the P2 Program

Plan

P2 Program

Implementation

Maintaining the P2

Program

Combining the Traditional

Approach with the

Systems Approach

O Approaches for Very
Small Organizations

O Other P2 Implementation
Approaches

O Reference

Oo Oo QQ

You can mix and match
components to derive a P2
program implementation
mode! that works best in your
organization. If you do this,
your organization’s P2 pro-
gram is far more likely to be
implemented and maintained.



fe . Provide the needed résou
to initiate the P2 program. People who participate
deciding what p2 changes are needed and how they will
occur are more ‘likely to support the changes and advance
the program. Provide training and lessons learned to in-
crease the success of the P2 program.

Chapter 3 will describe some of the elements that will help make
the P2 program work and thrive.

REFERENCES

2-1. | EPAWeb Page http:/ A:] jov/r i/programs/ai
air/nsr/nsrmemos/pollprev.pdf

2-2. United Nations Web Page
http:// .unepie.org/Cp2/home.html

2-3. World Council for Sustainable Development Web Page

http://www.wbesd.ch/aboutus.htm

2-4. “Focusing your P2 program on zero waste.” Pojasek, R.B.
(1998). Pollution Prevention Review 8(3): 97-105.

2-5. NIST Baldrige Web Site http:/A .quality.nist.go'

2-6. “New Mexico’s Green Zia Environmental Excellence Program:
Using a Quality Model for a Statewide P2 Program.”
Gallagher, Patricia; Kowalski, Judy; Pojasek, R.B.; and
Weinrach, Jeff. (1999). Pollution Prevention Review 9(1):
1-14.

2-7. Maintenance Technology Web Site http:/Avww.mt-online.com/

2-8. OSHA Internet Site http://www.osha.gov

2-9. EPAListing of State P2 Programs
ittp:// AS) ov/opptintr/p2home/resol s/st 2.ht

SCOOCOOOOOEOOHOOOO OOOOH OHOSOOSHOHOSHHOHOOOHEHHHOHHOHHOOOS



Process maps can also be
used to assess the costs of
resource use by work step.
These costs can then be used
to rank order opportunities for
P2 and charge back the costs
to the processes and products
that are responsible for creat-
ing the waste—a sort of inter-
nal “polluter pays” principle.

P2 assessments are used to
verify and update process
maps. As each P2 opportunity
is examined, a P2 assess-
ment can be used to gather
new information (including cost
data) necessary to support the
use of other Systems Ap-
proach problem-solving and
decision-making tools.

True costs associated with
resource use and loss will
change over time. Periodic P2
assessments can be used to
update the cost information in
the process map templates.

42

Process maps can also be used to assess the costs of resource
use by work step. These costs can then be used to rank order opportu-
nities for P2 and charge back the costs to the processes and products
that are responsible for creating the waste—a sort of internal “polluter
pays” principle. It is very important to focus not on the wastes, but
rather on the processes and products that are responsible for.them.
Every resource used in a process represents an opportunity to con-
serve the use of that resource, and every loss or waste from a process
represents an opportunity not to generate that loss or waste.

3. Perform Periodic P2 Assessments

In the Systems Approach, P2 assessments are used to verify and
update process maps. As each P2 opportunity is examined, a P2 as-
sessment can be used to gather new information (including cost data)
necessary to support the use of other Systems Approach problem-
solving and decision-making tools.

The organization should decide the best method to use for per-
forming P2 assessments and related data gathering. Once this is de-
cided, individual processes and procedures should be reviewed peri-
odically. In some cases, performing complete resources balances for
some work steps in the process maps can be helpful. P2 assessment
teams can revisit existing process maps or prepare new ones. Pro-

’ cess maps from the main process can be linked to process maps of

related ancillary and intermittent operations that support these pro-
cesses. Process maps can be prepared for different products or fami-
lies of products. The end goal may be to have a complete “book of
process maps” after a number of years of periodic P2 assessments.

True costs associated with resource use and loss will change over
time. Periodic P2 assessments can be used to update the cost infor-
mation in the process map templates. Many organizations track re-
sources used and lost by a variety of means and then normalize the
results to account for variations in production rates. Each organization
should find the best method to account for the true costs of resource
use and loss in its operations.

Analyzing the cost and benefits of each P2 opportunity is an impor-
tant process, especially when the true costs of managing environmen-
tal wastes, discharges, and emissions are considered. Organizations
should establish a good method for selecting P2 opportunities to in-
clude in the P2 program each year. Assessments should support and
invigorate a P2 program. They should not be the basis upon which the
P2 program is built.

4. Maintain a Cost Allocation System

The EPA suggests that organizations track all the costs associ-
ated with resource use and loss and charge them back to the pro-

PYTTTITITILL LLL LITT LLL Tir r Ltr rrr tiie



Integrating human resource practices: selection,

== performance, recognition, training, and career

sé» advancement.

-- Developing, cultivating, and sharing the P2 knowledge
- possessed by the organization’s employees.

3. Aligning human resource management with strategic
change processes.

x sls eal

Addressing these challenges requires use of employee-related data
on process knowledge, skills, satisfaction, motivation, EHS knowledge,
and well being. Such data can be tied to indicators of organizational or
unit performance, such as interested-party satisfaction, customer re-
tention, and productivity. Through this approach, employee contribu-
tions may be integrated and aligned with business P2 directions.

Fast response. Obtaining permits and regulatory compliance can add
significant time to organizational decision-making. Success in globally
competitive markets demands ever shorter cycles for introductions of
new or improved products and services. Also, faster and more flexible
response to interested parties is now a more important requirement.
Major improvements in response time often require simplification of
work units and processes together with timely incorporation of P2 into
the design phase (i.e., design for the environment). To accomplish this,
the P2 performance of work processes should be among the key pro-
cess measures. Other important benefits can be derived from this fo-
cus on time: time improvements often drive simultaneous improve-
ments in organizational behaviors, quality, P2, cost, and productivity.
Hence, it is often beneficial to integrate response time, quality, P2, and
productivity objectives.

Efficient product, service, and process design. Organizations need
to emphasize P2 in the design phase—problem and waste prevention
achieved through building P2 into products and services and building
efficiency into production and delivery processes. P2 design includes
the creation of fault-tolerant (robust) or waste-free processes and prod-
ucts. Costs of preventing problems at the design stage are lower than
costs of correcting problems that occur “downstream.” Accordingly,
organizations can emphasize P2 opportunities for P2 innovation and
interventions “upstream”—at early stages in processes. This approach
should also take into account the organization’s supply chain.

The design stage is critical from the point of view of public respon-
sibility. In manufacturing, design decisions impact the production and
content of municipal and industrial wastes as well as other environ-
mental impacts. Effective design strategies should anticipate growing
environmental demands and related issues and factors.

Long-range view of the future. Pursuit of market leadership requires
a strong future orientation and a willingness to make long-term com-

Using a Quality Model to Implement P2

Major improvements in
response time often require
simplification of work units and
processes together with timely
incorporation of P2 into the
design phase (i.e., design for
the environment).

Organizations need to empha-
size P2 in the design phase—
problem and waste prevention
achieved through building P2
into products and services and
building efficiency into produc-
tion and delivery processes.

411


When you tailor the P2 program to your organization’s vision, mis-
sion, and goals, you speed its acceptance by the members of the orga-
nization. The P2 program’s overall success will be ensured.

REFERENCES

3-1. Sustainable Measures Web Site
http:/Avww.sustainablemeasures.c

3-2. Green Zia Manual
tip: .pojasek-associate: m/Services;

2001Green_Zia_Criteria.pdf

3-3. | Massachusetts environmental excellence paper
Wik ojasek-associates.com/Reprints/baldrige.doc

3-4. American Chemistry Councils Responsible Care® Web Site
http://www.americanchemistry.com

3-5. National Pollution Prevention Roundtable (NPPR) Position
Paper on Facility Planning
ttp:/ -p2.org/inforesources/facil-pl.html

P2 Program Elements

EEE EEE EE ES EEE IE I IE IE OOO ee Ve VV Ve Ve Ve Vee VeVVeEVwVeEVeVeTVeVVeVeVIyT eS



Some organizations have
already begun to extend their
EMS program to the supply
chain. It is logical to extend
this involvement to the P2
program as well.

132

‘olve employees in product, service, and process design for continual
alimproverments

ie

‘successes?
Encourage employee participat
s?
i

es

king process improvement
.. decisions? - :
+. Gather input on the work environment from employees?
© Motivate and reward employee participation in the organization's envi-
ronmental improvement program?
+ Assist employees in dealing with life issues that can impact their abil-
ity to do work?
+ Assess employee satisfaction?

FOCUS ON INTERESTED PARTIES

The EMS- and quality-based approaches clearly recognize the im-
portance of having ties with regulators, customers, suppliers, and a
host of other interested parties. The traditional approach provides for
technology transfer, but it does not seek feedback on environmental
concerns of the interested parties.

By addressing the questions asked in Box 8-6, your organization
can move in the direction of involving interested parties in the P2 pro-
gram. Some organizations have already begun to extend their EMS
program to the supply chain. It is logical to extend this involvement to
the P2 program as well. Customers need to see decisions regarding
the products and services in light of what the environment, health, and
safety implications may be throughout the life cycle. Other interested
parties need to see how their actions affect the organization’s ability to
effectively implement and integrate P2 into its core business practices.

Chapter 8



cesses and products responsible for these costs instead of assigning
them to facility overhead. These costs include those that flow from the
general ledger, the cost of resources lost in the waste itself, and the
activity-based costs of managing the losses. When all these catego-
ries are included, it is not uncommon for a company’s waste costs to
be increased by three to five times.

Not all processes and products use and lose resources equally.

Ideally, each product should bear the burden of all the environmental,
health, and safety services that it uses. Managers are encouraged to
utilize accounting systems that generate valid product costs, reflecting
the true costs involved in producing and delivering the organization’s
products and ensuring proper environmental management of resources,
wastes, emissions, and discharges. This is good business because it
will avoid putting an unfair overhead burden on cleaner products; such
products can then be sold for less money or as “premium” products.

The limitations of traditional performance measurements, particu-
larly those methods related to overhead allocation, can produce
misleading or incorrect information: Whenever possible, accounting
procedures and paperwork should be simplified, eliminating non-value
adding activities while providing accurate information for decision-making
and audit requirements. They should also be consistent. Financial per-
sonnel, for example, should be using the same source data as other
personnel. Managerial accounting methods can be used like project
management methods in most organizations. Such information can
be reconciled on a periodic basis as it is allocated to products and
families of products. Further information on environmental accounting
can be found on the CD-ROM.

5. Encourage Technology Transfer

It is important for an organization to seek or exchange technical
information on P2 from other parts of the organization, other compa-
nies, trade associations, professional associations, consultants, ven-
dors, and university or government technical assistance programs. A
considerable amount of time, effort, and taxpayer money has already
been invested by public technical assistance programs and universi-
ties to research P2 alternatives for specific industries and processes.
Although it is risky to use this information as a “silver bullet” for the P2
problems faced by any particular organization, the information does
offer some potential technology options that facilities can consider when
they generate and prioritize P2 alternatives.

Organizations are encouraged to share the nonproprietary knowl-
edge they have gained in their P2 programs through trade associations
and other information clearinghouses. Many P2 award programs re-
quire the participants to share the information that was submitted in the
application for the award.

P2 Program Elements |

The EPA suggests that organi-
Zations track all the costs
associated with resource use
and loss and charge them
back to the processes and
products responsible for these
costs instead of assigning
them to facility overhead.

Not all processes and prod-
ucts use and lose resources
equally. Ideally, each product
should bear the burden of all
the environmental, health, and
safety services that it uses.

It is important for an organiza-
tion to seek or exchange
technical information on P2
from other parts of the organi-
zation, other companies, trade
associations, professional
associations, consultants,
vendors, and university or
government technical assis-
tance programs.

Organizations are encouraged
to share the nonproprietary
knowledge they have gained in
their P2 programs.

43,



The purpose of the detailed
assessment is to help the
team derive alternatives.

Based on the detailed assess-
ment, the assessment feam
proposes a number of P2
alternatives and screens them
to help focus on the imple-
mentation that will follow.

Once the P2 projects have
been selected, the traditional
approach has the P2 team
obtain funding and initiate work
on the alternative.

PERFORM DETAILED DEFINE P2 CONDUCT P2
P2 ASSESSMENT ALTERNATIVES [> FEASIBILITY >
34 32 ANALYSIS 3,3
Name Assessment Team(s) Propose Alternatives Technical Feasibility

Screen Alternatives Environmental Feasibility

Economic Feasibility

Review Data and Site(s)
Organize and Document

Information
WRITE P2 IMPLEMENT P2 MEASURE P2
> ASSESSMENT PLAN >) PROGRESS
REPORT 3.4 3.6 3.6

Input of Assessment Teams _—_ Select P2 Projects Acquire Data

Prepare and Review Report Obtain Funding Analyze Data

Present to Management Initiate Alternative Measure Economic Results

Review and Adjust

Figure 5-4. P2 Program Implementation.

include some employees. Checklists and worksheets are provided to
help the team collect data and information. This assessment team will
review the data and visit the sites where the P2 activity is planned to
occur.

The purpose of the detailed assessment is to help the team derive
alternatives (called “options” in the previous publications) for P2. The
team uses brainstorming as a tool to find potential alternatives. The
traditional approach does not formally include root cause analysis be-
fore deriving alternatives.

Based on the detailed assessment, the assessment team pro-
poses a number of P2 alternatives and screens them to help focus on
the implementation that will follow. Most of the P2 industry-specific
manuals provided a limited number of alternatives, so the screening
was fairly straightforward. The traditional approach model uses criteria
matrices for screening. Once screening is complete, it is time for a
feasibility analysis of the priority alternatives. Of course, not all P2 al-
ternatives require such formal analysis. Quick wins or “low-hanging
fruit’ P2 alternatives can proceed more expediently. They do not com-
pete for capital funding. When an alternative requires some capital fund-
ing to implement, itis frequently subjected to a technical feasibility study,
a determination of its environmental feasibility, and finally a determina-
tion of the economic feasibility. At this point, the traditional approach
requires the preparation of a formal, written P2 assessment report.
This report details the analysis of the P2 assessment team and allows
that information to be presented to management in a formal manner
after a review by the P2 task force. Once the P2 projects have been



IDENTIFY
ENVIRONMENTAL.
COMPLIANCE
PROCEDURES AND

REVIEW POLICIES IN
PLACE AND

ENVIRONMENTAL

ENSURE ALL
ENVIRONMENTAL
INFORMATION IS.

o

CONCERNS FOR THE
FUTURE

4.4 1.2 1.3

MANAGEMENT UP TO DATE

TECHNIQUES

GENERATE AN
ENVIRONMENTAL PLAN
FOR EMPLOYEE
—>| INVOLVEMENTAND [>_>

CONTINUAL,
ENVIRONMENTAL
IMPROVEMENT 4 4

Figure 6-2. Getting Started—Recognized Need.

EMSs require that organizations have a “commitment to comply
with relevant environmental legislation and regulations, and with other
requirements to which the organization subscribes.” An organization’s
current practices for tracking compliance are a good place to start,
and they should be compared to what an EMS entails. An EMS aligned
to ISO 14001 requirements offers the potential for delivering substan-
tial gains in production and environmental efficiency and reduced costs
in environmental compliance. It is likely that top-level management will
view an EMS as a competitiveness issue rather than as a cost center
for environmental compliance. Involvement of top management in de-
fining policy, reviewing the current plan, and maintaining EMS aware-
ness is seen as a positive outcome by many since management has
sometimes been a tough audience to reach on environmental issues.

It is likely that top-level man-
agement will view an EMS as a
competitiveness issue rather
than as a cost center for
environmental compliance.

An organization has to prove that its EMS has been implemented
effectively and leads to compliance over time. The organization must
have a procedure to identify and have access to legal and other re-
quirements to which it subscribes. Periodic compliance and EMS sys-
tem audits are required to assess procedural improvements and iden-
tify needed system improvements through corrective actions. Such a
mechanism for improvement is completely absent in command-and-
control regulations such as BAT (best available technology) standards
and emission standards. Standards such as these give organizations
no incentive to exceed what is necessary for compliance. In some
cases, they may encourage the use of control technologies over other
approaches that would result in better environmental performance.
Command and control standards give organizations no incentive to
exceed what is necessary for compliance.

Command and control stan-
dards give organizations no
incentive to exceed what is
necessary for compliance.

Another regulatory advantage of an EMS is the requirement to con-
sider legal and other requirements when establishing objectives and

82



high expectations. These values and expectations are reinforced by a
substantial personal commitment to the P2 program. Leaders should
serve as role models throughout the organization, thus reinforcing the
P2 core values at all levels. In other words, they should “walk the talk.”
Management must have active, visible leadership roles in the ongoing
strategic planning process to incorporate P2 into all business func-
tions. Leadership’s commitment to environmental performance is dem-
onstrated through consistent decisions on resource allocations such
as money and employees for P2 program implementation and evalua-
tion. If the P2 program is perceived as just another environmental initia-
tive, this leadership core value cannot be realized.

Continual Improvement

Every organization must strive for continual improvement. The or-
ganization should also have a commitment to the continual elimination
and reduction of waste. These.goals can be accomplished by encour-
aging creativity, maintaining a continual improvement environment, and
recognizing and rewarding employees for doing a good job. Employ-
ees at all levels and in all areas of the organization should be actively
involved and contribute ideas for P2 and P2 program improvement.

The P2 program cannot be oriented to simply completing individual
P2 projects. It must take the knowledge gained and use it to address
other P2 opportunities. This use of “lessons learned” fosters continual
improvement. The P2 program must always strive for zero waste, zero
emissions, and conservation of all resources. Zero is where continual
improvement should strive to be.

Valuing Employees

An organization’s P2 success depends increasingly on the knowl-
edge, skills, innovative creativity, and motivation of its workforce. Em-
ployee success depends increasingly on being given opportunities to
learn and practice new skills. Organizations need to invest in the devel-
opment of their workforces through education, training, and opportuni-
ties for continuing growth. Such opportunities include enhanced P2
awareness and rewards for demonstrated P2 knowledge and skills.
On-the-job training offers a cost-effective way to train and better link P2
training to work processes. Education and training programs may need
to utilize advanced technologies, such as computer-based learning and
satellite broadcasts. Increasingly, training, development, and work units
need to be tailored to a diverse workforce and to more flexible, high
performance P2 work practices. These items will prepare employees
and the organization for success.

P2 Program Elements

All senior leaders must set
clear and visible P2 values
and have high expectations.
These values and expecta-
tions are reinforced by a
substantial personal commit-
ment to the P2 program.

The organization should also
have a commitment to the
continual elimination and
reduction of waste.

An organization’s P2 success
depends increasingly on the
knowledge, skills, innovative
creativity, and motivation of its
workforce.

Employee success depends
increasingly on being given
opportunities to learn and
practice new skills.



MAR RBAAAAAAASAAA AA AA SBAAAAAAAAA DAA A att tt i te te ei eee

CHAPTER 8&

Finding Your Own Way to
Implement P2

INTRODUCTION

This Guide has presented three approaches to implementing a P2
program: traditional based, EMS based, and quality based. All three
approaches can be improved by using the process characterization,
problem-solving, and decision-making tools that are described in Chap-
ter 4. Your organization may already have some type of P2 program in
place. It may be seeking only to improve its existing program or may
not feel that there is time to implement a brand new program following
any of these three approaches. This chapter will discuss some of the
items that are covered in these approaches to provide you with some
ideas for planning and implementing a P2 program that is specific to
your organization’s requirements and culture. Let’s take a look at the
program elements in each of these approaches to see where they have
commonality. From this analysis, the elements that your organization
should strive for as it implements the P2 program may be apparent.

We also will look at the various planning elements that were de-
scribed in Chapter 3 of this Guide and the concept of guiding principles
or core values. It will be important to see how these mesh with or re-
main separate from the implementation elements. The implementation
elements that will be covered in this chapter are as follows:

= Extent of planning
eadership ~
P2 goal setting —
Focus on results
“Information and analysis
Process management
Employee participation

Focus on interested parties
Guiding principles or core values
P2 program elements

.
.
.
.

Each of these elements should be addressed in the P2 program.

EXTENT OF PLANNING

The three approaches run the full gamut of planning. You will need
to determine the effort your organization wants to devote to planning as
you seek to implement or improve the P2 program.

Finding Your.O'

Way to implement P2

Includes:

Introduction

Extent of Planning
Leadership

Setting P2 Goals
Focus on Results
Information and Analysis
Process Management
Employee Participation
Focus on Interested
Parties

Guiding Principles

P2 Program Elements
Now It’s Your Turn

oOO ooonoo0oo0o00g

All three approaches can be
improved by using the pro-
cess characterization, prob-
lem-solving, and decision-
making tools that are de-
scribed in Chapter 4.

This chapter will discuss some
of the items that are covered
in these approaches to pro-
vide you with some ideas for
planning and implementing a
P2 program that is specific to
your organization’s require-
ments and culture.

You will need to determine the
effort your organization wants
to devote to planning as you
seek to implement or improve
the P2 program.



Information analysis. \nformation analysis is the fuel of the P2 pro-
gram. Paying attention to this criterion is the only way that clear results
can be determined. The following three questions should be asked:

Information analysis is the fuel
of the P2 program.

decisions?

. This last question implies an important link to the strategic planning
and leadership criteria. An organization that performs well makes sure
that valuable information finds its way into the strategic planning pro-

cess and is not used solely in the environmental program.
Results measure the out-

Results. This is the criterion with the greatest number of points inthe comes of all the performance
quality model. Results measure the outcomes of all the performance changes and move the P2
changes and move the P2 program beyond anecdotal information and —_ program beyond anecdotal
success stories to something that will link to all the other criteria. Re- information and success
member that performance (i.e., the first six criteria) drive results. The stories to something that will
two important considerations that need to be addressed in this criterion _fink to all the other criteria.
are as follows:

hat are your organization's planned vs. ‘actual ‘Tesults re |

“lated to your P2 program approach? :

=*~ What are the levels and trends as they relate to impacts on
environment, other interested parties, and financial indica-
tors?

The “how” is still involved in this criterion as you need to consider
the following issues:

How do you plan to measure them?
...*,..How.do you use the results to drive the other ‘criteria?

* How do you trend your results for continual improvement?

* How do you trend the results of other similar organizations to
benchmark your P2 program progress?

Using the Criteria

The Green Zia program makes it clear that all the criteria are linked
and interrelated with the other criteria. Whenever you address one of
the criteria, you need to ask how you need to leverage this by recogniz-
ing how it interacts with another criterion. The information that can be
found on the CD-ROM will show many important connections between
these criteria.

Quality

107



CHARACTERIZE DOCUMENT PAST
P2 PRI
PLAN ‘OGRAM PROCESSES SUCCESSES mad
4A 12 13
Planning for Continual Environmental Process Maps of Main Process Prepare a Listing
Improvement Process Maps of Supporting Processes
Interested Party Focus Establish Information Templates
Leadership Process Management
Employee Involvement Information Analysis
Integrate with Guiding Principles
PREPARE DRAFT
P2 PLAN
14

Draft Plan Without Action Plans

Figure 7-2. Planning and Developing a Pollution Prevention Program.

Information analysis deter-
mines how the organization
selects, collects, and uses
information to assess the
effectiveness of the program
and make decisions on the
basis of this information.

Finally, after all this effort, it is
time to prepare a formal P2
plan in draft form for review
both internally and by the
interested parties. Once the
P2 action plans are prepared,
the P2 plan can be finalized
and distributed.

116

You will note that six of the seven criteria and the eleven guiding
principles of the quality model are incorporated into the P2 program in
the first two steps. This integration should help strengthen the P2 pro-
gram and integrate it into the organization’s key business operations.

The third step (Figure 7-2, work step 1.3) addresses the desirabil-
ity of documenting previous P2 activities. Even at the start of a P2
program, it is important to document what has been done before. The
third work step examines all P2 activities that can be documented with
a time frame of two to five years. Employees and management alike
will be justifiably proud of these accomplishments and can build on
them in this newly constituted P2 program.

Finally, after all this effort, it is time to prepare a formal P2 plan in
draft form for review both internally and by the interested parties. Once
the P2 action plans are prepared, the P2 plan can be finalized and
distributed.

Step 2. Develop Your Organization’s P2 Opportunities

The hierarchical process maps prepared in the previous step are
now used to gather information on the production units. You are now
ready to develop the P2 opportunities (Figure 7-3).

In the information and analysis step (Figure 7-3, work step 2.1),
every use of a toxic material represents an opportunity to eliminate that
use. Every loss of a toxic material or the generation of hazardous waste

Chapter 7



SUPPLEMENTAL READING

“How do you measure environmental performance?” Pojasek, R.B.
Environmental Quality Management, 10(4), 2001.

“New Mexico's Green Zia Environmental Excellence Program: Using
a Quality Model for a Statewide P2 Program,” 1999,
Gallagher, P., Kowalski, J., Pojasek, R. B., and Weinrach, J.
Pollution Prevention Review, 9(1):.1—14.

Green Zia Environmental Excellence Program: 2001 Program
Information and Application Guidance, New Mexico
Department of Environment, Santa Fe, NM, 2001.

WEB SITES
Systems Approach Tools:
http:/ ojasek-As jates.com

Information on the Baldrige Quality Award Program:
http:/ uality.nist.

New Mexico Green Zia Program Information:

hittp://www.nmenv.state.nm.us/ (See Special Projects)

Using a Quality Model to Implement P2 4



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tools (see Tools)
traditional P2 program, 15
P2 (pollution prevention) assessment, 41-42
hierarchical process maps, 41-42
periodic updates, 42, 45, 64, 132-133
process characterization, 41
P2 Resource Exchange (P2Rx), 11
Pareto analysis, 57-58, 70, 115
Pareto chart, 16, 58
Pareto Principle, 57
Partnership development, 39, 110-111, 132
Planning
action (see Action plans)
EMS program, 85-91, 122
for P2 implementation, 121-124
program, 31-47, 107
Quality model, 122-123
strategic, 103
traditional P2 program, 70, 71-72, 122
Pollution Prevention Act, 21
Pollution Prevention Code of Management Practices, 44
Prevention of pollution, 24, 84
Preventive/predictive maintenance, 25
Preventive procedures, 96, 98
Prioritization tools, 62-63
Problem solving, 17
Process changes and operational control in EMS, 92
Process characterization, 41-42, 51-52, 74
Process loss, 23, 53
Process management, 114, 128-129
EMS program, 128
quality-based program, 128
traditional P2 approach, 128
Process mapping, 9, 16, 51-56, 74
computerized, 53
EMS programs, 80, 81
hierarchical process maps, 41-42, 52-55, 114, 115
maps as templates, 52-53
resource tracking, 53, 55-56
traditional P2 program, 15, 69, 70, 71, 72, 73
Process safety management (PSM), 97
Product durability, 22
Production concerns, 14
Production models, biologically-inspired, 10
Production quality issues, 14
Production unit analysis, 115-116
Productivity, 12



process mapping, 51-56
root cause analysis, 59-60
selecting an alternative for implementation, 62-64
using P2 tools, 49, 66
Top-down approach, 2, 26, 70
Top management
management representative in EMS, 85, 99
support by, 40-41, 46, 82,.132-133 .
Total Quality Management (TQM), 25
Toxic emissions, 22
Toxic materials, substitutes for, 93
TQM (Total Quality Management), 25
Trade associations, 39
Traditional P2 program, 4-5, 69-77
combining with Systems Approach, 74-75
communication, 74
establishing P2 program, 70
maintaining the P2 program, 73-74
educational training, 73
integration into other P2 initiatives, 73
other implementation approaches, 76-77
planning, 70, 71-72, 123
process maps, 15, 69, 70, 71, 72, 73
program implementation, 71-73
top-down focus, 70
very small organizations, 75~76, 87
writing P2 program plan, 71
Traditional program, process management, 128
Training
EMS, 89, 99
environmental awareness, 89 ©

U

Union Carbide mission statement, 33-34

U.S. Air Force Compliance Through Pollution Prevention, 12
USPS vision statement, 33

Vv

Valid product costs, 43

Valuing employees, 37, 108-109, 131-132
Very small organizations, 75-76, 87
Vision statements, 31, 32-33

VOC (volatile organic chemical), 14
Volume of waste vs. cost, 58-59

Ww
War on waste, 25
Washington State, 83

EEE ED EE  _ E_ I I IEE Oe ee wee Vw Ve Ve Ve Vee Ve VV VV VeVe Vee eee Ve Vee eo



EPA/625/R-01/003
August 2001

An Organizational Guide to Pollution Prevention

U.S. Environmental Protection Agency
Office of Research and Development ~
National Risk Management Research Laboratory
Center for Environmental Research Information
Cincinnati, Ohio

80% Recycled/Recyclable
ae Printed with vegetable-based ink on

er that contains a minimum of
post-consumer fiber content
Processed chlorine free

v=——wrvwrvweeNweeweVeVweVerNwrVe Ve Ve Vee Vee VV VV VV VV VV VV VV Ve VV Ve VV ewe Vee VV Ve VewV Ve eV lw!



Core values, 35-40
corporate responsibility and citizenship, 39, 111 .
fast response, 39-40, 109
goal of continual improvement, 37, 107-108
interested party-driven P2, 36, 107, 131
leadership, 36-37, 107
long-range outlook, 38
management by fact, 39-40
partnership development, 39, 110-111, 132
quality and prevention, 38
valuing employees, 37, 108-109, 131-132
See also guiding principles
Corporate citizenship and responsibility, 39, 111, 125
Corrective actions, 96, 98
Cost and benefit analysis, 42
Cost of the loss, 56-57 -
general ledger costs, 56
lost resources, 56-57
management of non-product loss, 57
Costs
compliance, 12
cost allocation systems, 42-43
determining cost of the loss, 56-57
future liability, 12
information updating, 42
operating, 11
savings with EMS programs, 88
tracking with Systems Approach, 53, 56
true, 42, 43
valid product, 43
Cost vs. volume/weight of waste, 58—59
Criteria matrix (selection grid), 17, 62
Customers, 14, 39

D

Decision-making, 17

Design, 109

Design for Environment (DfE), 11, 19, 38, 97
Documentation, 91, 99, 114

Dupont mission statement, 34

Dupont vision statement, 32

E

Eco-efficiency, 22-23

Education, 44, 73, 74
employee, 73, 89-90
public, 29, 44, 74



REFERENCES

6-1. Federal Register Web Site
http:// .epa.gov/fedrgstr/EPA-GENERAL/1998/March/Day-

12/g6389.htm

6-2. Integrated Environmental Management Systems
Implementation Guide, EPA 744-R-00-011. US Environmental
Protection Agency, Office of Pollution Prevention and Toxics,
October 2000

6-3. Multi-State Working Group Web Site
http:/Awww.mswg.org

6-4. Environmental Management Systems: An Implementation
Guide for Small and Medium-Sized Organizations. NSF
International, Ann Arbor, MI, November 1996

http:/Awww.kppc.org/EMS/emspubs.cfm

6-5. _ EPA’s Environmental Performance Track Web Site
htto://www.epa.gov/performancetrack

6-6. _ ANSI-RAB information on registration, registrars, training and
consulting
/www.ansi. ublic/iso 10

6-7. EPA’s Environmentally Preferable Purchasing (EPP) Web Site
http:// .epa.govi intr/epp/index.htm

6-8. Minnesota Office of Environmental Assistance (MOEA) EPP
Web Site
http:/Avww.moes ite. mn.us/| rchasing/

6-9. A Catalogue of the Agency’s Partnership Programs, EPA
4100-B-97-003, U.S. Environmental Protection Agency, Office
of the Administrator, Spring 1998

SUPPLEMENTAL READING

Environmental Management System Demonstration Project. NSF
International, Ann Arbor, MI, December 1996

http://www.kppc.org/EMS/emspubs.cfm

Environmental Management System Primer for Federal Facilities,
DOE/EH-0573. U.S. Department of Energy and U.S.
Environmental Protection Agency, Washington, D.C., 1996
http:/ c.org/E} spubs..cfr

The ISO 14001 Implementation Guide: Creating an Integrated
Management System. Susan L. Jackson, John Wiley &
Sons, Inc., 1997

ISO 14000 Case Studies: Models for Implementation, Mark B. Baker
(Editor), CEEM Information Services, 1996



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To be truly successful, P2
requires a systematic, inte-
grated, consistent, organiza-
tion-wide approach. This
approach can be achieved
through comprehensive P2

planning.

P2 often requires the develop-
ment of awareness to accom-
plish the improvement effort.

Although you can learn from
others’ P2 success stories,
real P2 success comes from
the persistent application of the
P2 philosophy and core values
in each organization's specific
environment.

Past Operating and was sie Managemen practices anid for

es)
7S

tive or inactive fac Sty owners aah
taking into accoun munity concerns an
safety, and environmental impacts.”

LESSONS LEARNED

The creation and maintenance of a P2 Program necessitates an
overall plan. P2 does not just happen. To be truly successful, P2 re-
quires a systematic, integrated, consistent, organization-wide approach.
This approach can be achieved through comprehensive P2 planning.
Aclear and understandable vision that can be made real by the organi-
zation is of primary importance for success in the program. Without a
mission, the organization can have difficulty moving toward success.
Everyone in the organization must see how he or she can contribute to
P2 success. Top leadership must begin to understand the P2 philoso-
phy and the application of the core values. Many times P2 starts with
the individual efforts of a “champion.” It may catch on with a particular
process area or product group. To have it take hold organizationally, a
P2 planning effort is required.

P2 often requires the development of awareness to accomplish
the improvement effort. The building of awareness can come from train-
ing. Such training can be accomplished in a formal setting or on the
job. Some larger organizations have trained facilitators on staff who
work with the members of a team, managers as well as workers, as
they address each specific improvement effort. Smaller companies
rely on the use of P2 technical assistance providers to facilitate these
efforts with on the job training assistance and other guidance. No mat-
ter how it is accomplished, the training, either formal or informal, must
be effective and timely, and pursued continuously.

Within an organization, informal groups have their own leaders and
“rules” that determine, for example, the pace of work or the relationship
with the top management. If the informal organization and its leaders

- accept a proposed change, events will proceed more smoothly; if they

oppose it, change may be nearly impossible. Identify these informal
group leaders. Get to know them and spend time listening to their opin-
ions and perspective. When you understand their needs and concerns,
you will better understand how the P2 changes you seek can be imple-
mented more effectively.

Although you can learn from others’ P2 success stories, real P2
success comes from the persistent application of the P2 philosophy
and core values in each organization’s specific environment. Success
is measured differently in each organization. It cannot be achieved by
simply copying others.

Chapter 3]

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sponsible for tracking, analyzing, compiling, and
sxes reporting data? — : ;

=~=-.-.What is the frequency of measurement for data?

r= @ _ How will data be analyzed/compiled?

=. ® How will data be reported?

ees

Although the organization may be monitoring data on a hourly or
daily basis for compliance purposes, the data will be used more strate-
gically for the EMS. Monitoring will be used to detect overall trends and
the possible need for corrective and preventive action. In this way, the
organization may identify gradually declining performance and will be
able to reverse it before a nonconformance, noncompliance, or other
incident occurs.

Many companies are already evaluating their compliance in at least
one of two ways: through compliance audits or through monitoring of
regulatory permits. An environmental compliance audit compares an
organization's performance with a set of environmental requirements
relying largely on following a paper trail of permits, sampling data, and
reports. Auditing the EMS’s actual performance is different because it
focuses on employees from various levels and job functions within the
organization and their actions. A compliance audit compares an
organization’s performance to environmental requirements while an
EMS audit focuses on employees and their actions.

There are two types of environmental solutions: short term to fix
the immediate problem and long term to prevent the problem from re-
curring. The focus of the EMS and P2 is on the long-term solutions that
eliminate or reduce the organization’s environmental aspects and im-
pacts. The first step to implementing a long-term solution is to develop
plans that assign responsibility, determine progress dates, and desig-
nate needed resources to complete the corrective actions. If at some
point the initial solution does not work, it may mean the true root cause
was not correctly identified. At this point, generate new solutions and
record the reason for the change.

Management Review and Continual Improvement

An EMS encourages a systematic approach to improving environ-
mental procedures and performance through continual improvement.
Top management periodically reviews EMS implementation and effec-
tiveness (Figure 6-6, work step 5.2). Experience has shown that the
effectiveness of management directly affects the chances of a suc-
cessful EMS. EMSs are business systems that allow organizations to
manage their environmental issues in a systematic, organized fashion
based on continual improvement—just like any other area of business
such as quality, purchasing and inventory control, accounting and
payroll, and cash flow. Like these other areas, EMSs focus on top man-
agement support and commitment, accountability, employee involve-
ment, responsibility and training, documentation, operational controls,

EMS Approach to P2 Implementation

A compliance audit compares

an organization’s performance

to environmental requirements
while an EMS audit focuses on
employees and their actions.

The focus of the EMS and P2
is on the long-term solutions
that eliminate or reduce the
organization’s environmental
aspects and impacts.

An EMS encourages a sys-
tematic approach to improving
environmental procedures and
performance through continual
improvement.



RYT Trill



LOOK FOR P2 SELECT P2 CONDUCT P2
OPPORTUNITIES |____y} OPPORTUNITIES |____p} PROBLEMSOLVING }____y
1 2 3
CONDUCT P2 MANAGE P2
———] DECISION-MAKING |____p| PROGRAM
4 5

Figure 1-2. An Alternative Approach to a P2 Program.

e Process mapping

e Main process/supporting
processes

« Maps as information tem-
plates

The process maps become
templates for maintaining
information about the process.

e Rank ordering

e 80/20 rule

e Pareto chart

e Monetary metrics

Every process in every
organization will produce P2
opportunities.

While these steps will be discussed in more detail in Chapter 4 of this
Guide, it is important to highlight some of the differences between the
methods described here and the methods contained in the traditional
approach to P2.

All of the organization’s processes are characterized in detail us-
ing a tool known as process mapping. This tool allows the information
to be aggregated to a higher level when necessary. All supporting op-
erations (ancillary and intermittent) are examined and linked to the main
processes. Nothing is missed using this visual tool. All resources (e.g.,
energy, water, and materials) are accounted for at the work-step level
(ie., at the lowest level in the process maps as they define the actual
work task that is being performed). The process maps become tem-
plates for maintaining information about the process. The costs of us-
ing and losing resources can also be collected by work-step using the
process maps as templates. Traditional P2 methods have relied on a
walk-through process assessment to gather information on P2 oppor-
tunities.

Every use of a resource in a process represents an opportunity to
conserve the use of that resource. Every loss of a resource in a pro-
cess represents an opportunity not to lose that resource. Every pro-
cess in every organization will produce P2 opportunities. It is possible
to rank P2 opportunities using monetary units and also to construct a
Pareto chart. This chart will show that 20% of the P2 opportunities
represent 80% of the true costs of environmental management of the
uses and losses. No matter how the P2 opportunities are selected, itis
important to have the organization keep its collective eye on the most
important ones. Many organizations select a manageable number of
P2 opportunities to work on each year. Ideally, P2 opportunities should
be selected from every department in the organization to ensure that
everyone stays involved.

Chapter 1

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OO EE eee el eee ere eV VV VV VS VV VV VEVeVVeVeVVVVeEVVeVVeVeVVeVeVeV ST eo

ated with accidents or emergencies. An EMS provides for the testing
of emergency procedures when it is practicable.

EMS training programs ensure that all employees, suppliers, and
contractors whose job roles may impact objectives, targets, and com-
pliance are trained and capable of carrying out their responsibilities.
The organization should evaluate competency for employees whose
work may create significant environmental impacts. The organization
must date and retain training records, training materials, and documents
demonstrating evaluation of employee awareness and competency.

EMS documentation describes how all of the system elements will
be integrated into the organization's overall decision-making and busi-
ness planning process and provide direction to all relevant environmental
procedures. An EMS document control system includes procedures
for maintaining and protecting documents and other records as objec-
tive evidence of compliance and effectiveness. The EMS specifies re-
tention times for environmental records in accordance with relevant
laws.

Management must appoint a representative to ensure implemen-
tation and review of the EMS. The EMS requires periodic and objective
auditing and review of the organization’s environmental system effec-
tiveness and compliance. Without top management review, visible
involvement, and support, the EMS will not generate significant envi-
ronmental improvement or better results over the current management
system. This is the most important element of the EMS because man-
agement becomes a source of direction and oversees development of
action items for sustainable improvement and long-term value creation.
Management review promotes organizational leadership by demon-
strating a commitment to environmental responsibility. The scope and
frequency of the review will depend on the size and complexity of the
organization’s environmental impacts.

Organizations are discovering that their investments in EMSs are
leading to improved environmental performance and compliance with
benefits for the environment and community. An EMS provides a good
method for establishing and implementing a P2 program. To achieve

maximum environmental benefits, the EMS should embody the “plan, °

do, check, and act” model for continual improvement. This model
ensures that environmental impacts are systematically identified, con-
trolled, and monitored. The EMS helps ensure more consistency by
organizations in achieving and maintaining compliance, promoting
results-oriented efforts, and attaining more reliable data on environ-
mental performance. Effective use of an EMS can be viewed as a
demonstration of environmental responsibility and leadership by orga-
nizations. An EMS provides the basis for collaborating with regulatory
agencies to enhance suitability and effectiveness and promote a lead-
ership, performance-based system.

EMS Approach to P2 Impleme:

An EMS document control
system includes procedures
for maintaining and protecting
documents and other records
as objective evidence of
compliance and effectiveness.

Management review promotes
organizational leadership by
demonstrating a commitment to
environmental responsibility.

An EMS provides a good
method for establishing and
implementing a P2 program.
To achieve maximum environ-
mental benefits, the EMS
should embody the “plan, do,
check, and act” model for
continual improvement.

99



United States . Pe : ‘
Environmental Protectiot-Agency/ORD
National Risk Management Tema?
Research Laboratory * TBAR
Cincinnati, OH 45268.

x
Official Business ‘S
Penalty for Private Usé “PS
$300 4 :

EPA/625/R-01/003


Change management is a
fundamental and critical
element of P2 program imple-
mentation.

Empowering teams to fully
implement the new P2 behav-
iors is central to successful
change management.

The business case needs to
be made for all P2 projects.

Instituting a P2 program can
facilitate change in an organi-
zation.

Everyone in the organization
must change to make P2
work,

The very reasons that organi-
zations are trying to become
“lean” are the same reasons
that P2 should be an integral
part of that program.

28

Change occurs because people as a group accept it. Approach
such change deliberately. Involve the organization’s members and lis-
ten to them. Be responsive to their needs and ideas. When change
represents a new work style for people, allow time to adjust to it and
experiment with it. An idea approached as a pilot project may be ac-
cepted more readily than one imposed as a permanent change. You
can combat resistance by surrounding the organization’s members
with a network of familiar activities, support, and guidance. Encourage
them to feel anchored to the direction and mainstream activities of the
organization.

Change management is a fundamental and critical element of P2
program implementation. Failure to develop bureaucracy-elimination
initiatives, communication improvement, and training programs sends
mixed signals to the employees. Empowering teams to fully implement
the new P2 behaviors is central to successful change management.

Many P2 consultants and P2 technical assistance providers have
tried to sell P2 as an environmental program. Your organization will
probably find greater success by linking P2 to its strategic needs. Ad-
dress the true scope and impact of P2 as part of managing your busi-
ness needs. To increase your effectiveness, integrate the P2 program
into the organization’s core business practices. The business case
needs to be made for all P2 projects. Success needs to be measured
economically, as well as in volume and weight.

DEALING WITH CHANGE

Instituting a P2 program can facilitate change in an organization.
Technical savvy and operational knowledge are not sufficient by them-
selves. Everyone in the organization must change to make P2 work.
This will not be easy. There are seven things you should consider when
you start a P2 program in your organization:

2 is might be ac:
as part o ‘a “War on wasi aa or related to issues

reasons thal

je
4 Wiowiig ore 7 rioney ‘to

the bottom Tine is ‘important | in a private orga ation

pr
taining the same mission with fewer funds is a common
. cause for many not-for-profit and government organizations:
Many times money has something to do with the need for
change. This should make P2 very attractive.

Chapter 2



Interested-party—driven P2. P2 is judged by interested parties (i.e.,
customers, employees, suppliers, regulators, stockholders, the public,
and the community). Thus, P2 must take into account all product and
service features and characteristics that contribute value to these in-
terested parties and lead to their satisfaction, preference, and contin-
ued interest in your organization.

Interested-party—driven P2 is thus a strategic concept. It is directed
toward organizational customer retention, market share gain, growth,
and maintenance of all relationships with time. It demands constant
sensitivity to changing and emerging interested-party and market re-
quirements and the factors that drive interested-party satisfaction and
attention. Interested-party—driven P2 also demands awareness of de-
velopments in technology and of competitor's offerings and rapid and
flexible response to interested-party arid market requirements.

Interested-party—driven P2 means much more than waste dis-
charge and emission reduction, merely meeting regulatory requirements
and specifications, or reducing complaints. Nevertheless, waste re-
duction and elimination of causes of dissatisfaction contribute to the
interested party's view of P2 and are thus also important parts of inter-
ested-party—driven P2. In addition, the organization’s success in re-
covering from EHS problems and waste management issues (“mak-
ing things right for the interested party”) is crucial to building interested-
party relationships and to customer retention.

Leadership. An organization's senior leaders are the right team to set
directions and create an interested-party orientation, clear and visible
P2 values, and high expectations. These directions, P2 values, and
expectations should address all interested parties. The leaders can
ensure the creation of strategies, systems, and methods for achieving
environmental excellence, stimulating innovation, and building knowl-
edge and capabilities. The strategies and P2 values will help guide all
P2 activities and decisions of the organization. The senior leaders who
are committed to the development of the entire workforce will encour-
age participation, learning, innovation, and creativity by all employees.

Through their behavior and personal roles in P2 planning, commu-
nications, review of P2 performance, and employee recognition, the
senior leaders serve as role models, reinforcing P2 values and expec-
tations and building leadership and initiative throughout the organiza-
tion.

Continual improvement and learning. Achieving the highest levels
of P2 performance requires a well-executed approach to continual im-
provement and learning. The term continual improvementrefers to both
incremental and “breakthrough” improvement. The term learning re-
fers to adaptation to change, leading to new goals and/or P2 ap-
proaches. Improvement and learning need to be “embedded” in the

sing a Quality Model to Impler

P2 must take into account all
product and service features
and characteristics that
contribute value to these
interested parties and lead to
their satisfaction, preference,
and continued interest in your
organization.

An organization's senior
leaders are the right team to
set directions and create an
interested-party orientation,
clear and visible P2 values,
and high expectations.

The term continual improve-
ment refers to both incremen-
tal and “breakthrough” im-
provement.

The term learning refers to
adaptation to change, leading
to new goals and/or P2 ap-
proaches.



For the program to be results-
driven, there will have to be an
organized means for managing
information and analysis in
your P2 program.

130

In Box 8-3, there are some questions that may help determine how
information is collected and analyzed in the P2 program.

a ‘ ie
y and environmental losses?
id saiet requirements?

product, service, or produ ion process
List=3 eericoumene Impacts of: ol a product, service, or produc-

ess thi

“Track your competitors’ *
~ design? :
-* Analyze information to prioritize areas for improvement?

+» Use information and results to identify organization-wide areas for im-
provement (e.g., P2 opportunities)?

Use comparative information to assess and improve its environmental
performance (i.e., benchmarking)?

+ Evaluate competitors and market trends in the formulation of its envi-
ronmental strategies?

green” trends and use this data in product

ram

For the program to be results-driven, there will have to be an orga-
nized means for managing information and analysis in your P2 pro-
gram. The tools in Chapter 4 provide some order to the program and a
good starting point. By selecting more items from the questions, you
can drive continual improvement.

PROCESS MANAGEMENT

The traditional approach is project-based and does not place a
great deal of emphasis on process. Assessments are used to locate
opportunities for P2 and a project is set forth to minimize or prevent
waste at that location. These assessments may not find other points at
which the P2 opportunities can be leveraged. Furthermore, the assess-
ments may not involve the institutionalization of P2 by changing the
process of environmental management.

On the other hand, the EMS- and quality-based approaches em-
phasize process; both ask the type of questions that can be found in
Box 8-4. A strong EMS is a vital component of the quality-based P2
approach and will help the organization attain a maximum number of
points in this criterion.

Process mapping and resource accounting as described in Chap-
ter 4 help measure and report the results of reducing your environmen-
tal impacts. The organization will benefit by addressing the issue of



An effective means to charac-
terize processes is with a
hierarchical process map.

Ithas been widely recognized
that most people can only
“see” up to six objects at a
time and comprehend visually
what they mean. Hierarchical
process maps allow only three
to six objects on a page.

The assemblage process
steps constitutes a node tree
which establishes the relation-
ship and connections between
the work steps at each level.

In a Systems Approach, every
work step is connected to
every other work step in this
diagram, which depicts the
entire system.

for resource use and waste generation. Every use of a resource in a
process represents an opportunity to conserve the use of that resource.
Every loss of a resource in a process represents an opportunity to
avoid that loss. Taking advantage of these opportunities benefits every-
one in the organization. The discovery, correction, and prevention of
waste generation should be the responsibility of everyone in the organi-
zation.

An effective means to characterize processes is with a hierarchi-
cal process map (Figure 4-1). In most organizations, process docu-
mentation is typically organized into categories such as company,
facility, product line, and department. Much process documentation is
then carefully filed away in reports or databases that most people do
not review on a regular basis. This information may take the form of
process flow diagrams, flow charts, value stream maps, process and
instrumentation diagrams, machine configurations, arrow diagrams,
box diagrams, floor plans, or other schematic depictions. All of these
process characterizations suffer from complexity—too many objects
on a single page.

It has been widely recognized that most people can only “see” up
to six objects at a time and comprehend visually what they mean. Hier-
archical process maps (Reference 4-2) allow only three to six objects
on a page. The entire process must be depicted in three to six boxes.
Sub-processes can be used to provide detail at the next level but are
also restricted to the three-to-six-box rule. The assemblage process
steps constitutes a node tree which establishes the relationship and
connections between the work steps at each level. In a Systems Ap-
proach, every work step is connected to every other work step in this
diagram, which depicts the entire system. There are two very impor-
tant rules associated with process mappin

interested parties.

Figure 4-2 shows examples of process maps. You can find other
examples of process maps on the CD-ROM accompanying this Guide.

Using Maps as a Template

Some organizations think of a process as a single box with its
inputs and outputs. Using this model, it is difficult to change an entire
process to make P2 happen. By using the process map as a template,
process documentation can be organized by, and linked to, individual
work steps in the process at the lowest level. All standard operating
procedures (SOPs), best management practices (BMPs), regulations,

Chapter 4

OOS OOOHOOOGHOSOHOHHHEHEHOHSHOHHHHOHHOHOEHH8EHHHOH088CS



Employees are a very impor-
tant part of the P2 program.

Process management con-
cerns itself with how you
manage all work processes in
such a way that P2 behavior is
facilitated.

106

large. The questions that need to be considered for this criterion in-
clude the following:

programs?

The employees represent a special stakeholder position that has its
own criterion.

Employee involvement. This criterion looks at the bottom-up portion
of the P2 program, which is every bit as important as the top-down
portion covered in the leadership category. Employees are a very im-
portant part of the P2 program, so it is important not to rely exclusively
on outside experts and technical assistance to find P2 alternatives.
Who knows the inner workings of an organization better than the em-
ployees? Questions that need tobe addressed are the following:

‘your organiza ion prepare
lopment and"in the implementation” fe) the Po
approaches? ~

How are the employees’ value and well-being considered in
“the P2 program?

Both the other interested-party and employee involvement criteria
deal with the involvement of people in your P2 program. Now, you should
turn to the process. In the past, this may have been the sole focus of
the P2 program.

Process management. This is the criterion that ISO 14001 or other
EMSs can help an organization with its score. Process management
concerns itself with how you manage all work processes in such a
way that P2 behavior is facilitated. It is important to realize that the
process management criterion includes both “things people do” and
other organization work processes (e.g., manufacturing). The impor-
tant questions to ask here are as follows:

ganization identify
nee nen

ig Wo! processes tl 38 that impact the
es your organization analyze t
understand their impacts a
low does your “organizatio
gain P2 program excellence?

1age all work processes to

This criterion is closely related to the information-analysis criterion.



The traditional approach has a
“top-down” focus.

The traditional approach views
the preliminary assessment as
a “walk-through” activity to be
performed by a team of em-
ployees or by an outside
service provider or process
expert.

The Systems Approach
described in Chapter 4 of this
Guide allows for some “bot-
tom-up” efforts before the
endorsement of senior man-
agement.

These ideas show how you can
organize this part of the P2
program using the tools pre-
sented in this Guide.

70

ESTABLISH P2 ORGANIZE P2 CONDUC
PROGRAM PROGRAM PRELIMINARY P2
ASSESSMENT
11 1.2 13

Figure 5-2. Establishing a P2 Program.

Let’s look at the details in each of these steps to see how the infor-
mation in this Guide can ease the implementation using the traditional
approach to P2.

ESTABLISHING A P2 PROGRAM

The traditional approach has a “top-down” focus. This approach,
as presented in the earlier EPA publications (Figure 5-2), begins with
getting management approval and setting program goals before P2
information is collected. The first step is to obtain an executive-level
decision to establish the P2 program. This decision is communicated
to the workforce using a policy statement. Consensus-building efforts
will promote acceptance of this policy statement.

To organize the P2 program, management names a P2 task force
and states goals before any formal information is gathered. Goals that
are established upfront for a P2 program challenge the effort.

Under the traditional approach, the task force next conducts a prelimi-
nary P2 assessment to collect some P2 data, reviews sites for future P2
studies, and establishes the priorities for the P2 program. A preliminary
assessment is necessary to gather information for the written P2 plan
(Figure 5-2, work step 1.3). Some organizations may consider conduct-
ing this preliminary assessment prior to work steps 1.1 and 1.2 (see Fig-
ure 5-2). The traditional approach views the preliminary assessment as a
“walk-through” activity to be performed by a team of employees or by an
outside service provider or process expert.

The Systems Approach described in Chapter 4 of this Guide al-
lows for some “bottom-up” efforts before the endorsement of senior
management. Using the process-mapping tool described in Chapter 4
of this Guide gives the team a more complete understanding of the
processes (including the ancillary and intermittent processes). This
leads to a more complete listing of opportunities for P2. Pareto analy-
sis can be used to rank order the opportunities for P2. The organiza-
tional management can then propose goals based on a more com-
plete assessment of the P2 opportunities and establish clear priorities
for the program. Goals could be stated in the action plans for each year
instead of as program goals. These ideas show how you can organize
this part of the P2 program using the tools presented in this Guide.

lapter 5

© OS OOO OOOOH O OOOOH HHOHHOHOHEHHOHOHHHHHHHOOHOHOOOOCHOOESO



Cleaner production is the
continuous application of
an integrated preventative
environmental strategy ap-

plied to processes, products,

and services.

The international community has adopted the term cleaner pro-
duction. As you can see from the definition of cleaner production in Box
2-2, it has a broader meaning than the one we give to the term P2. The
final term eco-efficiency is used extensively in the sustainable devel-
opment arena and is defined in Box 2-3.

ies the more efficient use of natural resources and thereby
Tisks fo jumain health and safety.
the end of the pro- * i

‘throughout its life-cycle, from the extraction of the raw materials through to”
f Fthe product's ultimate disposal.

=~" For services, the strategy focuses on incorporating environmental con-
cerns into designing and delivering services.

United Nations Environment Program (Reference 2-2)

tio meet human needs. the ratio secre ects
fproducts and services produc i@ economy asa *
[e—to ff
ifm, sector, or economy. Measuring co-e
indicators of both input and output

é ‘WWerld Busine ss Council for Sustainable Development (
lerence, — ) considers that eco-efficiency places e demands

i if '
Re du ing material intensity of goods and services

1
2. Reducing energy intensity of goods and services

3. Reducing toxic emissions

4. Enhancing material recyclability

5, Maximizing sustainable use of renewable resources
6. Extending product durability

7. Increasing the service intensity of goods and services



A multimedia EMS approach
will ensure all significant
aspects are identified that
impact the environment and
are costly for the organization.

The organization benefits by
involving suppliers and con-
tractors in the EMS proce-
dures and requirements for
certain significant environmen-
tal aspects they could impact.

The EMS's objectives and
targets are the most important
place for articulating P2 plan-
ning goals.

and compliance with various environmental regulations. This leads to
asingle media dependence on reactive and end-of-pipe strategies that
are potentially inefficient and costly. Many organizations that have insti-
tuted a thorough EMS have benefited by becoming aware of inefficien-
cies that were not apparent previously. Correcting these inefficiencies
generates cost savings and reduced environmental liabilities. A multi-
media EMS approach will ensure all significant aspects are identified
that impact the environment and are costly for the organization.

The organization benefits by involving suppliers and contractors in
the EMS procedures and requirements for certain significant environ-
mental aspects they could impact. Identification of health and environ-
mental concerns associated with the raw materials used by an organi-
zation is important in assessing the significance of environmental as-
pects associated with that materials’ use. It may be necessary to pro-
vide training and guidance to outside organizations whose actions onsite
may create an aspect or impact the organization’s environment. This
provides a forum for the two organizations to investigate goods and
services for P2 opportunities. From improving efficiencies to changing
basic processes, design has played an important role in reducing waste.
Good supplier partnerships can result in designing for P2 and meeting

the objectives and targets established for the EMS.

An organization may choose to modify an existing assessment
tool or develop a procedure for identifying all the organization’s environ-
mental aspects and their significance. Use a team approach during
this planning phase and keep the aspects’ list updated. Prioritize the
significant aspects to begin addressing opportunities to improve the
organization's impact on the environment. Finally, remember to look
beyond regulatory requirements and your organization's boundary when
considering your organization's aspects and invite input from all inter-
ested parties.

EMS Objectives and Targets

The EMS sets explicit goals by establishing and maintaining objec-
tives and targets for improvement (Figure 6-4, work step 3.3). The EMS’s
objectives and targets are the most important place for articulating P2
planning goals. Although an organization has discretion with regard to
its objectives and targets, they must be consistent with the
organization’s environmental policy containing a commitment to pre-
vention of pollution that helps reinforce source reduction goals and com-
pliance with state P2 planning laws

cA VS
jectives—overal environmenta
io.achieve...

goals that an organization sets

Targets—detailed performance requirements that are set and met
* to achieve the environmental objectives.

i Chapter 6 i

0600 OOOOH OOS HOHHOOOHOHOHH8HHOS OHHH HHOOHOHHHHOHOHOOO



See ee orrerlrlerelseeseesereerelererere ere Vee Se VV VV eV Ve Vee Vee Ve Ve Vee Ve Vee Ve eee Ve Vee Ve eS

There is a substantial body of literature that describes, analyzes, and evaluates P2 efforts in the United
States and internationally. It is clear that, like quality, P2 is a mindset that needs to permeate into the culture
of the organization. Some have said that P2 is a way of life, nota new program. P2 requires many changes
in behavior that cannot be simply demanded. Empowering employee teams to fully implement the new P2
behaviors is central to successful change management.

E.3 P2 Program Elements

P2 program planning should begin with the preparation of a vision statement, a mission statement,
and a statement of goals. If your organization already has formal statements, it is important to align the P2
Program with these statements. These statements and goals will help provide a good foundation for the P2.
plan that your organization develops. Next, it is important to see how the P2 program aligns with the
organization's guiding principles (also known as the core values). These items will help ensure that the
program is understood and compatible with other initiatives in the organization.

The EPA has found that P2 programs often have similar program elements. They have published in
the Federal Register six important elements that would be found in many. programs of this nature. These
elements include the following: . -

rovide top management support
haracterize the process ve eset
‘etform periodic assessments. i
- 4. Maintain a cost allocation system: sen ct ond
a Encourage technology transfer :

*~ 6. Conduct program evaluations

There may be other elements that can be included in the organization's P2 program. One good source
is the American Chemistry Council's Responsible Care® Program's P2 Code. In addition, the organization
must be certain to include the planning requirements that may be specified in its state environmental
regulations. -

To be truly successful, P2 requires a systematic, integrated, consistent, and organization-wide ap-
proach. This approach can be achieved through comprehensive P2 planning. Although you can learn from
others’ P2 success stories, real P2 success comes from the persistent application of the P2 philosophy
and guiding principles in each organization’s specific environment. Success is measured differently in
‘each organization. It cannot be achieved simply by copying others. 7

E.4  P2 Tools

P2 teams can use a variety.of specialized tools. These tools provide visual aids that are essential for
communicating P2 information to management, other workers, and other interested parties. Tools also
help P2 teams gather information and provide problem-solving and decision-making guidance. Finally, by
using the tools, the P2 team is in a better position to construct an action plan for each P2 project included
in the program. This allows for consistent tracking by the P2 oversight committee.

P2 tools are Systems Approach tools. The Systems Approach looks at the whole organization, and the
parts, and the connections among the parts. These tools help point out how things can be changed to conserve
the use of a resource or prevent the waste from occurring. This is fundamentally different from having an
external assistance provider suggesting a way to change the process without considering the system.



WRITING THE P2 PROGRAM PLAN

The traditional approach next addresses writing the P2 program
plan (Figure 5-3). A good planning effort makes careful note of what the
stakeholders want in the program. These are the interested parties or
external groups described in the quality-based implementation model
(see Chapter 7). Stakeholders may include the following: customers,
suppliers, employees, regulators, environmental interest groups, com-
munity organizations, stockholders, and anyone else with a stake in
the outcome of the P2 program.

The P2 plan should state clear objectives for the P2 program. It
should anticipate obstacles to program implementation and plan means
to overcome them. A good planning effort addresses these obstacles
during the preparation of the plan. Finally, the P2 plan requires a firm
schedule. It can be a challenge to set a schedule based solely on the
information gathered to this point, but a schedule is essential for man-
agement to track the plan’s progress during the course of the year.

> WRITE P2 PROGRAM PLAN

Consider External Groups
Define Objectives

Identify Potential Obstacles
Develop Schedule

Figure 5-3. Writing the P2 Program Plan.

Earlier in this Guide (Chapter 4), action plans were described. The
action plan is a tool that can be used to address all the concerns that
can arise when writing a P2 program plan. Each organization should
have an action plan for each P2 project conducted in the P2 program.
The collection of these action plans (many organizations implement 8
to 11 P2 action plans in a typical year) constitutes the major portion of
the P2 plan. The other part of the P2 plan outlines the management
structure within which these plans will be used and reviewed during the
course of the year. The objectives of the program should reflect the
vision and mission statements for the P2 efforts.

P2 PROGRAM IMPLEMENTATION

In the traditional approach the detailed P2 assessments the start-
ing point of the program implementation phase (Figure 5-4). An as-
sessment team is assembled for this task. It is not defined as a worker
team but rather as a higher-level, multidisciplinary team which may

itional Approach to P2 Implei

Stakeholders may include the
following: customers, suppli-
ers, employees, regulators,
environmental interest groups,
community organizations,
stockholders, and anyone else
with a stake in the outcome of
the P2 program.

The P2 plan should state clear
objectives for the P2 program.

A schedule is essential for
management to track the
plan’s progress during the
course of the year.

Each organization should have
an action plan for each P2
project conducted in the P2
program.

In the traditional approach the
detailed P2 assessment is the
starting point of the program
implementation phase.



OTHER (MPLEMENTATION APPROACHES

Chapter 6 will examine how an organization can use the environ-
mental management system (EMS) to help implement a P2 program.
This is an important implementation model since many organizations
are now considering this type of EMS (i.e., ISO 14001, EMAS, etc.).
Chapter 7 will examine how an organization can use a quality-based
program like the Baldrige approach to implement a P2 program. A pre-
vention-based approach is built into the criteria that allow an organiza-
tion to compare itself to organizations which have achieved environ-
mental excellence. An organization that scores well in the rating sys-
tem should have a significant amount of P2 in its operations.

Process maps have been prepared in each of these chapters so
you can compare them to the process maps in this chapter. By using
this tool, you will be able to select the approach that is most effective
for you and compare it to the implementation approaches provided in
this Guide. Chapter 8 will provide some tips on how to mix and match
these implementation approaches.

REFERENCE
5-1. Nothing to Waste Manual
ttp:// menv.ste m.us/ (see Special Projects)

. Traditional Approach to P2 Implementation .



»

»

>

>

>

>

>

>

» CONTENTS

> .

y Executive Summary . . 1
»

> Chapter 1: Introduction 9
> Evolution of Pollution Prevention (P2) : 9
» Benefits of P2 : : "1
> Impediments to P2 Use . 13
> P2 in Steps Lo 15
D. Organization of This Guide 18
> :

> Chapter 2: Getting Started 21
> How to Define P2 ; 21
> “Sustainable Development 23
J Integrating the New P2 Program into Core Business Practices 24
> Who Should Implement P2? 26
> When Will You Begin? 27
> Lessons Learned from Past P2 Programs 27
J Dealing with Change 28
q

J Chapter 3: P2 Program Elements . 31
> P2 Program Planning ~ 31
» Core Values 35
J Selecting Program Elements - 40
> Lessons Learned . 46
»

> Chapter 4: P2 Tools : 49
>. Using P2 Tools . 49
> Systems Approach Tools : 49
> Checklists 65
» Lessons Learned 66
> -

> Chapter 5: Traditional Approach to P2 Implementation 69
y Introduction 69
» Establishing a P2 Program 70
> Writing the P2 Program Plan 71
» P2 Program Implementation 71
> Maintaining the P2 Program 73
> Combining the Traditional Approach with the Systems Approach 74
} Approaches for Very Small Organizations 75
7 Other Implementation Approaches - 77
J

J

J

a Te
, . .
)



into your organization. In the past, you have probably focused on what
you were doing. This may still be important. The “how” approach will
lead you to the level of P2 integration that you seek. The first six criteria
show you how to drive performance that will then lead to results, some-
thing that is covered in the seventh criterion. Let's take a look at the
types of “how” questions that should be asked in each of these criteria.

Leadership. A strong top-down direction for P2 or an EMS will en-
hance the chances of success in the program and help integrate it into
the organization as a whole. P2 will be seen as important if the top
leaders support it. Two sets of issues must be dealt with in the leader-

* ship criterion:

continual P2. program improvement to the employees and
_ other interested parties?

; ¢ How do senior leaders demonstrate that commitment?

The time you take to keep the leaders informed and involved (i.e.,
“walking the talk”) will help you provide answers to these important ques-
tions.

Strategic planning. Leadership most often uses some form of strate-
gic planning to guide the organization’s course. Sometimes this involves
a formal strategic planning program. In other cases, the strategic plan-
ning may be much less formal. There are four basic questions that you
need to address in the strategic planning criterion to attain continual P2
program improvement:

een ree |

you develop these. goals < and objectives?

_How,do you implement these goals a and objectives? .

How do these goals and objectives relate to your |
organization’ 's overall business objective?

To be ideally situated, the P2 program must be important in the
eyes of the senior leaders and be represented in the strategic planning
process. There is a strong link between strategic planning and leader-
ship.

Interested-party involvement. No organization operates in isolation.
There are many other organizations that can have an impact on your
P2 or EMS programs. Interested parties include a wide variety of differ-
ent stakeholders in your P2 program such as customers, suppliers,
contractors, regulatory agencies, non-government organizations
(NGOs), environmental groups, community groups, and the public at

Using a Quality Model to Implement R2°

The first six criteria show you
how to drive performance that
will then lead to results, some-
thing that is covered in the
seventh criterion.

A strong top-down direction for
P2 or an EMS will enhance the
chances of success in the
program and help integrate it
into the organization as a
whole.

To be ideally situated, the P2
program must be important in
the eyes of the senior leaders
and be represented in the
strategic planning process.

There are many other organi-
zations that can have an
impact on your P2 or EMS
programs.



18 to 40+ alternatives. Many of the alternatives derived in the former
case may not finish in the top-10 listing after the longer list of alterna-
tives is prioritized. The cause-and-effect diagram is the most widely
used problem-solving tool in the world. It deserves consideration in the
implementation of your P2 program.

The issue of goal setting is very important in P2. The traditional
approach sets goals up front. Many state-mandated P2 programs also
set statewide goals at the start of the program. In the Systems Ap-
proach, the organization sets performance goals in the action plans
after the information on P2 has been gathered and evaluated. They are
set year-by-year and project-by-project. The sum of all the action plan
performance goals is the overall performance goal of the year. Some
quality experts believe that goal setting is rarely done properly. They
argue that one should measure continual improvement and always in-
crease the amount of P2 accomplished, no matter how small they may
be. There should also be no backsliding in areas in which improve-
ments have already been made. This sort of seemingly incremental
improvement can yield large breakthroughs as P2 program participants
learn how to master change.

The basics of the traditional approach can be integrated with the
lessons of the Systems Approach. They work well together and allow
the organization to make continual improvement in the conduct of the
traditional P2 program.

APPROACHES FOR VERY SMALL ORGANIZATIONS

One argument for retaining the traditional approach exclusively was
that it worked well for very small organizations. The tools of the Sys-
tems Approach were sometimes thought to take too long to use and to
be too difficult for very small organizations to master. Some observers
thought that these organizations would have to rely on outside P2 tech-
nical assistance providers to help them with P2 alternatives.

The following case study illustrates how the Systems Approach
could be used by small organizations to complement the use of the
traditional approach. Use of this Systems Approach does not rule out
the traditional approach, but illustrates how the tools that are presented
in this Guide might increase the effectiveness of the traditional approach.

EPA funded the development of a publication called Nothing to
Waste (Reference 5-1) for its Environmental Justice program. This pub-
lication uses the Systems Approach for dealing with very small busi-
nesses. A model for helping. very. small organizations succeed was
developed by a team lead by a not-for-profit group, Working Capital.
They formed groups of leaders of very small organizations who met on
a regular basis outside of working hours. A facilitator helped them work
through some modules that taught them how to write a business plan
and how to apply for a loan. Banks provided the groups with money to

Traditional Ap

The cause-and-effect diagram
is the most widely used prob-
lem-solving tool in the world.

The issue of goal setting is
very important in P2,

This sort of seemingly incre-
mental improvement can yield
large breakthroughs as P2
program participants learn how
to master change.

The basics of the traditional
approach can be integrated
with the lessons of the Sys-
tems Approach.

EPA funded the development
of a publication called Nothing
to Waste for its Environmental
Justice program. This publica-
tion uses the Systems Ap-
proach for dealing with very
small businesses,



EPA Standards Network Fact Sheet, [SO 14000: International
Environmental Management Standards, EPA/625/F-97/004
http:/Awww.epa.gov: mrl/

ISO 14000 Resource Directory, EPA/625/R-97/003
http:/Avww.epa.gov/ttonrmrl/

1SO 14001: A Tool for Supporting Government Environmental
Programs and Policies, EPA/625/R-00/006
http:/Avww.epa.gov/ttbnrmrl/

ISO 14001: An Industrial Management Tool for Achieving
Competitive Advantage and Environmental Compliance,
EPA/625/R-00/007

http:/Awww.epa.gov/ttonrmrl/
See the CD-ROM for more reading.

EMS Approach to P2 Implementation



These teams can be used to
identify, evaluate, and imple-
ment P2 opportunities.

Teams are authorized to take
direct action, make decisions,
and initiate changes that result
in continual improvement.

The EMS is driven by environ-
mental impacts.

An organization's aspects may
include waste generation and
pollution, resource utilization
and depletion, energy genera-
tion and utilization, and other
ecological impacts on the
environment.

86

allows for discussion and comparison of differences. It may be useful
to set up self- managing P2 teams chosen from all levels of the organi-
zation. The involvement of several levels of management in these dis-
cussions, normally in several groups, improves their usefulness. Clearly
identifiable teams are the primary means of organizing the EMS work,
as opposed to individual job functions or independent work areas. These
teams can be used to identify, evaluate, and implement P2 opportuni-
ties.

Teams are authorized to take direct action, make decisions, and
initiate changes that result in continual improvement of the EMS to com-
ply with the policy and achieve the organization’s objectives and tar-
gets. When the employees’ roles have been formally structured to sup-
port the work team approach, members can rely on one another for
cross training, problem solving, administrative duties, and mutual sup-
port. Opportunities for waste elimination, reduction, reuse, recycling,
and energy and water conservation are addressed by a P2 team of the
most appropriate people regardless of their reporting level in the orga-
nization.

Identification of Aspects and Significant Environmental
Impacts

The EMS is driven by environmental impacts. An EMS encourages
organizations to systematically address the environmental impacts of
their activities, products, and services (Figure 6-4, work step 3.2). This
systematic approach may prove effective in encouraging organizations
to take a proactive and P2 approach to managing their environmental
impacts and programs. An organization’s aspects may include waste
generation and pollution, resource utilization and depletion, energy gen-
eration and utilization, and other ecological impacts on the environ-

ment.

ices that can interact with the environment.

The standard outlines a core set of planning activities that are used
in many organizations to assess and implement P2. This planning en-
sures a facility will:

vities, operations, processes, services,

ve environmental impacts

irements that apply to the organization's

, and services

valuate ‘which environmental impacts are significant

Set objectives and targets for reducing negative environmental

impacts

© Select and implement activities through environmental man-
agement program(s) to achieve the identified targets

Chapter 6



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Paper Rinse Spent Rags, Plates Water — Developer

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Figure 4-2. Hierarchical Process Maps.

54

fapter 4

©ODSSHHOLHOO HOH HHOHHDEHHOHSHOHOOHHEOHHHHHHOHOHOHHHOHOHROO


The Systems Approach tools
point out how things can be
changed to conserve the use
of that resource or prevent the
waste from occurring.

The Systems Approach
provides management with a
reasonably accurate profile of
process problems.

arise within the organization—which in turn may stem from some diffi-
culty with the way things work (or don’t work). Because of these en-
tanglements, too much time and energy may be spent trying to under-
stand the situation before ever getting on to the problem-solving stage.
Systems Approach tools can help.

The Systems Approach tools cut through such situations. They
facilitate problem solving by allowing the workers to understand why a
regulated or expensive resource is being used or a waste is being
generated. These tools point out how things can be changed to con-
serve the use of that resource or prevent the waste from occurring.
This is fundamentally different from having the environmental coordi-
nator or external assistance provider suggest a way to change the
process without involving the workers in decision-making.

The Systems Approach relies on intra-organizational teams, not
individual experts, to make decisions. It requires team members to
analyze a resource or waste problem thoroughly, determine the under-
lying root cause, and generate possible alternatives. Based on this,
the problem solvers can make an objective, rational, comparative evalu-
ation. This is not to say that the team should not use the proper exper-
tise as a resource to their work. It should. However, responsibility for
decision-making should rest in the hands of team members who will
implement and evaluate the proposed measures.

Because the Systems Approach is interactive and based on work-
ers’ own decision-making efforts, team members feel they “own” a
portion of the analysis. Of course, employees have preferences and
different points of view, and because the Systems Approach tools are
“team-friendly,” they allow for this. This involvement is important be-
cause an answer imposed from outside is less likely to work than one
arrived at within the organization.

Another consideration is the overall management process in the
organization. It is important to identify the process-related reasons for
resource use and loss before you can convince a manager to change
the process to avoid them. In this context, the Systems Approach pro-
vides management with a reasonably accurate profile of process prob-
lems. It makes clear that, unless the problems are corrected, these
and similar problems are likely to recur. Effective planning, including
the revision of current strategies and policies, benefits from the use of
the Systems Approach.

Checklists do have a place in P2 programs. Throughout the Sys-
tems Approach, it is useful to make lists of questions and answers for

anything related to each of the tools. Such lists form an outline of the

entire problem situation and are important entries in any record of the
process. Some sample checklists can be found on the CD-ROM that
accompanies this Guide.

Chapter 4

SPOOHOHOOHHSHHSSOHHSSHOHHGSHHHHHOHHHOHHHOHHOHOHOHHHHEHOOHOS



Undertaking P2 projects can
reduce regulatory exposure
and, in some cases, eliminate
the need for permits, manifest-
ing, monitoring, and reporting.

P2 can improve an
organization’s material produc-
tivity through more efficient
use of raw materials due to
improved processes and
operations.

P2 reduces the generation of
wastes (discharges, emis-
sions, spills, and leaks) at the
source, resulting in less toxic
waste, and thus assures
improved environmental
protection.

12

substances. These steps will produce cost savings through material
loss prevention and may result in reduced insurance rates as medical
claims and disability leaves decrease. Better labor relations can also
result from improved worker safety. Unfortunately, there have been
cases where P2 activities have inadvertently decreased worker safety
hazards (e.g., substituting the flammable solvent isobutyl alcohol for
the halogenated solvent 1,1,1-trichloroethane which is non-flammable
but a worker health issue). It is important that P2 does not trade off
environmental improvement with workplace health and safety. Ergo-
nomics can also be influenced by P2 efforts.

Reduced compliance costs. Undertaking P2 projects can reduce regu-
latory exposure and, in some cases, eliminate the need for
permits, manifesting, monitoring, and reporting. This is referred to as
avoiding the need for regulatory compliance. Keeping up with regula-
tory requirements and submitting the required reports can be an ex-
pensive and time-consuming process that, if eliminated, saves money.
For example, the U.S. Air Force has initiated a program known as Com-
pliance Through Pollution Prevention (Reference 1-1). The Air Force is
trying to achieve and remain in compliance by using P2 instead of clas-
sical environmental engineering and regulatory compliance techniques.
Some organizations have been able to change their regulatory compli-
ance status (e.g., move from a large quantity generator of hazardous
waste to a small quantity generator) through the use of P2 activities.

Increased productivity. P2 can improve an organization’s material
productivity through more efficient use of raw materials due to improved
processes and operations. For example, an organization that produces
large quantities of wastes (discharges, emissions, spills, and leaks)
might be using old technologies to produce its products, or its pro-
cesses might be poorly controlled and inefficiently operated. Some-
times small process improvements involving material substitutions and
changes in operating procedures can result in increased product yield
and better quality.

Increased environmental protection. Many waste disposal and treat-
ment methods are less protective of the environment than previously
estimated. These methods may only move environmental contaminants
from one medium to another. They may cause problems in the future
that are not yet apparent. P2 reduces the generation of wastes (dis-
charges, emissions, spills, and leaks) at the source, resulting in less
toxic waste, and thus assures improved environmental protection.

Reduced exposure to future liability costs. Reduction of potential
long-term liability from waste disposal, emissions, and discharges has
become an important concern in recent years. Some past disposal
practices, although legal, have caused environmental damage for which
organizations have been held liable, creating a large liability expense
and damaging their public images. P2 can help reduce long-term liabil-
ity by reducing the amount and toxicity of waste generated.

Cha pter 1



portant program element. Management should encourage employees
at all levels of the organization to identify opportunities to reduce waste
generation and promote energy and water conservation. Management
should also encourage employees to adopt the P2 philosophy in day-
to-day operations and identify new opportunities at meetings and other
organizational functions. P2 should be a process of continual improve-
ment when incorporated into an organization’s policy. Ideally, a P2 pro-
gram should become an integral part of management's strategic plan
to increase productivity and quality.

Some techniques top management can use to demonstrate their
support are:

roving strategic P2

tributions... -
*_. Ensure that P2¢ a
ie. writing. a .
* ® Commit the organization to implementing P2 action plans.
* Provide training for all employees on how resource use and
production losses result from wasteful work processes.
* Publicize P2 results.

ee ee cee eee

2. Characterize the Process and Assess P2 Opportunities

Some P2 assessments focus on wastes being generated by a
facility's main processes. In contrast, process characterization leads
to the identification of all P2 opportunities (including those in related
ancillary and intermittent operations), not just the ones uncovered ina
limited P2 assessment or walk-through. Both resource use and loss
are considered.

An effective way to conduct process characterization is through
the use of hierarchical process maps. These maps (see Chapter 4)
can be used to analyze all processes, including ancillary and intermit-
tent operations. An organization using this assessment method can
also examine energy and water use, landscaping, commuting, noise,
odor, and other aspects of their operations. These process maps:can
also be used as templates for collecting information on resource use
and the loss of resources, with the information organized by work step.
Some organizations use process maps as a means for maintaining a
resource use and loss accounting system to track the types and
amounts of resources involved, including the rates and dates they are
used or lost.

P2 Program Elements

Process characterization
leads to the identification of all
P2 opportunities (including
those in related ancillary and
intermittent operations), not
just the ones uncovered in a
limited P2 assessment or
walk-through.



~—_e wer eG V SSE VV EVV VVEVVEVVVEeETVVEeVVeEVVVVeEVeTVVeVeETVVVeVET eS

gi iving prefe 7
reduction, second to recycle/reuse,
chniques may be used __

5. Ongoing | reduction of wastes and i releases
SHIGE fi fi rst to.squ

Ongoing ‘dialogue witl empl joyees and members oft the
public regarding waste and release information, progress
in achieving reductions, and future plans. This dialogue
‘should be ata personal, face-to-face level where possible, {
and should emphasize listening to others and discussing H
their concerns and ideas - H
Inclusion of waste and release prevention objectives in
research and in design of new or modified facilities, pro-
sses, and products. ”

10. An ongoing program for “promotion and support o ‘of waste

8

ssl lt

a) sharing of technical information: and experience with cus-
“tomérs and suppliers. .

b) support of efforts to develop improved waste and release
asea= reduction techniques.

#¢) assisting in establishment of regional air monitoring net-
“works,

participation in efforts to develop consensus approaches
to the evaluation of environmental, health, and safety
impacts of releases.

=:@) providing educational workshops and training materials.
f) assisting local governments and others in establishment
of waste reduction programs benefiting the general pub-
lic.

ee er

. Periodic evaluation of waste management practices
associated with operations and equipment at each mem-
ber company facility, taking into account community
concerns and health, safety, and environmental impacts
and implementation of ongoing improvements.

12. Implementation of a process for selecting, retaining, and

- reviewing contractors and toll manufacturers taking into

account sound waste management practices that protect
the environment and the health and safety of employees
and the public.

13. Implementation of engineering and operating controls at

each member company facility to improve prevention and

early detection of releases that may contaminate ground-
water.

P2’Program Elements



The traditional approach looks
at all routine communications
and finds ways to encourage
them.

The traditional approach
recommends a public out-
reach and educational pro-
gram.

The Systems Approach tools
presented in this Guide can be
used to enhance the effective-
ness of the traditional ap-
proach.

Another potential improvement
is in the use of root cause
analysis to examine why a
selected P2 opportunity has a
problem associated with the
use of a regulated material or
a regulated loss.

Communication is important to any program. The traditional ap-
proach looks at all routine communications and finds ways to encour-
age them. It also promotes the solicitation and follow-up of employee
suggestions.

As an incentive for participation in the P2 program, the traditional
approach includes an employee reward program. It features perfor-
mance reviews, recognition among peers, and material rewards. Fi-
nally the traditional approach recommends a public outreach and edu-
cational program.

More information on the traditional approach, including copies of
the previous EPA publications, can be found on the CD-ROM that ac-
companies this Guide. All the checklists and worksheets from the tra-
ditional approach are provided on that CD-ROM.

COMBINING THE TRADITIONAL APPROACH WITH THE
SYSTEMS APPROACH

Many of the readers of this Guide have been using the traditional
approach for years. The process maps provided here and in Chapter 1
should help you use this approach more effectively. You may have be-
gun to consider changes you might make to the approach that will
work well for you. It is instructive to prepare a process map of your
approach to P2 so everyone in your program can understand it clearly.

The Systems Approach tools presented in this Guide can be used
to enhance the effectiveness of the traditional approach. One area
where improvement can be made is in the process characterization. It
is easier for management and team members to “see” the process
maps. Having piles of information and checklists to review can be far
more daunting. The process maps also enable the team to focus on
certain areas that offer the best opportunities for P2.

Process mapping can be conducted by those interested in pro-
moting P2 before going to management for commitment to the pro-
gram. It may be a wise decision to let them understand what opportu-
nities await them if they approve this program. Process maps will typi-
cally find more opportunities for P2 than a walk-through or preliminary
assessment.

Another potential improvement is in the use of root cause analysis
to examine why a selected P2 opportunity has a problem associated
with the use of a regulated material or a regulated loss. Experiments
have been conducted with P2 teams to test the theory that root cause
analysis will lead to better alternative generation. A team that does not
use root cause analysis and goes directly from the selection of the P2
opportunity to the generation of alternatives typically is capable of speci-
fying two to four alternatives. In contrast, a team that uses root cause
analysis first and then tries to generate alternatives will come up with

Chapter 5

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and other results; and financial results. The environmental results look
at current levels and trends just as the other approaches do. The sec-
ond segment of the results summarizes customer, employee, com-
munity, supplier, market, and other interested-party results within the
context of the continual environmental improvement approach. In other
words, how is their perception of your organization’s environmental
excellence changing? The third segment of the results summarizes
the financial performance results related to the implementation of your
continual environmental improvement approach.

The organization’s results need to convey levels (the current level
of environmental performance reported graphically), trends (multiple
data points presented graphically), and comparative data (how your
organization is performing with respect to similar organizations). It may
take a few years to build strong results, but it is an important means of
improving your organization’s P2 program. The link between environ-
mental and financial results is very important. All environmental results
can be “translated” into financial results. This is the best means avail-
able to get and maintain top management leadership in the P2 pro-
gram. Make establishing this connection a priority as you plan a new
P2 program or seek to improve an existing one.

INFORMATION AND ANALYSIS

It is necessary to examine how your organization uses information
in order to identify and evaluate environmental aspects of products,
services, or production processes. It is also important to determine
how this information is used to assess service, product, or process
performance and to identify areas for improvement (i.e., P2 opportuni-
ties) based on environmental considerations.

Most of the information in the traditional approach comes from as-
sessments performed in the workplace. Checklists are often used to
gather information for the analysis of each P2 project. Everything is
usually handled on a project-by-project basis.

In the EMS approach, information is gathered on the aspects of the
organization and analyzed on a general level to determine the signifi-
cant environmental impacts and to set EMS objectives and targets.
Further information is required for each of the environmental manage-
ment programs. Documentation is maintained in the EMS to track in-
formation and make it available for analysis. This is an important ele-
ment in the quest for continual environmental improvement.

In the quality-based P2 approach, information and the analysis of
that information play a pivotal role in the program. The information and
the results should be linked and used in the planning efforts. Manage-
ment can use these items to make P2 a central issue in the day-to-day
operation of the organization.

Finding Your Own Way to Implement;/P2

The link between environmen-
tal and financial results is very
important. All environmental
results can be “translated” into
financial results. This is the
best means available to get
and maintain top management
leadership in the P2 program.

It is important to determine
how this information is used to
assess service, product, or
process performance and to
identify areas for improvement
(i.e., P2 opportunities) based
on environmental consider-
ations.



All the referenced material is accessible using the CD-ROM, including the previous EPA P2 publications
and associated checklists. Information on a large number of EPA and state P2 activities is also included.
The CD-ROM is divided into the following sections:

=e 2 z SoSaT a

checklists sex
Links to information on the: P2 tools...
nforr upport P2 implementation oe

1€ quality (Green Zia) model to support P2 implementation

anuals

i RR TET

Other sources of useful P2 information



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process management when implementing the P2 Program. Using the
Systems Approach tools will provide a head start in this direction.

issues (aspects)? _ i
Involve employees, customers, and suppliers in process analysis?

se its environmental management system to manage processes in 4

4

4

&

==" day-to-day operations?
--- Conduct process analysis of corrective actions or other nonoperational
problem areas?
_lmprove its process analysis s system?
“Systematically prioritize areas for continual improvement?
Ee Develop action plans to improve processes? "
F

Involve employees, customers, and suppliers in identifying and imple-
menting process improvements?
Manage processes to meet or exceed environmental performance
goals?
+ Communicate information on improvement projects to ensure organiza-
"tional learning?
+ Use benchmarking as part of ongoing process improvement activities?
+ Improve its process improvement system?

‘EMPLOYEE PARTICIPATION

All approaches include employee involvement. Both the EMS- and
quality-based approaches address employee education and skill de-
velopment. The quality-based approach also emphasizes employee
satisfaction and well being. As more and more organizations address
the issue of sustainable development and its focus on the social as-
pects of environmental issues, it will become more important to pay
attention to the well being of the employees.

It is always informative to walk around a facility and randomly ask
employees what they know about the organization’s P2 program. Hav-
ing a P2 policy statement hanging on the wall does not ensure that the
employees will be able to participate effectively in the program. When-
ever an organization undertakes a new management program, quite a
bit of time is spent preparing the employees for participation in that
program. It makes sense that the same would hold true for P2.

Box 8-5 lists some questions to ask about employee participation
in a P2 program.

Employee involvement plays a key role in any successful P2 pro-
gram, so it is important to be diligent in promoting it.

Finding Your Own Way to Implem

Having a P2 policy statement
hanging on the wall does not
ensure that the employees will
be able to participate effec-
tively in the program.

Employee involvement plays a
key role in any successful P2
program, so it is important to
be diligent in promoting it.



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CHAPTER 4

P2 Tools

USING P2 TOOLS

P2 teams can use a variety of specialized tools to get their work
accomplished. These tools provide visual aids that are essential in com-
municating P2 information to management, workers, and other inter-
ested parties. Tools also help P2 teams gather information and provide
problem-solving and decision-making guidance to the P2 team. Finally,
by using specialized tools, the P2 team can construct an action plan
for each project covered by the program. This plan allows for consis-
tent tracking by the P2 oversight committee.

There is an endless variety of different problem-solving and deci-
sion-making tools available. Most of these tools have been used through-
out the world in a variety of quality programs for more than 50 years.
Only in the past 10 years or so have they been applied to P2 projects.
Many small organizations have learned these tools by using the Envi-
ronmental Justice manual entitled, Nothing to Waste (Reference 4-1).
Larger organizations have often learned the tools through the various
types of quality programs that have come and gone over the years. The
problem is that environmental managers are often unfamiliar with such
tools. This is beginning to change as more organizations seek to inte-
grate environmental programs into their core business practices. This
integration effort helps align the ways problems are addressed and
solved within the organization. Keeping the P2 program independent of
mainstream operations activities may limit the program's efficiency and
effectiveness.

SYSTEMS APPROACH TOOLS

An organization acts as a system that functions as a whole through
the interaction of its parts. The Systems Approach looks at the whole
organization, and the parts, and the connections between the parts.
The functionality of the parts depend on how they are connected, rather
than what they are. The parts of a system are all connected directly or
indirectly. Therefore, a change in one part affects all the other parts.
Given this interdependence, tools that address the complexity of orga-
nizations are important. There are several reasons why the Systems
Approach tools meet this need and work so well in the planning and
implementation of your P2 program.

First, processes that use resources and generate wastes do not
always provide synoptic information clearly suited for checklist-style
presentation. Instead, these processes are more than likely intertwined
with other situations such as emotional distress or political issues that

Includes:

0 Using P2 Tools

O Systems Approach Tools
O Checklists

O Lessons Learned

CO References

Specialized tools provide
visual aids that are essential in
communicating P2 information
to management, workers, and
other interested parties. Tools
also help P2 teams gather
information and provide
problem-solving and decision-
making guidance to the P2
team.

The Systems Approach looks
at the whole organization, and

the parts, and the connections
between the parts.



ACKNOWLEDGMENTS

This Guide was prepared under the direction and coordination of Emma Lou George of the U.S. Envi-
ronmental Protection Agency (US EPA), Office of Research and Development, National Risk Management
Research Laboratory, Technology Transfer and Support Division, Technology Transfer Branch, Cincinnati,
Ohio. .

Science Applications International Corporation (SAIC) compiled and prepared the information used for
this Guide under the management of Lisa K. Kulujian. The authors were Dr. Robert B. Pojasek, Pojasek &
Associates, and Cam Metcalf, Executive Director, Kentucky Pollution Prevention Center. Custom Editorial.
Productions (CEP) of Cincinnati, Ohio, prepared the final document for publication.

The seeds for this document were planted by a Focus Group comprised of invited pollution prevention
practitioners from US EPA, Regional and State programs, industry, and academia. This Focus Group was
conducted in Cincinnati, Ohio, in conjunction with the National Pollution Prevention Roundtable in the
Spring of 1998. It was further shaped by an Engineering Conference conducted in Crested Butte, Colo-
rado, in the Fall of 1998. The final draft of this Guide was distributed to more that two hundred pollution
prevention practitioners. The following people (in alphabetical order) spent valuable time reviewing and
commenting on this publication, providing significant input that helped the authors in making it a more
complete and accurate informational Guide:

M. Gavin Adams, Pollution Prevention Program, AL Department of Environmental Management (ADEM)
Gary E. Baker, QEP, Battelle

Martine Dumais, National Office of Pollution Prevention, Environment Canada

Art Gillen, Senior Associate, First Environment, Inc.

Robert Lundquist, MOEA /MnTAP

Sandi Moser, National Office of Pollution Prevention, Environment Canada °

Margaret Nover, Pollution Prevention Manager, City of Portland

Lynnann H. Paris, Chief, Technology Transfer Branch, TTSD, NRMRL, ORD, US EPA

Timothy J. Piero, Kentucky Pollution Prevention Center

Pollution Prevention Division, Office of Prevention, Pesticides and Toxic Substances, US EPA

John Shoaff, US EPA, Standards & International Affairs, Office of Prevention, Pesticides and Toxic
Substances

Mark Snyder, MOEA/ MnTAP

TP3 Staff, Division of Environment and Conservation, TN Department of Environment and Conserva-
tion (Cynthia Rohrbach, David Borowski, Karen Grubbs)

Pete and Lynnann H. Paris (Chief, Technology Transfer Branch) provided the scenic picture from
Maine that has been used for the cover art of the Guide and the companion CD-ROM.



The periodic use of checklists
generates a consistent means
of assessing progress.

Tools take time to master, but
they help foster skills that the
P2 team needs to characterize
the process, solve problems,
and make decisions.

Track the implementation of the solution and evaluate
progress.

Test the use of each of the P2 program elements in this
process.

Q

Q

Q_ Test the completion of the action plan. :

a

Q

Q Test the overall P2 program effectiveness.

The periodic use of checklists generates a consistent means of
assessing progress. Checklists should be designed to provide man-
agers and P2 team members with a tool for assessing the significant
characteristics of each step in the Systems Approach, checking the
vital “how to” of each step, and analyzing in greater detail how well the
tools are being used.

A number of checklists can be found in the CD-ROM that accom-
panies this Guide. You should be able to use and customize these
electronic documents to fit the needs of your organization.

LESSONS LEARNED

Tools take time to master, but they help foster skills that the P2
team needs to characterize the process, solve problems, and make
decisions. The repeated use of the tools makes P2 team meetings
more productive. Many people avoid the use of tools because they be-
lieve that it takes too long and the benefits are not worth the effort. The
tools lead to increased focus and questioning. P2 teams that use the
root cause analysis tool usually derive a minimum of 20 P2 alternatives
for future consideration. In contrast, teams that do not use the tool
typically limit themselves to three or four alternatives.

The more methods and tools that you have time to use, the better
the P2 program will be in the long run. Limiting tool selection can impair
the development of the P2 program.

Chapter 4



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CHAPTER 2

Getting Started

So you have decided to move from conducting specific P2 projects
to having a formal P2 program. Maybe you are just trying to revive an
older P2 program in your organization. In either case, this section of the
Guide will provide you with information to consider before beginning
your P2 program planning process.

HOW TO DEFINE P2

It is important to decide how you will define P2. In order to know
what you can include in your P2 program, it helps to know what is pos-
sible. There are many definitions available to choose from and many
programs that are closely related to P2. We will present a few P2 con-
cepts to help you determine where you wish to focus your efforts. First,
the definition of pollution prevention adopted by the U.S. Environmental
Protection Agency (EPA) is provided in Box 2-1.

; 1, Rallution Prevention. Be -Befinition. ]
Pollution prevention means “so means “source reduction” (as defined under the
Pollution Prevention Act) and other practices that reduce or eliminate the

Ecreation of pollutants through:

Ticreased @iliciency in the use of raw. “materia s, energy, water, or j

==6ther resources, or _ ‘

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seat docmenicestia series

The Pollution Prevention Act defines source reductionto mean any prac-

men:

reduces the amount of any hazardous substance, pollutant, or con-
taminant entering any waste stream or otherwise released into the ¢
lin

or contaminants.

Under the Pollution Prevention Act, recycling, energy recovery, treat-

= ment, and disposal are not included within the definition of pollution preven-
tion. Some practices commonly described as “in-process recycling” may
qualify as pollution prevention.

From Hank Habicht’s EPA memorandum of May 28, 1992 (Reference 2-1)

The EPA definition stresses the importance of placing source re-
duction at the top of a “waste management hierarchy.” Recycling, proper
treatment, and safe disposal of the residues are farther down the hier-
archy. There are other similar P2-like concepts that some feel com-
pete with the EPA definition.

Getting Started ‘ |

Includes:

0 How to Define P2

O Sustainable Development

1 Integrating the New P2
Program into Core
Business Practices

1 Who Should Implement
P2?

O When Will You Begin?

C1 Lessons Learned from
Past P2 Programs

0 Dealing with Change

O References

In order to know what you can
include in your P2 program, it
helps to know what is possible.

The EPA definition stresses the
importance of placing source
reduction at the top ofa “waste
management hierarchy.”



A formal action plan should be
prepared for every P2 activity
that is planned for each year
of a P2 program.

Many P2 practitioners currently use prioritization tools. One limita-
tion, however, is that they begin with a finite set of potential solutions to
choose from because they have not used a method such as brainwriting
to generate sufficient alternatives. An example of the prioritization of
the alternatives generated in the previous step may be found in Figure
4-8. You may note that alternatives can be grouped in different combi-
nations during the bubble-up/bubble-down procedure. Other examples
of the use of bubble-up/bubble-down can be found on the CD-ROM.

Action Planning

Finally, a formal action plan should be prepared for every P2 activ-
ity that is planned for each year of a P2 program (Reference 4-8). Inthe
tush to implement, P2 practitioners should not overlook the need to
formalize their action plans. Each action plan should list the P2 alterna-
tive that will be implemented and show the sequence of steps neces-
sary to implement the alternative. The person responsible for ensuring
that each step is completed should be indicated in the action plan.
Performance of that step must have some recognizable goal that must
be reached. A metric should be devised to measure the progress to-
ward meeting that goal and to provide a time frame for reaching the
goal or completing that step. Finally, an indication of the resources re-
quired to reach the goal should be included in the formal action plan.

A sample form for use as an action plan is shown in Figure 4-9.
Some action plan examples can be found on the CD-ROM that ac-
companies this Guide.

When P2 programs are audited on an annual basis, the auditor
can select action plans and confirm that the work indicated actually
has taken place. Periodic assessments of P2 program status depend
on information like this to serve as the basis for measuring progress.

ALTERNATIVE Date:
SELECTED:
, Responsible Monitoring | Completion | Resources
Action Person Performance | Technique | Deadline Needed

Figure 4-9. Example of an Action Plan.

Chapter 4

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EHS (environment, health and safety) management, 101-102
80/20 rule, 16, 57, 59
Embedded goals, 107-108
Emergency preparedness, 96
Employee participation, 26, 39, 116-117, 129-130
award programs, 74
educational training, 73
EMS training and responsibility, 82-90
growth opportunities, 37
valuing, 37, 108-109, 132
EMPs (Environmental Management Programs), 5, 90-91
EMSs. See Environmental management systems
Energy intensity, 22
Environmental accounting, 43
Environmental Accounting Project (EAP), 11
Environmental awareness training, 89-90
Environmental compliance audits, 82, 95
Environmental excellence, 5, 101
Environmental, health and safety (EHS) management, 101-102
Environmental impacts, 86-88, 97-98
Environmentally Preferred Purchasing (EPP), 11
Environmental Management Programs (EMPs), 5, 90-91
Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations, 87 .
Environmental management systems (EMSs), 5, 24—25, 79-100
aspects, 86-91
checking and corrective action, 93-94
communication of EMS policy, 84
emergency preparedness, 96
environmental impacts, 86-91
Environmental Management Programs (EMPs), 90-91
environmental policy, 83-84
getting started, 80-83
implementation, 91-94
ISO 14001 format, 24, 79
lessons learned, 96-99
management commitment, 83-84
management review and continual improvement, 95-96
monitoring and measurement, 94-96
objectives and targets, 88-89
operational control, 92-93
planning, 85-91
principles, 79-80, 96
process management, 128-129
process mapping, 80, 81
scope of EMS, 83-84
spill prevention, 96
training and responsibility, 89-90



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To obtain the cost of the losses, it is often necessary to confer with
the purchasing department. Some of these costs are estimated since
they may be split between product and loss, such as in the paint ex-
ample. Sometimes you throw away a container included in the cost of
the product inside the container. Of course, because estimates are
less accurate than the general ledger costs, you may want to estimate
conservatively to maintain the credibility of your analysis.

A third cost category is associated with the activity-based cost of
managing the loss. If the loss is regulated (e.g., hazardous air pollut-
ant, hazardous waste, or wastewater priority pollutant), there are anum-
ber of activities that may be required by the regulations. You first must
determine all the activities that must be performed for the non-product
losses from each work step at the lowest level in the process map.
Then you must estimate the cost associated with each of these activi-
ties. The total activity-based cost associated with each loss is added to
the total cost of the loss associated with the general ledger cost and
the cost of the lost resources.

Often the cost of a non-product loss will triple when adding the cost
of the lost resource (i.e., the second cost category above). If the loss is
regulated, the activity-based cost of managing the loss may increase
this composite cost to five times the original general ledger cost. Obvi-
ously, there are large variations in the true cost of the non-product losses.
However, capturing all the cost components is necessary because if
the loss can be prevented, all of this money is saved, not just the gen-
eral ledger cost of the loss.

Selecting P2 Opportunities

Information gathered in the process-mapping phase of the P2 pro-
gram can be used to select P2 opportunities on which to focus for
problem solving and decision-making. This is generally more useful
than relying solely on a walk-through or other P2 assessment. How-
ever, walk-throughs using process maps are essential to the proper
verification of the information in the maps. Some P2 programs target
opportunities by trying to eliminate costly compliance issues associ-
ated with the use or loss of regulated materials. Other P2 programs
seek to address targets that have been pre-selected by management
or environmental personnel. Each organization has its own means for
selecting P2 opportunities. However, there is a tool that can be used to
help the P2 team through this process.

If all the P2 opportunities identified in the process maps were ar-
ranged in order of their true cost to the organization, you would find that
20% of the P2 opportunities provide approximately 80% of the cost ben-
efits. Conversely, the remaining 80% of the P2 opportunities provide
20% of the true cost benefits. In most cases, you will find the 80/20 rule
(also called the Pareto Principle) to be a great guide for selecting P2
opportunities (Figure 4-4). Most organizations use Pareto analysis in

P2 Tools

Often the cost of a non-
product loss will triple when
adding the cost of the lost
resource (i.e., the second cost
category above). If the loss is
regulated, the activity-based
cost of managing the loss may
increase this composite cost
to five times the original
general ledger cost.

Capturing all the cost compo-
nents is necessary because if
the loss can be prevented, all
of this money is saved, not
just the general ledger cost of
the loss.

If all the P2 opportunities
identified in the process maps
were arranged in order of their
true cost to the organization,
you would find that 20% of the
P2 opportunities provide
approximately 80% of the cost
benefits.



Capital justification protocols
may not recognize the “hidden”
costs that are avoided and the
reduction in the organization's
financial overhead burden
resulting from P2 measures.

Unfortunately, P2 changes
may occur faster than the
government can respond.

Some P2 projects may affect
product quality, even when
properly implemented, and
thus may be regarded with
skepticism.

Some large organizations have
encouraged their supply
chains to adopt P2 behaviors
to further the competitive
advantage of the entire value
chain.

Implementation of P2 projects
are often viewed by production
as requiring time, money, and
personnel, all of which are
usually in short supply.

Capital requirements. Implementation of P2 measures might require
capital investment. Such projects may need to be justified
economically and are subject to the availability of capital in the organi-
zation. Capital justification protocols may not recognize the “hidden”
costs that are avoided and the reduction in the organization’s financial
overhead burden resulting from P2 measures.

Specifications. Specifications can be both an incentive and an im-
pediment. For instance, specifications may stipulate certain materials
be used in the manufacture of a product, or that virgin materials be
used rather than recycled. This can lead to the use of materials that
are damaging to the environment, or the unnecessary use of virgin
materials where recycled would suffice.

Regulatory issues. \t may be necessary to obtain a new or modified
permit or other governmental approval before implementing a process
change or material substitution. This can be time-consuming and costly.
For example, if a process is regulated by the Food and Drug Adminis-
tration (FDA), all process changes require submittal of an
application for approval, and new equipment must be inspected and
approved by the FDA. In some cases, clinical trials of a substance,
such as a drug, must be repeated to demonstrate efficacy. Unfortu-
nately, P2 changes may occur faster than the government can respond.
Many permit changes can take long periods of time to attain in even the
most efficient governmental agencies.

Product quality issues. Organizations have great concern for the
quality of the products and services they offer. Some P2 projects may
affect product quality, even when properly implemented, and thus may
be regarded with skepticism. For example, the use of mineral oils in-
stead of mineral spirits (that have high volatile organic chemical [VOC]
emissions) to carry dyes to fabrics may mean that some of the oils will
remain on the fabric once it is dried, thereby changing the “feel” of the
fabric and possibly the value of the finished product.

Customers’ acceptance. The customer ultimately defines product
quality; anything that affects the quality, or even the perception of qual-
ity, may affect acceptance by the customer. Customers often have a
greater influence on how an organization operates than other outside
parties. Some large organizations have encouraged their supply chains
to adopt P2 behaviors to further the competitive advantage of the entire
value chain.

Immediate production concerns. Implementation of P2 projects are
often viewed by production as requiring time, money, and personnel, all
of which are usually in short supply. Production quotas must be met as
a first priority. After all, meeting the customers’ demands is what pays
the bills. However, production often finds the means to improve pro-
ductivity, and P2 needs to be seen in this same light.

OOOO OO LOSS OSE OOHODHOHEOHOSOHSHHHOSHSHHHHHSHHHOHHHOEHOHOOO



CHAPTER 3

P2 Program Elements

P2 PROGRAM PLANNING

Before planning begins, the team seeking to implement the P2 pro-
gram should consider preparing a vision statement, a mission state-
meni, and a statement of goals. If similar statements already exist for
the organization, you should see how P2 fits into these existing state-
ments. If the organization has no formal statements, the P2 program
team may wish to draft these statements to help provide some focus to
their efforts. It is important not to get side tracked on trying to differenti-
ate between vision statements, objectives, values, purpose, guidelines,
covenants, standard of performance, mission statements, core values
and guiding principles. For the purposes of talking about P2 planning,
we will adopt some simple definitions that can be modified as you see
fit.

Avision statement represents what the organization wants in terms
of P2. A mission statement identifies what the organization needs to
accomplish, in the future, in the key areas that affect P2 and its busi-
ness. A mission statement specifies an organization's purpose or “rea-
son for being.” Itis the primary objective toward which the organization’s
plans should be aimed. The mission is something to be accomplished,
while a vision is something to be pursued. Goals establish the metrics
that will be used to measure progress. Indicators are used to measure
progress along the way. These statements and measures will help pro-
vide a good foundation for the P2 plan that your organization develops.
Some of these statements may already have been formulated in an
ISO 14001 effort or other EMS initiative. Planning provides an organiza-
tion with a time frame in which to ask questions related to the enact-
ment of P2 programs (see Box 3-1). Considering these questions will
encourage the proper thought and analysis for your planning effort.

‘Where are we right now?
‘Where do we want to go?
“How do we get there?
‘When do we want to arrive?
:-: Who will get us there?
ies: What will it cost?
. How do we measure results? . wee
= Whowill help accomplish the plan?
; Whenwill each goal be completed?

*  Whatare the expected results?

Fc ete

P2 Program Elements

Includes:

O P2 Program Planning

O Core Values

O Selecting Program
Elements

O Lessons Learned

O References

Before planning begins, the
team seeking to implement
the P2 program should con-
sider preparing a vision
statement, a mission state-
ment, and a statement of
goals.

A vision statement represents
what the organization wants in
terms of P2. A mission state-
ment identifies what the orga-
nization needs to accomplish,
in the future, in the key areas
that affect P2 and its busi-
ness.

Goals establish the metrics
that will be used to measure
progress. Indicators are used
to measure progress along the
way.



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Using the Systems Approach Tools

Many organizations are finding they have to adapt to survive in the
global economy. Managers are learning new ways to run their organi-
zations, and workers are learning how to contribute their knowledge to
improving processes. By learning how to monitor, control, and con-
stantly improve production and various supporting systems, organiza-
tions are better able to provide their customers and other interested
parties with what they want, when and how they want it. These busi-
ness practices lead to better decisions for the interested parties and
for the organization—workers and managers alike.

The principles of quality improvement can be useful tools for achiev-
ing environmental excellence. Just as defect prevention is better than
the “find and fix” approach to quality control, P2 is preferable to “end-of-
pipe” control. The application of the quality improvement tools used by
the Systems Approach is a powerful force in eliminating environmental
inefficiencies and preventing pollution.

Process Mapping

Getting to know more about the uses and losses of resources in a
process and clarifying all that you already know are the two basic tasks
of process characterization. These tasks involve information gather-
ing, listing, sorting, and comparing.

Process characterization is the step where the bulk of your learn-
ing about the process takes place. This is where your existing systems
knowledge regarding the process is revealed and organized and where
new knowledge comes easily because the process-mapping tool makes
all process relationships “visible.” You will find that you no longer need
to restrict yourself to the main process. It is now possible to look at all
supporting operations—both ancillary and intermittent—to see how they
impact the main process.

Consider that every time a laboratory sample is taken to monitor a
process, the laboratory creates a waste. This waste could be prevented
if the sample were not taken in the first place. Of course, some moni-
toring is necessary and perhaps even required. This circumstance pre-
sents an opportunity to improve the efficiency of the monitoring pro-
cess. Maybe you could make an argument to the regulatory agency for
less monitoring based on your organization’s compliance record. For
example, the use of sensors for continuous monitoring would offer an
alternative to traditional “grab” samples. An argument could be made
and supported by the P2 program to change the sampling, thereby
reducing the wastes produced in the laboratory.

Process characterization makes P2 opportunities visible.
Worksheets probably do not do this effectively. Diagrams are often a
better tool. Connections between all work steps help clarify the causes

The application of the quality
improvement tools used by
the Systems Approach is a
powerful force in eliminating
environmental inefficiencies
and preventing pollution.

Process characterization is
where your existing systems
knowledge regarding the
process is revealed and
organized and where new
knowledge comes easily
because the process-mapping
tool makes all process rela-
tionships “visible.”

Connections between all work
steps help clarify the causes
for resource use and waste
generation.

P2 Tools |



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= ae |

FE Step 3. P2 Problem Solving

Once the P2 opportunities are selected, the use and loss of re-
sources are seen as “problems.” Worker teams are assembled to ad-
dress these problems using root cause analysis to first ask why each
is a problem. A simple cause and effect (fishbone) diagram can help
the team examine how materials, machines (technology), methods,
and labor contribute to the problem. This visual tool can communicate
the causes of the problem to all levels of the organization. In fact, the
cause-and-effect diagram is the most widely used problem-solving tool
in the world.

With this important information gathered and analyzed, the team
can now search for alternatives to solve the problem using tools like
brainstorming and brainwriting. It is important to remember the adage
that “the only way to find a good P2 alternative is to find many alterna-
tives.” In the past, many P2 problem-solving efforts centered on finding
the “right answers” instead of searching for alternatives. Previous.P2
success stories should be used only to provide ideas to the team using
this problem-solving method. Because workers often wish to be in-
volved in solving problems associated with their work, home-grown
solutions are often more readily implemented than expert-generated
solutions from the outside.

Now the team must select an alternative to implement. A good tool
for doing this is known as bubble-up/bubble-down. It is a forced-pair
comparison of all the alternatives. Some teams prefer to use a criteria
matrix or selection grid for rating each alternative against a predeter-
mined set of criteria. Alternatives that are inexpensive and easy to imple-
ment go to the top of the list using the bubble-up/bubble-down tool.
These “low hanging fruit” or “quick win” alternatives can often be imple-
mented without much further study. More effective alternatives may
require additional study. In some cases, a detailed feasibility study must
be prepared. It is always beneficial from a team development perspec-
tive to have the “quick wins” precede these more complex programs.

To implement the alternatives, a written action plan should be pre-
pared and submitted to management for review and approval. The key
component of the P2 plan at the facility will be the action plans that are
being implemented during the current year.

7 eae
“Step 5. P2 Program Management

2 ene ain at ighanrtnnigtc mene lf

This Guide suggests ways an organization can establish, imple-
ment, and manage its P2 program. The activities described in Steps 1

Introduction . i

A simple cause-and-effect
(fishbone) diagram can help
the team examine how materi-
als, machines (technology),
methods, and labor contribute
to the problem.

e Root cause analysis
Cause and effect diagrams
Fishbone diagrams
Brainstorming

Brainwriting

Now the team must select an
alternative to implement.

* Bubble-up/bubble-down
* Criteria matrix
* Action plan

To implement the alternatives,
a written action plan should be
prepared and submitted to
management for review and
approval.



Benefits of P2, 1, 11-13
continual improvement, 13
enhanced public image, 13
immediate, 27
improved worker safety, 11-12
increased environmental protection, 12
increased productivity, 12
reduced costs, 11, 12
reduced exposure to future liability, 12
resource conservation, 13
Best available technology, 82
Best management practices (BMP), 52
BMP (best management practices), 52
Bottom-up approach, 2, 26, 70, 125
Brainstorming, 17, 61, 72
Brainwriting, 17, 61-62, 116
Bubble-up/bubble-down (forced pair analysis), 17, 62-63, 116

c
Cause-and-effect diagram, 17, 59-60, 75, 116
CD-ROM, 6-7
Change
acceptance of, 27-28, 46, 50
behavioral, 27-28
change management, 28, 46
dealing with, 28-30
facilitating, 30, 50
intra-organizational teams, 50
management of, 28, 50, 56
process changes in EMS, 92
Checklists, 50, 65-66, 67
Cleaner production, 22, 23
Climate Wise, 97
Communication, 29, 74
of EMS policy, 84
external and internal, 84
traditional P2 program, 74
Complexity in P2 program, 29-30
Compliance audits, 82, 95
Conservation, resource, 13, 23, 40
Continual improvement, 13, 37, 67, 93
as core value, 37, 107-108
EMS program, 95-96
management review and, 95-96
Quality model, 107-108, 112-118, 131-132
Continuous improvement, 13
Core business practices, integration of P2 into, 2, 10, 24-26

138



Prevention of pollution is
defined by the standard as
“use of processes, prac-
tices, materials or products
that avoid, reduce or control
pollution, which may in-
clude recycling, treatment,
process changes, control
mechanisms, efficient use of
resources and material
substitution.”

The EMS standard requires
the environmental policy of the
organization be made avail-
able to the public.

The EMS requires the organi-
zation to develop and imple-
ment procedures to ensure
internal communication of the
EMS policy, responsibilities,
and results.

P2 is different from prevention of pollution as defined in the EMS
standard. Prevention of pollution is defined by the standard as “use of
processes, practices, materials or products that avoid, reduce or
control pollution, which may include recycling, treatment, process
changes, control mechanisms, efficient use of resources and ma-
terial substitution.” This definition does include control and treatment
scenarios but the phrases indicated in bold in the definition provide a
clear mandate in the policy to pursue source reduction as a goal and
objective of the EMS.

The EMS policy is used as the guidance for setting and reviewing
the organization’s environmental objectives and targets. The EMS stan-
dard does not require specific environmental goals. Instead, it provides
a general framework for organizing the tasks necessary for effective
environmental management and improved performance.

Communication of the EMS Policy

Once management reaches agreement on the policy, it should be
documented, kept up-to-date, and used by all employees. Most organi-
zations already have procedures in place on how they communicate
their policies internally and externally (Figure 6-3, work step 2.4). The
EMS standard requires that the environmental policy of the organiza-
tion be made available to the public. Many organizations already
provide far more environmental information through P2 plans, annual
reports, regulatory records, and participation in emergency response
planning.

An EMS addresses the process for responding to external com-
munications or requests for environmental information. The organiza-
tion documents its procedure on “how to” respond to these external
requests for information on the EMS, environmental aspects, and P2, if
and when they occur. The basic documentation an organization should
keep for external requests includes who made the contact, the date,
the nature of the request, the nature of the response, and what, if any,
materials were sent.

The EMS requires the organization to develop and implement pro-
cedures to ensure internal communication of the EMS policy, respon-
sibilities, and results. The EMS and environmental “aspects” need to
be communicated to all internal levels of the organization and job func-
tions that could impact the environment. The internal communication
procedure specifies whose responsibility it will be to communicate
changes relating to the EMS and environmental aspects. Changes may
include environmental information, such as revised objectives and tar-
gets, changes in procedures, and environmental incidents or regula-
tory changes. Another internal communication “how to” is a process
for responding to employee requests and concerns related to the EMS
and P2. Internal communication should include discussions of general
and useful P2 opportunities that apply to all wastes and losses identi-
fied in the organization.

Chapter 6



A P2 program provides an
effective process for evaluat-
ing, planning, and controlling
changes to existing products
and the design of new products
that would generate less waste
in the production process and
at the end of their useful life.

Successful organizations
charge their P2 multifunction
teams with the responsibility
for creating high-quality prod-
ucts that are inexpensive to
manufacture while using fewer
toxic materials and generating
less waste.

The P2 feedback system
must be built on objective data
and analysis, all of which are
quantitative and can be
charted over time.

The information needs to be
comprehensive and timely
enough for all levels of workers
to understand the current
performance of the P2 pro-
gram.

38

Designing Quality and Prevention Together

By building quality into products and services in the production pro-
cess, an organization reduces the need to correct problems down-
stream. This mind-set leads to prevention rather than detection. A P2
program provides an effective process for evaluating, planning, and
controlling changes to existing products and the design of new prod-
ucts that would generate less waste in the production process and at
the end of their useful life.

For years, P2 technical assistance providers have recognized the
importance of design as a means of P2 progress through a concept
called “Design for Environment.” However, instead of handling this as a
separate initiative, the need for design changes must infuse all P2 ac-
tivities as a core value. Successful organizations charge their P2 mul-
tifunction teams with the responsibility for creating high-quality prod-
ucts that are inexpensive to manufacture while using fewer toxic mate-
rials and generating less waste. Whenever possible, these organiza-
tions involve key suppliers at an early stage of the new product devel-
opment in order to determine the types and constituents of wastes,
and to address potential health and safety issues. Many quality phi-
losophies work very well in P2 programs.

Long-Range Outlook

To achieve P2 goals, organizations must make long-term commit-
ments to all interested parties—customers, employees, suppliers, regu-
lators, shareholders, the public, and the community. To develop a long-
range outlook, an organization must anticipate many types of change,
including:

s by competitors

1 latory requirements
aoe

takehol der expectations
* Community expectations

Management by Fact

Many organizations rely on anecdotal information to indicate their
progress. In the P2 field, mountains of case histories feed this ten-
dency.

By contrast, management relies on specific, measurable data. The
P2 feedback system must be built on objective data and analysis, all of
which are quantitative and can be charted over time. Most of this infor-
mation can be gathered quite easily, with no need for sophisticated
statistical techniques. The information needs to be comprehensive and
timely enough for all levels of workers to understand the current perfor-
mance of the P2 program.

Chapter

CO)



CHAPTER 6

EMS Approach to P2
Implementation

INTRODUCTION

The new international voluntary standard for environmental man-
agement systems (EMSs) known as ISO 14001 is proving to be an
effective tool for improving organizational environmental performance
and implementing P2 opportunities. The intent of the standard is to
establish and maintain a systematic management plan designed to
continually identify and reduce the environmental impacts resulting from
an organization's activities, products, and services. Currently, no gov-
ernment mandate requires organizations to have a comprehensive
EMS, but several states are exploring the effectiveness of having orga-
nizations use an EMS in implementing and complying with P2 planning
requirements.

Government policymakers are interested in EMSs as a possible
way to supplement the so-called “command-and-control” environmental
regulations. The EPA recognizes that an EMS can help organizations
integrate environmental considerations into day-to-day decisions and
practices (References 6-1 and 6-2). EMSs will not replace existing
regulatory systems in the United States but will work best when they
complement the existing regulatory programs including formal enforce-
ment actions. Other EMSs are emerging, but the focus of this chapter
will be on the ISO 14001 standard’s elements.

For several years, the EPA has been engaged in a number of im-
portant activities designed both to promote and evaluate the effective-
ness of EMSs in a variety of settings. These activities vary widely and
include (1) a major EMS research program conducted in partnership
with states through the Multi-State Working Group (MSWG), (2) pro-
grams to promote and demonstrate the value of EMSs in various sec-
tors such as local government and metal finishing, and (3) the use of
EMSs as components of voluntary leadership programs. The EPA has
also used EMSs as important components in enforcement settlement
agreements. The MSWG has adopted a consensus policy document
to help guide states and others in designing EMSs, evaluating EMS
credibility, and participating in EMS processes (Reference 6-3). The
principles are as follo\

EMS Approach to P2 Implementati

Includes:

O Introduction

O Getting Started

0 Environmental Policy,
Management
Commitment, and Scope

O EMS Planning

O EMS Implementation

O Monitoring and
Measurement

O Lessons Learned

O References

O Supplemental Reading

The intent of the standard is to
establish and maintain a
systematic management plan
designed to continually iden-
tify and reduce the environ-
mental impacts resulting from
an organization’s activities,
products, and services.

The EPA recognizes that an
EMS can help organizations
integrate environmental
considerations into day-to-day
decisions and practices.

The MSWG has adopted a
consensus policy document
to help guide states and
others in designing EMSs,
evaluating EMS credibility,
and participating in EMS
processes.



Gathering accurate cost
information is important for
justifying investment in P2
alternatives.

cess work step. Spreadsheets can be linked to the objects in a com-
puterized process map, as well as to word processing files. Keeping
track of this information is useful for helping rank-order P2 opportuni-
ties by cost. This can all be accomplished using your organization’s
charting software.

Determining the Cost of the Loss

Gathering accurate cost information is important for justifying in-
vestment in P2 alternatives. This cost typically needs to be collected
by work step because this is where the P2 will be applied. There are
three types of costs that should be tracked:

"2." Cost of the lost resources.
3. Activity-based costs associated with the management of the
> “foin-product loss oe :

6 le

For each loss identified in the process map, the P2 team should
examine the “chart of accounts” to see if the cost is tracked by the
accounting department in the general ledger. For example, ifan organi-
zation generates solid waste, there may be a cost for the disposal
contractor in the general ledger. The chart of accounts provides a ven-
dor number and/or other code for this payment category. It is important
to remember that the general ledger typically tracks only money that
goes in and out of an organization (i.e., payment for invoices and pay-
roll and revenues or financial allocations). It does nottrack internal trans-
actions (e.g., environmental coordinator preparing a permit). These in-
ternal transactions are activity-based costs that will be discussed in
more detail below. All cost data obtained from the general ledger is
quite accurate and does not involve estimates of any kind.

Asecond cost category is associated with the cost of the resources
that become non-product outputs or process losses. For example, when
a part is spray painted, some of the paint does not end up on the part.
This overspray is probably captured on a paint filter in the ventilation
system. If 60% of the paint is incorporated on the part (i.e., interim
product in throughput), 40% of the paint is lost from the work step (i.e.,
non-product loss). The cost of this lost paint should be added to the
general ledger cost associated with this loss along with the cost of the
paint filters (i.e., the intent of purchasing the filters was only to dispose
of them after they captured droplets of paint, preventing these drops
from getting into the air handling/treatment system). The plastic bags
in the wastebaskets in your office represent a similar case. Your build-
ing management firm purchased those plastic bags intending to throw
them away, thereby making the custodian’s job easier. The cost of all
the bags that are purchased must be added to the cost of your solid
waste disposal bill along with the estimated cost of everything else that
you purchased and threw away in that wastebasket.

FOSS OHHOOOOSHOOSHOHHHHHOHOHOOOOHHHSHHHHSHHOOHHHHOHOHHSO


An EMS promotes important
planning and improvement
elements needed in the design
of multimedia source reduction
and recycling programs for all
forms of pollution.

The goal of the standard is to
establish a common approach
to EMSs that is internationally
recognized, leads to improved
environmental performance,
and provides an opportunity for
gaining international recogni-
tion and market share.

80

_ EMS mi roved environmental per-

formance, which may enable regulatory agencies to achieve
3 policy objectives more efficiently and improve communica-
tions with the public.

A growing number of organizations have pioneered new strategies
for integrating environmental management into their overall business
strategy. Although regulatory compliance remains an important driver
of environmental performance and of the adoption of advanced prac-
tices, business factors such as cost savings and improved business
performance are just as important. EMSs are motivating organizations
all over the world to reconsider their environmental performance and
effectiveness and determine how P2 strategies can help them reduce
wastes, risks, and costs. These organizations should establish and
maintain a systematic management plan that promotes P2 and is de-
signed to continually identify and reduce the environmental harm (im-
pacts) created by the organization's activities, products, and services.
The EMS fosters innovative strategies and a framework for improving
environmental performance by encouraging all the employees of the
organization to look for ways to reduce environmental impacts by first
using P2 techniques. Supporting information on EMSs can be found on
the CD-ROM that accompanies this Guide.

GETTING STARTED

Like other management systems, an EMS is a formal approach for
articulating goals, making choices, gathering information, measuring
progress, and improving performance. An EMS promotes important
planning and improvement elements needed in the design of multime-
dia source reduction and recycling programs for all forms of pollution.
Several elements of an EMS provide positive reinforcement for P2 as-
sessment and planning efforts and add an element for continual review
by management that is needed for implementation and improvement.
Figure 6-1 is a top-level process map for implementing P2 using an
EMS program.

The goal of the standard is to establish a common approach to
EMSs thatis internationally recognized, leads to improved environmental
performance, and provides an opportunity for gaining international rec-
ognition and market share. ISO 14001 is a management system stan-
dard, not a performance standard. Given that ISO 14001 is a system
built for industry by industry, it uses a language that management un-

Chap!

000 OOOOCOOOOHOOOOHOOOOOOOOOSOHOOOOHOHHOOHO8HH8HOKHNOEESS


party focus, leadership, and employee involvement. You should deter-
mine the gap that may exist between the more detailed questions that
get asked in the Green Zia program for each of these criteria and what
is currently going on in your organization. The Green Zia criteria ques-
tions can be found on the CD-ROM that comes with this publication.
Your gap analysis should also consider how to integrate the P2 pro-
gram into your core business practice using some combination of the
11 guiding principles. This step is very similar to the first step in the
traditional P2 approach discussed in Chapter 5.

The consideration of the quality model criteria shoud not only help
you make your plan more businesslike, but it should also help you bet-
ter meet the requirements of any P2 planning laws.

The leadership criterion helps you prepare the management P2
policy. This leadership examination will look at how senior leaders ac-
tually communicate and demonstrate their commitment to continual
environmental improvement and P2 to employees and to other inter-
ested parties.

The employee involvement criterion helps you prepare the employee
involvement, awareness, and training requirements. This effort looks
at how the organization prepares and involves employees in the devel-
opment and implementation of the P2 approaches. It also asks how
the employees’ value and well being are considered in these programs.

The strategic planning criterion addresses how the organization
will identify, develop, and implement long-term and short-term goals
and objectives for continual environmental improvement and P2 and
how these goals and objectives relate to the overall business objec-
tive.

Finally, the interested-party focus criterion determines how your
organization involves all interested parties in the development and imple-
mentation of your continual environmental improvement and P2 efforts.

In the next step (Figure 7-2, work step 1.2), the relevant processes
that occur within the organization are characterized using the process-
mapping tool in the Systems Approach. These maps will be used as
templates for gathering information on the process. This activity helps
you identify the production units that require further analysis.

During this work step, consideration of two other criteria is impor-
tant: process management and information analysis. Process man-
agement addresses how the organization will identify, analyze, and
manage all the processes that have the ability to impact the environ-
ment or cause injury to workers. Information analysis determines how
the organization selects, collects, and uses information to assess the
effectiveness of the program and make decisions on the basis of this
information.

Using a

The leadership criterion helps
you prepare the management
P2 policy.

The employee involvement
criterion helps you prepare the
employee involvement, aware-
ness, and training require-
ments.

The strategic planning criterion
addresses how the organiza-
tion will identify, develop, and
implement long-term and ~
short-term goals and objec-
tives for continual environ-
mental improvement and P2.

The interested-party focus
criterion determines how your
organization involves all
interested parties in the devel-
opment and implementation of
your continual environmental
improvement and P2 efforts.

Process management ad-
dresses how the organization
will identify, analyze, and
manage all the processes that
have the ability to impact the
environment or cause injury to
workers.



The P2 program is imple-
mented by preparing draft
action plans for all the alterna-
tives.

Typically, it is good to aim for
8 to 11 plans each year.

118

alternatives in the next step. Now, they are in a position to generate alter-
natives for realizing this opportunity by using a brainwriting tool (Figure
7-3, work step 2.3). Finally, they will select an alternative for implemen-
tation using a bubble-up/bubble-down tool (Figure 7-3, work step 2.4).
These interactive problem-solving and decision-making tools will help
the team gather the information needed for successful implementation
and communication with management and other interested parties.

Step 3. Implement Your Revised P2 Program

The P2 program is implemented (Figure 7-4) by preparing draft ac-
tion plans for all the alternatives studied in the previous step. These ac-
tion plans are the core of the P2 program each year and should be care-
fully reviewed before implementation. At this point, it is worthwhile to
reconsider the relevant items in the quality model that were evaluated in
the first step of the program (Figure 7-1). Recall that these criteria, as
well as the guiding principles, are carefully designed to help integrate
programs into core business practices. Constant effort to develop and
improve on these items will keep the P2 program moving towards zero
waste and emissions as a stretch goal. These criteria and guiding prin-
ciples can be reinforced in the action plans and in the revisions to the P2
plan itself.

A key point, given the work done in the previous step, is employee
involvement, awareness, and training. It has often been said “employ-
ees never resist their own ideas.” They can become important partners
in P2 when the Systems Approach is used in the program. Once all this
is done, final action plans are created for implementing each P2 alterna-
tive. Typically, it is good to aim for 8 to 11 plans each year. This goal
should not inhibit people from doing other P2 activities. The focus will be
on the main action plans in the program. The P2 plan will provide for
implementation that is subject to a P2 program oversight committee.
This group should be comprised of managers and should include the
organization’s senior manager. The action plans should be reviewed at

———»| _ IMPLEMENTP2 PROGRAM {|__»

Prepare Draft Action Plans
Consider Al Quality Model Criteria
Finalize Action Plans for Year (8-11 Plans)
Provide for Program Oversight

Provide for Program Auditing

Prepare Final P2 Program

Figure 7-4. Implement the Pollution Prevention Program.

Chapter T

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NE IE I I eee wr VV VV VV VVeVVEVeEVeEVUVUVEVeVeVeVUVeVVeVeVe Ve eo

consider the prevention of pollution, compliance with all legal re-
quirements, and continual improvement. Like P2, an EMS seeks to in-
tegrate environmental concerns into core business practices.

Quality Initiatives

Quality initiatives focus on preventing defects in processes, prod-
ucts, and services. These initiatives often declare a “war on waste.”
However, too few also consider air emissions, water discharges, solid
and hazardous wastes, and spills and leaks to be a waste. Organiza-
tions develop ISO 9000 programs to deal with quality. ISO 9000 pro-
grams are prepared in the same format as the ISO 14001 program.
Quality initiatives have evolved just as P2 has been defined and re-
fined. Many people have less than fond memories of certain manage-
ment fads like “Total Quality Management (TQM).” Despite the ap-
proaches and fads that cycle in and out, most organizations would agree
that quality refers to everything an organization does to provide goods
and services that meet customer requirements, the way that
organization’s employees interact together, and the organization’s ex-
pectations of its suppliers and other interested parties. Developers of
P2 programs should become familiar with the quality improvement ini-
tiatives in the organization.

Some organizations use the Baldrige criteria to judge their overall
operating performance. The Malcolm Baldrige National Quality Program
is the Presidential Award program in the United States (Reference 2-
5). These performance-based criteria are currently used in approxi-
mately 50 countries and 44 of the 50 states to help improve competi-
tiveness in both manufacturing and service businesses. An environ-
mental excellence program has been developed in New Mexico using
the Baldrige model. This Green Zia Program is used to rate organiza-
tional environmental programs that “go beyond mere compliance.” This
program (Reference 2-6) helps an organization establish core values
for its program and demonstrates how quality and P2 can be effectively
integrated. A set of criteria and a rigorous scoring system allow any
organization to track and search for trends in its continual improve-
ment using a unit-less score. This eliminates the need to “normalize”
for production. These concepts are covered in Chapter 7.

Preventive/Predictive Maintenance

Preventive and/or predictive maintenance is designed to keep ma-
chinery from breaking down. Unscheduled equipment downtime often
leads to the generation of wastes in organizations. There are a number
of Internet sites dedicated to the topic of preventive/predictive mainte-
nance (Reference 2-7). The principles from this field are applicable to
P2 programs.

Quality initiatives focus
on preventing defects in
processes, products, and
services.

The Baldrige criteria are
currently used in approxi-
mately 50 countries and 44 of
the 50 states to help improve
competitiveness in both
manufacturing and service
businesses.

Unscheduled equipment
downtime often leads to the
generation of wastes in organi-
Zations.



Waste management hierarchy, 21
Waste Minimization Opportunity Assessment Manual, 1, 9, 69
WBCSD (World Business Council for Sustainable Development), 22
Web Sites

American Chemistry Council’s Responsible Care, 47

ANSI-RAB information on registration, registrars, training and consulting, 100

Baldrige Quality Award Program, 119

Environmental Management System Demonstration Project, 100

Environmental Management System Primer for Federal Facilities, 100

EPA, 30

EPA Design for Environment, 19

EPA Environmental Accounting Project, 19

EPA Environmentally Preferable Purchasing (EPP), 100

EPA Environmental Performance Track, 100

EPA EPP Program, 19

EPA listing of State P2 programs, 30

EPA P2 Programs and Initiatives, 19

EPA Resource Exchange (P2Rx), 19

EPA Sustainable Industry, 19

Federal Register, 100

Green Zia manual, 47

Green Zia Program Information, 119

Maintenance Technology, 30

Mass environmental excellence paper, 47

MOEA's EPP, 100

Multi-State Working Group, 100

NIST Baldrige, 30

NIST MEP, 19

Nothing to Waste Manual, 67, 77

NPPR, 19

NPPR Position Paper on Facility Planning, 47

OSHA, 30

SBDC, 19

State P2 Programs, 19

Sustainable Measures, 47

Systems Approach tools, 119

United Nations, 30

World Business Council for Sustainable Development, 30
Weight vs. cost of loss, 58-59
Worker involvement, 26
Worker safety, 11-12, 26
Working capital, 75
World Business Council for Sustainable Development (WBCSD), 22
World Commission on Environment and Development, 23

Zz
Zero waste/zero emission, 10, 23-24, 37, 102, 117-118

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EXECUTIVE SUMMARY

An Organizational Guide to Pollution Prevention provides information to help organizations get P2
programs started or to re-evaluate existing P2 programs. It presents an alternative method for working on
P2 projects and four approaches to implementing a P2 program in an organization. This Guide was not
written to provide a “one-size-fits-all” formula for starting or improving a P2 Program. The intention is to
spark some ideas and provide tools that can be used to successfully complete an organization’s P2
mission. .

Also, the Guide is notintended to be an exhaustive review of case studies and company examples. It
does not include information on state P2 planning requirements. In order to keep this document a reason-
able length, these examples have been cited in the references section, and supplemental information is
provided on the CD-ROM that accompanies this Guide. There are many U.S. Environmental Protection
Agency (EPA) programs that support the practice of P2, including Environmental Accounting Project,
Design for Environment, P2 Resource Exchange, Environmentally Preferable Purchasing, Sustainable
Indust ry Project, Performance Track Program, and.other initiatives across the Agency. Internet links to
these programs and other information are provided on the CD-ROM.

An Organizational Guide to Pollution Prevention is organized into three basic sections:

ae Approach, "Quality Approach, and!
Finding Your Own Way to
Implement P2

3. Companion CD-ROM Supporting P2 Information

Sendnisnacaas si gsomatinte rt

The EPA acknowledges the efforts of the principal authors of this Guide—-Dr. Robert Pojasek (Presi-
dent, Pojasek & Associates) and Mr. Cam Metcalf (Executive Director, Kentucky Pollution Prevention Cen-
ter). This Guide was prepared in fulfillment of Contract Number 68-C7-0011, Work Assignment #3-20, by
Science Applications International Corporation, under the sponsorship of the EPA. Ms. Emma Lou George
was the EPA Project Officer. Ms. Lisa Kulujian served as the SAIC Project Manager.

E.1 Introduction to P2

P2 has evolved substantially in its first decade. In 1988, the EPA published the Waste Minimization
Opportunity Assessment Manual (EPA/625/7-88/003). This publication was revised and reissued in 1992
as the Facility Pollution Prevention Guide (EPA/600/R-92-088). Large numbers of these publications were
distributed in the United States and internationally, and the information was well.received. These publica-
tions have been included on the CD-ROM.

P2 programs provide many benefits to the organizations that use them. These include:



NN NSE eer rls seesaw eee Ve Ve Ve VeVVe VV Ve Ve VV Ve Ve Vee Ve eee Ue

ET ENTE

to Ask, About the Other - interested-Party

fit nental me
Work with customers to encourage effective product and environmental
ewardship?

Market “green” products, Services, ~and processes?

- Develop markets for new and/or “greener” products and services?
Involve suppliers, contractors, and vendors in the development and im-
provement of products, services, and processes as part of the con-
entalimprovement program?
uppliers, contractors, and vendors for their environmental.
performance? ~
‘Support the P2 or environment improvement efforts of suppliers, con-
sultants, contractors, and vendors?
+ Work with oversight agencies to manage compliance in a mutually bene-

a fighalfashion?. 2. eee ce seunee ee ren a

Communicate continual, environmental improvement goals and action
plans to interested parties to gain feedback, support, and buy-in?
Develop systematic processes for timely reporting of reportable events/
i activities to appropriate interested parties?

+ Work with oversight agencies to develop regulations and compliance

approaches that encourage P2?
+ Provide a regular, independent evaluation of successes made in the
program?
* Communicate results to interested parties?

P2 cannot be thought of as a strictly internal matter. It is becoming
much more important to consider other interested parties when con-
ducting a P2 program.

GUIDING PRINCIPLES

Unlike the traditional approach, the EMS- and quality-based ap-
proaches seek to align the P2 program with the organization's guiding
principles or core values. Many experts feel that guiding principles are
essential to the successful integration of P2 into core business prac-
tices. The guiding principles that are presented in Chapters 6 and 7 are
as follows:

Your Own Way to Implement Pi

P2 cannot be thought of as a
strictly internal matter. It is
becoming much more impor-
tant to consider other inter-
ested parties when conducting
a P2 program.



as orlversvesvevweewesvwerwerVwe Vee Ve Ve VV Ve VV Ve VV VV VV VV VV VE VV Vee VV VV Vee Ve Vee Vee Vee oO

Environmental manager, 26

Environmental policy, 83-84

Environmental protection, 12

Environmental Protection Agency
Design for Environment (DfE), 11, 19, 38, 97
Environmental Accounting Project, 19
Environmental Performance Track program, 83
pollution prevention definition, 21

EPA. See Environmental Protection Agency

EPP (environmentally preferred purchasing), 11

Evaluation. See assessment

External partnerships, 39, 110-111

F

Facility Pollution Prevention Guide, 1,9, 69

Fast response, 39-40, 109, 132

FDA (Food and Drug Administration), 14

Fishbone diagram, 17, 59-60

Food and Drug Administration (FDA), 14

Forced pair analysis (bubble up/bubble down), 17, 62-63, 116

G
Gap analysis audit, 81
Goal setting, 31, 34, 75
continual improvement, 37, 107-108
embedded goals, 107-108
EMS programs, 80-81, 126
Goals statement, 31, 34
Quality model, 126
traditional P2 approach, 12
Green Lights, 97 :
Green Zia Program, 5, 25, 76, 101, 102
Guiding principles of P2, 36, 106-112, 131-132
EMS programs, 96
quality-based program, 106-112
See also Core values

H
Hierarchical process maps, 41-42, 52-55, 114, 115

i]
Impediments to P2 use, 1, 13-15
Implementation, 26, 62-64
customizing for your organization, 121-133
EMS programs, 91~94
quality-based program, 118-119
revised P2 program, 116-117
traditional P2 program, 71-73, 76-77



partnership development, 110, 132
valuing employees, 108-109, 131-132
implementation, 116-117, 118-119, 124
improving the P2 plan, 112-118
developing opportunities, 115-116
implementing revised plan, 116-117
maintaining the program, 117
planning and development, 112-114
Malcolm Baldrige National Quality Award, 101
measuring progress, 117-118 :
model criteria, 102-106
employee involvement, 104
information analysis, 105
interested party involvement, 103-104
leadership, 103
process management, 104
results, 105
strategic planning, 103
public responsibility and citizenship, 111
strategic planning, 103
to implement P2, 118-119
Quick wins, 63, 72, 115

R
Rank ordering, 16, 58, 115
Recycling, 21, 22, 23
Registration of EMS, 91
Regulators, 39
Regulatory compliance, 9-10, 35
Regulatory issues as impediment to P2 use, 14
Regulatory permit monitoring, 95
Requirements for success, 27-28
Resource accounting, 55, 128
Resource conservation, 13, 23, 40
Resource Conservation and Recovery Act, 40
Response time, 40, 109, 132
Responsible Care Program, 3, 44, 97
Results focus, 111
EMS-based program, 126
Quality model, 126-127
traditional P2 program, 126
Reviews of P2 programs, 44, 95-96
Risk management, 26
Root cause analysis, 17, 59-60, 74-75, 116
cause and effect diagram, 59-60, 75
80/20 rule, 59, 115
fishbone diagram, 59-60

EEE IEE EE EE EE IE EE EEE Oo eerlselee leer CVs Owe eee VOCS



P2 programs are composed of
a number of program ele-
ments. Different organizations
often mix and match these
elements to construct a
program that meets the intent
of their P2 vision.

Top management support is
essential for ensuring that P2
becomes an organizational
goal.

products and services. Also, a faster and more flexible response to
interested parties is now a more critical requirement. Major improve-
ments in response time often require simplification of work units and
processes together with timely incorporation of P2 into the design phase
(e.g., design for environment). To accomplish this, the P2 performance
of work processes should be among the key process measures. Other
important benefits can be derived from this focus on time. Time im-
provements often drive simultaneous improvements in organization,
quality, P2, cost, and productivity. Hence, it is beneficial to integrate
response time, quality, P2, and productivity objectives.

SELECTING PROGRAM ELEMENTS

P2 programs are composed of a number of program elements.
Different organizations often mix and match these elements to con-
struct a program that meets the intent of their P2 vision. A number of
states have enacted P2 planning legislation. These acts contain a wide
variety of different planning components. More information can be found
on the CD-ROM that accompanies this Guide. In 1989, the EPA speci-
fied six program action elements that should be considered for organi-
zations seeking to prepare waste minimization programs as required
by the Resource Conservation and Recovery Act (RCRA). (See 54
Federal Register 25056-25057) This guidance was finalized on May
28, 1993 (58 Federal Register 31114-31120). All organizations gener-
ating hazardous waste in the United States must certify on their mani-
fest forms that they have a program in place that meets these require-
ments. These six program elements are:

hoy ass plia’| eked eben k RARE Het Eble
orm periodic assessments
F’4. Maintain a cost allocation system

= I RR

5. Encourage technology transfer
6. Conduct program evaluations

Let’s take a brief look at each of these elements. Keep in mind that
individual organizations may include additional elements in their P2 pro-
grams for their own purposes or to comply with state P2 planning re-
quirements. The number of elements used and the degree to which
each element is stressed should be a function of the group implement-
ing the P2 program in each organization.

1. Provide Top Management Support

Top management support is essential for ensuring that P2 becomes
an organizational goal. You will remember that leadership is consid-
ered to be an important core value. Most articles written on quality
programs list upper-level management support as the single most im-



Chapter 6: EMS Approach to P2 Implementation 79
Introduction 79
Getting Started 80
Environmental Policy, Management Commitment, and Scope of the EMS 83
EMS Planning . 85
EMS Implementation 91
EMS Monitoring and Measurement 94
Lessons Learned 96

Chapter 7: Using a Quality Mode! to Implement P2 103
Introduction 103
Seven Quality Model Criteria 104
The 11 Quality Model Guiding Principles 108
Five-step Process to Improve Your P2 Plan 114
Using the Quality Model to Implement P2 -120

Chapter 8: Finding Your Own Way to Implement P2 123
Introduction 123
Extent of Planning . 123
Leadership ~ 126
Setting P2 Goals 128
Focus on Results 128
Information and Analysis 129
Process Management 130
Employee Participation . 131
Focus on Interested Parties 132
Guiding Principles 133
P2 Program Elements 134
Now It's Your Turn 135

Index 137

SPCOSOGOSSSHOSSSSSHSOSOSHSSSEHISSOHHHLHHSHHSHOHHHEHHHHHOHHOO


Goals can be defined in action
plans prepared to help imple-
ment the P2 program.

34

actiog or Supporting research on the
effects of products, processes,

created b past hand ing —

fes with government and others to create responsible laws,
rkplace,

fes the principles and practices of Responsible Care by shar-

Stienices and offering assisiance to others Whi

rere rn

ublic, that we will conduct our business with
é environment. We will implemen “
= gies that build successful businesses and a :
= for all our stak

_ We will l continuously i improve our practices in light of advances i in

- w unders' ealth and environmental

science. We will make consistent, measurable progress in implement-

ing this Commitment throughout our worldwide operations. DuPont sup-

ports the chemical industry's Responsible Care® and the oil industry's

Strategies for Today’s Environmental Partnership as key programs to
achieve this Commitment.

Reference: http:/Awww.dupont.com/corp/environment/commitment.html

Statement of Goals

The third basic component of a P2 plan is the statement of goals.
Goals are specific statements that express where the organization
wishes to go within a specific time period (e.g., this financial quarter).
The quantitative measures used are absolute. Goals can be defined in
action plans prepared to help implement the P2 program. Action plans
are discussed in Chapter 4. Setting goals and objectives in a P2 pro-
gram are also addressed in Chapter 6.

Many P2 programs state quantitative and specific goals of both a
short-term and long-term nature. Sometimes the goals are set during
the initial planning period of the P2 program. In other cases, the goals
are to be set after much more information has been gathered and ana-
lyzed. Once the goals are set, it is important to measure their progress
over time.

Some quality experts feel that goals actually tend to hold an organi-
zation back because no one ever tries to exceed the goals by a signifi-
cant amount. These people have suggested that organizations con-
stantly measure their continual improvement effort in specific areas.

Chapter 3

OOOO OO OOOO OOHOOOHOOHHHOOHOHOSHOOHHHHOHHHHHHHHHOHOHOHOOO



FIVE-STEP

PROCESS

1. Plan and develop your P2

program.

2. Develop your organization’s
P2 opportunities.
3. Implement your revised P2

plan.

4. Maintain your P2 program.
&. Measure your progress
toward zero waste and zero

bine these quality model items by reading the Green Zia and Baldrige
information on the CD-ROM. Let us now see how these items can be
incorporated into a P2 Plan.

FIVE-STEP PROCESS TO IMPROVE YOUR P2 PLAN

Let's examine a simple five-step process that utilizes the quality
model and the Systems Approach tools presented in the first four chap-
ters of this guide. This process should help you integrate your P2 plan
into your organization’s core practices. These steps are as follows:

sa ied enesta ce aa

jaintain your P2 program. ;
5. Measure your progress toward zero waste and” .
. emissions. .

emissions. This five-step process is presented as a top-level process map in Fig-
ure 7-1. Each of these steps will be described in the following sections.
You can follow along with the various process maps that were pre-
pared to illustrate the points made in the text.

PLAN AND DEVELOP DEVELOP P2 ee IMPLEMENT P2 Ly
P2 PROGRAM OPPORTUNITIES PROGRAM
1 2 3
MEASURE PROGRESS
MAINTAIN P2 TOWARD
—| PROGRAM ENVIRONMENTAL
EXCELLENCE

Figure 7-1. Top-level Depiction of Quality Model Approach to Pollution Prevention

114

Implementation.

Step 1. Plan and Develop Your P2 Program

The first step in preparing a P2 program (Figure 7-2, work step
1.1) is to determine the elements of the quality model that will be ad-
dressed in the P2 planning effort. Four of the seven criteria covered in
this chapter are addressed in this step: strategic planning, interested-



Continual improvement. Successful implementation of a P2 program
can be an integral part of a company’s continual improvement or quality
improvement program. Reducing wastes and improving efficiency are
goals of both P2 and continual improvement. Many organizations use
continual improvement to constantly change certain work processes in
order to improve them. To clarify the use of the term “continual im-
provement,” the following distinction is made:

ontinuous improvement—happening all the time. everything |
wing forwal at once; ; often used in qual ity programs.

“Continual improvement—happening all the time, but not 8 every- |

thing moving forward at the same time and rate; often used by auditors ‘

. of Environmental Management Systems and in other environmental
programs.”

The term continual improvement is used throughout this text.

Resource conservation, P2 will lead to the use of less energy and
water. All resources, materials use, and waste reduction can be moni-
tored in the same program. Traditionally, most organizations had sepa-
rate programs (e.g., water conservation or energy efficiency) for re-
source conservation and P2. However, these programs are related in
many ways; both are necessary to improve efficiency and to meet the
organization’s goal of sustainability.

Enhanced public image. P2 can help an organization gain a favorable
image with the community by showing that they are willing to make
changes to improve the environment and move towards sustainability.
Some organizations have used their “green” image to successfully dis-
tinguish themselves in the marketplace, thus adding to their intangible
goodwill market value.

IMPEDIMENTS TO P2 USE

Anumber of impediments commonly hinder successful implemen-
tation of a P2 program. It is important to recognize these impediments
and address each of them during implementation. Management's com-
mitment to addressing these issues is a key element of the success of
the P2 program.

fondfeguiatory i issues oe
_ Product, quality | issues

ptance

production concerns

ization i image concerns

_ *. Available time/technical expertise
° Inertia

Successful implementation of
a P2 program can be an
integral part of a company’s
continual improvement or
quality improvement program.

P2 will lead to the use of less
energy and water.





eee eee eer ee Ve Ve VV SVE Ve Ve Ve Vee Ve VeVe Vee eee Vee Vee Vee Vee VU ee So

ABSTRACT

This Pollution Prevention (P2) Guide provides information to help organizations get P2 programs
started or to re-evaluate existing P2 programs. It presents an alternative method for working on P2 projects
and four approaches to implementing a P2 program in an organization. This Guide was not written to
provide a “one-size-fits-all” formula for starting or improving a P2 Program. The intention is to spark some
ideas and provide tools that can be used to successfully complete an organization’s P2 mission.

Also, the Guide is not intended to be an exhaustive. review of case studies and company examples. It
does not include information on state P2 planning requirements. In order to keep this document a reason-
able length, these examples have been cited in the references section, and supplemental information is
provided on the CD-ROM that accompanies this Guide. There are many U.S. Environmental Protection
Agency (EPA) programs that support the practice of P2, including Environmental Accounting Project,
Design for Environment, P2 Resource Exchange, Environmentally Preferable Purchasing, Sustainable
Industry Project, Performance Track Program, and other initiatives across the Agency. Internet links to
these programs and other information are provided on the CD-ROM. :

An Organizational Guide to Pollution Prevention is organized into three basic sections:

1. Basic P2 Concepts and Tools (Chapters 1-4) ~~ Introduction to P2, Getting
: Started, P2 Program Elements,

and P2 Tools

2. P2 Program Implementation Approaches (Chapters 5-8) Traditional Approach, EMS

: .Approach, Quality Approach, and

Finding Your Own Way to
Implement P2

3. Companion CD-ROM Supporting P2 Information

The EPA acknowledges the efforts of the principal authors of this Guide—-Dr. Robert Pojasek (Presi-
dent, Pojasek & Associates) and Mr. Cam Metcalf (Executive Director, Kentucky Pollution Prevention Cen-
ter). This Guide was prepared in fulfillment of Contract Number 68-C7-0011, Work Assignment #3-20, by
Science Applications International Corporation, under the sponsorship of the EPA. Ms. Emma Lou George
was the EPA Project Officer.



It is important that P2 activities
not be restricted to the envi-
ronmental professionals in an
organization.

All the implementation models
presented require a policy
statement that is endorsed by
the top management of the
organization.

Leadership is encouraged in
the quality-based P2 approach
by recognizing the importance
of both senior leadership and
community leadership.

126

The final aspect of the quality- and EMS-based P2 approaches is
the actual integration and implementation of P2 activities with other
organizational programs. It is important that P2 activities not be re-
stricted to the environmental professionals in an organization. Employee
teams from different departments need to be involved. The oversight
committee should be composed of senior managers representing dif-
ferent functions within the organization. Whenever possible, it is pru-
dent to look at their planned activities to see which ones have potential
for P2 involvement. In this manner, the planned integration will be much
more effective.

An emphasis on planning is important no matter which approach
your organization uses. Although your organization may choose not to
have planning dominate your P2 program’s implementation, you should
seek to improve your planning efforts each year by asking the ques-
tions provided and enhancing the program incrementally. Your organi-
zation could gradually increase the level of planning by answering those
questions. In this manner, your organization will be integrating the P2
program into the core business practices.

LEADERSHIP

All the implementation models presented require a policy state-
ment that is endorsed by the top management of the organization. Some
important differences exist, however.

In the traditional approach, a “top-down” focus was encouraged.
Management approval was sought before the P2 program was started.
This commitment to the program was communicated to the workforce
using the policy statement. Management names the P2 task force. Al-
though management often saw P2 reports and success stories, this
information loop sometimes did not provide for strong support for con-
tinual improvement.

The EMS-based Implementation Approach also seeks to have top
management periodically review EMS implementation and effective-
ness. Experience has shown clearly that program success is largely
dependent on maintaining the involvement of senior management. The
EMS is a management system that allows organizations to address
the environmental issues in a systematic, organized fashion based on
continual improvement—just like any other area of the organization.
The EMS approach described in this Guide focuses on all manage-
ment issues, including attainment of objectives, completion of correc-
tive actions, effectiveness of policy, and cost-driven targets.

Leadership is encouraged in the quality-based P2 approach by rec-
ognizing the importance of both senior leadership and community lead-



The Green Zia model has all
the essential ingredients that
make a zero waste vision
possible.

104

Using this quality model, the stretch goal can be set at zero—zero
defects, zero inventory, zero equipment breakdowns, and zero waste.
Many organizations are now extending the zero concept to EHS pro-
grams—zero incidents, zero accidents, zero wastes, Zero emissions,
and zero drain on world resources (sustainability). P2 is a major driv-
ing force in the quest for zero waste and zero emissions.

The Green Zia model has all the essential ingredients that make a
zero waste vision possible. First, it has criteria that define “best in class”
so each organization can measure progress towards excellence. Sec-
ond, it has a set of guiding principles (or core values) that must be
present in order to integrate the criteria throughout the program. Third,
it has a rigorous scoring system that is used by trained examiners to
provide a score that represents the current state of the environmental
excellence program on a 1000-point scale. Fourth, the examiners is-
sue a feedback report detailing the strengths and weaknesses of an
organization's excellence program against the criteria and guiding prin-
ciples. The scoring system and the feedback reports-are important
tools for organizations to use in their environmental excellence pro-
grams. Organizations seek excellence, in their own way, using this
model by selecting the performance elements for improvement and
determining how to leverage these efforts in the organization. The P2
plan‘is often used to drive the program.

This chapter will first look at the criteria contained in this quality
model. Next, the quality model's guiding principles will be discussed.
Finally, a five-step process will be presented to show how this quality
information can be integrated with the Systems Approach presented in
the first four chapters of this Guide. You can find more readings on this
topic in the reference section at the end of the chapter and on the CD-
ROM that accompanies this Guide.

SEVEN QUALITY MODEL CRITERIA

When implementing a P2 program, it is important to keep your eye
on what is important. Based on years of quality management experi-
ence, this boils down to seven criteria:

‘4.
- 5. Process management
.6._ Information analysis
7, Results

These criteria form the basis for the Green Zia program and will be

used in the quality model presented in this chapter. Within each of these
criteria, you will need to address how you are working to integrate P2

| i : Chapter 7



such as the effectiveness of the alternative, the ability to implement
the technique, and the cost associated with that implementation. This
method of discussing the various alternatives is very interactive. Other
tools do not allow for a lot of verbal communication among P2 team
members. This communication leads to more information that will ulti-
mately help facilitate implementation of the selected alternative.

Alternatives that “bubble up’ to the top are typically easy to imple-
ment and have a relatively low cost. These alternatives may be charac-
terized as the low hanging fruit or quick wins. Little or no capital is re-
quired to implement these alternatives and work can begin right away
in most cases. If good cost data is collected, these “quick wins” can
generate savings that can be reinvested by the organization to create
more prevention and value. Alternatives that currently fall below the
grouping of quick wins are generally more effective at preventing re-
source use and process losses. However, they may require more study
and capital investments. Since it will take time to test and study these
alternatives in an engineering feasibility study (See Waste Minimiza-
tion Opportunity Assessment Manual, EPA/625/7-88/003 and Facility
Pollution Prevention Guide, EPA/600/R-92/088 on the CD-ROM for more
information on conducting a feasibility study), the P2 team can be work-
ing on the problem with the higher ranked, albeit less effective, alterna-
tives. The results of the feasibility study will be useful for preparing a
capital justification request to use the more effective alternative at a

later time. Continual improvement can be maintained in a P2 program
in this way.

The alternatives, in order of priority, are as follows:

4. Simply reduce the soap input in the car wash
2. Use high-pressure water instead of soap
3. Alter the soap application step
4. Use degradable soap
5. Install a closed-loop system .
6. Use alternative cleaning materials
7. Use a local, off-base car wash
8. Use rental cars instead of owning/maintaining
9. Locally treat the water before discharge to sewer
10. Drive less, walk more, use bicycles
11. Reuse dirty/soapy water
12. Install a new/improved car wash
13. Use a softening agent to take the soap out
of the water
14. Handwash the cars
15. Use ultrafiltration to filter the water
16. Dry-clean the cars
17. Ultrasonic cleaning
418. Ablative paint for cars
19. Use dirt-colored cars
20. Paint the cars with slippery paint
21. Do not clean the cars at all
22. Buy new cars constantly

. Figure 4-8. Bubble-up/Bubble-down Example.

EE LL EE I TLE SL IES el rlCcT rl Oo orrrevseeverelereelereeewerewee er Ve Ve VV Ve Ve VS Ve VV Ve Ve VV Ve VVeVeVSe VY Vo



through 4 will take place within that program. While Steps 1 through 4
apply to many organizations, P2 program management (Step 5) must
be designed to fit the culture of the organization using P2. The organi-
zation must provide training for the people participating in the program.
There must be understandable policies and a management commit-
ment. Relationships to other organizational programs must be clearly
defined. Oversight for the P2 program can be provided in the form of
program audits, by both internal and third parties. Finally, there must be
a way to measure progress and evaluate the effectiveness of the P2
program. Some information that enables organizations to adapt the
program management to their own culture is provided in Chapters 5
through 7.

P2 program management
must be designed to fit the
culture of the organization
using P2.

ORGANIZATION OF THIS GUIDE

This Guide will provide information to help organizations get their
P2 programs started or to help re-evaluate existing P2 programs. Chap-
ter 2 provides some advice on how to get started with the P2 program
process. The planning of the P2 program is covered in Chapter 3 and
is discussed along with some planning elements that should be ad-
dressed. Most P2 programs can use tools (discussed in Chapter 4) to
facilitate communication within the organization and between organi-
zations. Tools that support the five-step model described previously
are presented in Chapter 4. These tools can also be used in all of the
implementation models covered in this Guide. Several models are pre-
sented to help in implementing the P2 program. A traditional P2 imple-
mentation model is presented in Chapter 5. It can be used with or
without the tools presented in this Guide. Also presented is a version
of this model called “Nothing to Waste” that is particularly useful to
small organizations. Chapter 6 shows how an environmental man-
agement system (EMS) may be used to implement a P2 program.
Chapter 7 presents a quality model that can be used to implement a
P2 program. Chapter 8, the final chapter, examines how individuals
can design and implement their own P2 programs from the materials
presented in this Guide.

A companion CD-ROM is included to provide supporting informa-
tion on all of these topics and additional information that may be re-
quired to plan and implement a P2 program for your organization. All of
the referenced material is accessible through the CD-ROM. The fol-
lowing information is provided on the CD-ROM:

a
1
\y

P2 Implemen ation
pportP2 Implementation *

s

: Chapter 1

CSOSOOSSOHOESEHSHHHOHOHESOHHOLCHSHOOHHSHHHHHHHHHHHHHHHHHHHOO


INDEX
A .
Accounting procedures, 43
Action plans, 17, 64
EMS environmental management programs, 90-91
quality-based program, 116-117, 122-123
traditional P2 program, 71
Alternatives for P2 problem, 72
brainstorming, 61
brainwriting, 61-62
bubble-up/bubble-down, 62-63
criteria matrix, 62-63 .
forced pair analysis, 62-63 —
generating, 61-62
provocation technique, 62
selecting alternative for implementation, 62-64
selection grid, 62
American Chemistry Council (ACC), 3, 44
Analysis
cost and benefit, 42
forced pair, 17, 62-63, 116
information, 38-39, 105, 114, 115, 127-128
objective gap, 81
Pareto, 57-58, 70, 115
production unit, 115-116
root cause, 17, 59-60, 74-75, 116
Aspect identification, 87
Aspects, 86-87, 97
Assessment
environmental performance, 93-94, 111
need for objective data and analysis, 38-39
P2 opportunities, 41-42
periodic updates, 42, 45, 64, 132-133
program, 44
in traditional P2 program, 70, 71-72
use of checklists, 65-66
Audits
compliance, 82, 95
gap analysis, 81

B
Baldrige criteria, 25
BAT (best available technology), 82

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These P2 tools are derived from quality programs and are widely used throughout the world. The
application of the quality improvement tools used in the Systems Approach is a powerful force in eliminat-
ing environmental inefficiencies and preventing pollution.

The P2 tools are:

source accounting using
on of P2 opportunities using a Pareto
alysis of the root cause of the problem using a cause-and-effect diagram
“Generation of alternative solutions using brainwriting
Selection of an alternative for implementation using bubble-up/bubble-down
Implementation of the alternative using an action plan

Checklists are also useful to help the P2 teams review the process and ensure that their work is
complete.

Tools take time to master, but they help foster skills that the P2 team needs to characterize the pro-
cess, solve problems, and make decisions. Making P2 a way of life takes more than words; it requires
action. Action plans provide documentation for accomplishing the goals decided upon by using the tools.
It makes it easier to track P2 progress over time.

E.5 Traditional Approach to P2 Implementation

The P2 approach provided in the previous EPA publications is presented along with process maps
depicting each of the steps. This traditional approach has a “top-down” focus. It starts with getting man-
agement approval with pre-set program goals. This is communicated to the workforce using a policy
statement. A P2 task force is organized and conducts a preliminary P2 assessment.

From this information, a P2 program plan is prepared with clear objectives and a firm schedule. Now
a detailed P2 assessment is conducted to start the implementation phase. Checklists and worksheets
are provided to help the team collect data and information. This assessment team will review the data and
visit the sites where the P2 activity is planned to take place.

The team will derive P2 options (called alternatives in this Guide) and screen them with a criteria
matrix. A feasibility analysis is performed to make’a final determination based on technical, environmental,
and economic factors. At this point, the traditional approach requires the preparation of a formal, written
P2 assessment report to present the analysis to management for a decision.

Once the work begins, it is reviewed and adjusted to make sure it meets the objectives. The final step
in the traditional program is to measure P2 progress. Data is acquired from the implementation phase and
analyzed.

Previous P2 publications provide guidance on how to maintain the P2 program. Five activities are
detailed as follows: .

rating

Providing the proper amount of F
Communicating and Soliciting 0
* _ Providing for proper incentives for participating
* Implementing public outreach and education

ive Summary



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Technology transfer is very important to the propagation of P2. The
Baldrige program requires winners of the award to go out and speak
about what it takes to be successful with this program. Many winners
give more than 100 speeches the year after they win. The EMS ap-
proach encourages organizations to mentor suppliers and contractors.
Both approaches willingly share their successes so others can follow.

NOW IT’S YOUR TURN

This Guide has presented a number of useful P2 implementation
approaches. It is up to your organization to use them and get started
with a program that will work in your organization. The CD-ROM will
provide you with the information needed to move forward.

This Guide was not written to provide a “one-size-fits-all” formula
for starting or improving a P2 program. Its intention is to spark some

ideas and provide tools that you can use to successfully complete your
organization’s mission.

i Own Way to Implement P2



Allithree of these terms—pollution prevention, cleaner production,
and eco-efficiency—addres:

: Elimination of process losses at the source without resorting
to end-of-pipe pollution control devices. .
Conservatioi including energy, materials
and water) that are used in the process or operation.

There are also some differences between these terms. For ex-
ample, eco-efficiency looks at maximizing the sustainable use of re-
newable resources while cleaner production focuses on the more
efficient use of natural resources. P2 looks at the protection of natural
resources by conservation. All of the definitions address hazards to
public health and the environment and seek to reduce toxic emissions
and the use of toxic raw materials. However, only cleaner production
addresses the need to consider whether there is a shift in risk from the
environment to worker safety as a result of changes made in the pro-
cess.

Eco-efficiency and cleaner production address processes, prod-
ucts, services, and life cycle issues. P2 considers “in-process recy-
cling” while eco-efficiency considers “enhancing material recyclability.”

The authors use the term P2 throughout this Guide. However, you
can choose to add elements of cleaner production and/or eco-efficiency
to your program if you wish to do so. The definitions of these terms are
provided to help you see what is possible. There are organizations al-
ready incorporating many of these additional items into their P2 pro-
grams. P2 can be defined more broadly than EPA originally intended.

SUSTAINABLE DEVELOPMENT

P2 plays an important role where the goal is sustainable develop-
ment. There are many definitions of sustainable development. The fol-
lowing definitions provide broad and operational perspectives to cover
the range of components that are commonly included under the
sustainability umbrella. According to the World Commission on Envi-
ronment and Development, “sustainable development is a process of
change in which the exploitation of resources, the direction of invest-
ments, the orientation of technological development, and institutional
change are all in harmony and enhance both current and future poten-
tial to meet human needs and aspirations.” An operational definition of
sustainable development is “Good stewardship of natural resources
such that long-term productivity may be maintained or improved with
minimal, if any, adverse impacts on the environment and worker health
and safety.”

lf your organization is interested in a sustainable development goal,
it is important to consider setting a goal of zero waste or zero emis-

Started

Consider whether there is a
shift in risk from the environ-
ment to worker safety as a
result of changes made in the
process.

The authors use the term P2
throughout this Guide. However,
you can choose to add ele-
ments of cleaner production
and/or eco-efficiency to your
program if you wish to do so.

P2 can be defined more
broadly than EPA originally
intended.

P2 plays an important role
where the goal is sustainable
development.

Consider setting a goal of zero
waste or zero emissions.

23



Records document that the organization is doing what it said it

would, and they include forms, labels, tags, logbooks, and correspon-

dences. Important record system questions are the followin:

> ©. How will récords be filed’?
® How will records be disposed (recycled)?

EMS OPERATIONAL oHecrine n>
IMPLEMENTATION CONTROL ihe i
4A 42 43
Documentation Develop Procedures for Activities Investigate Nonconformances
Document Control Stipulate Operating Criteria Determine Root Causes

Implement and Review Corrective
Actions

Preventive and Corrective Maintenance

Figure 6-5. Implementation of the EMS.

Implementation of operational
controls is the “do” part of the
EMS cycle of “plan, do, check,
review."

The important step for opera-
tional control is identifying
activities and employee job
functions that can have a
potential or actual impact on
the environment.

Good operational control for
P2 is defined as a procedure
or process within an organiza-
tion that reduces multimedia
wastes and conserves natural
resources.

92

Operational Control

Implementation of operational controls is the “do” part of the EMS
cycle of “plan, do, check, review” (Figure 6-5, work step 4.2). Proce-
dures are instructions used by the organization for environmental sys-
tem activities such as P2. They define the details of who, what, when,
where, and why in the EMS activities and include some generic “how
to’s.” This is where most organizations expend the most effort while
implementing an EMS. Because procedures are extremely important,
the organization will benefit from determining which procedures to docu-
ment and how to best write them for guidance and training. Written
procedures are an essential element of operational control if the ab-
sence of these procedures could lead to deviations from the environ-
mental policy, objectives, and targets.

The important step for operational control is identifying activities
and employee job functions that can have a potential or actual impact
on the environment. Operational controls established for significant
environmental impacts help the organization determine the roles, re-
sponsibilities, and authorities needed to ensure performance. You stipu-
late operating criteria for employees in these improved standard pro-
cedures. Large amounts of waste may be generated through improper
storage practices, inefficient production start-up or shutdown, sched-
uling problems, lack of preventive maintenance, or poorly calibrated
devices for pollution control. Good operational control for P2 is defined
as a procedure or process within an organization that reduces multi-
media wastes and conserves natural resources.

Chapter 6

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process design

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Bt. Results focus
£ 12. Prevention of pollution
“43, Compliance with legal requirements

The guiding principles are used to drive the P2 program’s objectives
and targets.

P2 PROGRAM ELEMENTS

The six program elements for a P2 program using any of the ap-
proaches have a number of now-familiar items:

erform n_periodic assessments

ecg emcee | ° ve ae d

Conduct program evaluations

Each of these items is covered in the implementation chapters
(Chapters 5-8).

Two crucial program elements require consideration as you de-
velop or seek to improve the P2 program. These are:

The importance of communicating with top management in finan-
cial terms is quite clear. It is important to determine the real cost of all
resource use and loss in the process (including all ancillary and inter-
mittent processes). It is important to translate environmental perfor-
mance measured in volume and weight into financial terms. Some basic
information on this topic can be found in Chapter 4. Additional material
on this and on EPA’s Environmental Accounting Project is available on
the CD-ROM. The quality-based P2 approach scores the ability to evalu-
ate costs effectively. In most cases, this evaluation is required to get
and maintain top management approval for the program.



IDENTIFY IDENTIFY
ASPECTS AND OBJECTIVES
EMS PLANNING SIGNIFICANT AND >
IMPACTS TARGETS
3.41 3.2 3.3
Develop Organizational Structure Use Tools to ID Aspects ‘Set Attainable and Measurable Goals
Appoint Management Representative Identify Legal and Other Requirements Ensure Goals Are Realistic
Practice Team Approach Develop Criteria for Significant Consider Interested Party Views
Identify Resources Aspects and Impacts
EST)
EMS TRAINING ENVIRONMENTAL
RESPONSIBILITIES \GEMENT
PROGRAM)
3.4
Consider Types of Training Write a Plan

Provide Ownership and Responsibility

Detail How Goals Will Be Attained with Time Frames
Ensure New Products and Services Are Environmentally Friendly

Figure 6-4. Planning in the EMS.

EMS PLANNING

As an organization grows and as product lines change, planning is
necessary. Planning for P2 should go hand in hand with any business
planning effort (Figure 6-4, work step 3.1). Unfocused, ill-timed, or poorly
managed P2 efforts will lead to low performance and high cost. Con-
versely, a well-conceived and effectively implemented P2 program leads
to high performance and reduced costs. Improved environmental per-
formance is an important benefit for most organizations undertaking
EMS development and implementation. Although some organizations
have comprehensive EMSs that systematically track environmentally
relevant activities, many do not. An EMS includes organizational struc-
ture, responsibilities, practices, procedures, processes, and resources
for implementing effective environmental management.

Top management appoints a management representative or rep-
resentatives to ensure the organization accomplishes its goals when
establishing an EMS. The management representative monitors and
evaluates the system and reporis to top management on the EMS’s
effectiveness. The coordinator(s) works with organizational teams to
generate new ideas and modify the EMS when necessary for improve-
ment. The organization could create an environment and select a fo-
rum in which creative ideas can be heard and tried.

Most organizations choose to meet in teams to discuss production
and wastes and develop questions for needed checklists. Teams are
used to multiply the strength of the organization. The team approach

As an organization grows and
as product lines change,
planning is necessary. Plan-
ning for P2 should go hand in
hand with any business plan-
ning effort.

The management representa-
tive monitors and evaluates
the system and reports to top
management on the EMS’s
effectiveness.

Teams are used to multiply
the strength of the organiza-
tion. The team approach
allows for discussion and
comparison of differences.



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P2 practitioners found this approach to be useful for very small organizations. Another method, cafled
Nothing to Waste, has also been shown to be very effective with very small organizations and uses the
tools presented in Chapter 4.

E.6 EMS Approach to P2 Implementation

The international voluntary standard for environmental management systems (Ems), known as ISO
14001, is an effective tool for implementing P2 alternatives. It is the intent of this standard to establish and
maintain a systematic management plan designed to continually identify and reduce the environmental
impacts resulting from an organization’s activities, products, and services. An EMS promotes important
planning and improvement elements needed in the design of multimedia source reduction and recycling
programs.

As an initial step in developing a comprehensive EMSs, most organizations find it helpful to complete an
objective gap analysis of their existing environmental system. This enables the organization to compare its
systems against ISO 14001 and highlight areas that require attention under the EMS development phase.

The preparation of the EMS includes the following steps:

Pp ag
Communication of the EMS. policy|
« EMS planning
EMS implementation 4
& ¢* Monitoring and measurement

An EMS establishes specific objectives, targets, and time frames for implementing P2 initiatives, im-
proving environmental performance, and maintaining compliance, including compliance with state P2 plan-
ning requirements. Environmental management programs (EMP) are used to achieve the EMS objectives
and targets.

Organizations are discovering that their investment in an EMS is leading to improved environmental
performance and compliance with benefits for the environment and the community. An EMS provides a
good method for establishing and implementing a P2 program. To achieve maximum environmental bene-
fits, the EMS should embody the “plan, do, check, and act” model for continual improvement.

E.7 Using a Quality Model to Implement P2

P2 results are the outcomes of the performance of the P2 program and not a measure of the perfor-
mance itself. Furthermore, P2 results by themselves offer little diagnostic value. They do. not indicate

whether an organization could have done better or if they really exceeded expectations. A model that - ;

focuses on measuring performance has been developed in the United States and is known as the Malcolm
Baldrige National Quality Award. It measures six performance categories (i.e., leadership, strategic plan-
ning, other interested party involvement, information and analysis, employee participation, and process
management). A seventh category captures the results. The Green Zia Program (New Mexico Environ-
ment Department) has adapted this quality model to measure environmental excellence. From the per-
spective of the organizations using this model, it is a prevention-focused, performance-driven EMS. Per-
formance can be measured on a 1,000-point scale. This is a unit-less number and does not need to be
normalized like other environmental metrics. Results are measured in three parts: environmental results,
results of the interested party involvement, and financial results.



Another company set up four EMPs for dealing with (1) all regulated
aspects, (2) solid waste, (3) energy usage, and (4) PCB elimination.
Finally, one company’s EMPs were developed largely at the depart-
mental level. The EMP(s) and objectives are reviewed by the team when
changes occur in the organization’s operations. When objectives and
targets are not met, corrective actions are identified and taken.

As progress is made, it should be recorded against the EMPs cre-
ated. Some questions and progress can be measured quantitatively.
Other questions are more subjective, but progress can still be mea-
sured. The purpose is to monitor progress on currently active EMPs
and watch for slippage on implemented activities. As with any imple-
mentation review, the questions to ask are the following

tion back on schedule? woe
—...¢ . What issues need to be resolved to continue our
progress?

EMS IMPLEMENTATION

At present, there is a clear need for careful evaluation of how an
EMS will influence an organization’s environmental effectiveness. This
evaluation will facilitate more informed decision-making about how best
to incorporate an EMS approach into existing environmental regulatory
programs and P2 planning. At this point, many organizations already
have sophisticated EMSs in place and perceive little customer demand
or regulatory advantage to seek full registration. Many are aligning with
the standard, however, and are aware that third-party auditing may be-
come necessary in the future.

Most organizations already have regulatory and P2 procedures in-
cluding work instructions, batch sheets, training records, testing and
monitoring results, controls to meet permit operating limits, and cali-
bration instructions (Figure 6-5, work step 4.1). Build on your existing
documentation whenever you can if it is appropriate. The working docu-
ments provide the detailed “how to” and step-by-step instructions
needed to perform tasks. Document the system requirements to meet
your business needs and keep it simple.

If instructions and documentation do not add value to operational
control, question whether they are needed. Not every department in the
organization will need the same amount or detail in documentation.
Factors that can affect the need to document procedures include the
risk and complexity of the activity and the frequency and degree of su-
pervision needed to perform the activity. Organizational teams should
identify gaps in the existing documentation and initiate new procedures
to ensure continual improvement.

EMS Approach to P2 Implementation

The number of EMPs that an
organization sets up can vary.
One company uses one EMP
to address all of its objectives
and targets. Another company
set up four EMPs for dealing
with (1) all regulated aspects,
(2) solid waste, (3) energy
usage, and (4) PCB elimina-
tion. Finally, one company’s
EMPs were developed largely
at the departmental level.

Build on your existing docu-
mentation whenever you can if
it is appropriate.

If instructions and documenta-
tion do not add value to opera-
tional control, question whether
they are needed.

Factors that can affect the
need to document procedures
include the risk and complex-
ity of the activity and the
frequency and degree of
supervision needed to perform
the activity.



EMSs focus on top manage-
ment support and commit-
ment, accountability, employee
involvement, responsibility and
training, documentation,
operational controls, preven-
tive actions, and periodic
checking and review with
corrective action.

The EMS must include pre-
ventive actions and how to
mitigate environmental im-
pacts. Improving emergency
preparedness procedures
reduces accidental and mate-
rial losses while maintaining or
increasing productivity.

When it comes to developing
solutions, the EMS stipulates
that the corrective and preven-
tive actions be appropriate to
the magnitude of the problem
and commensurate with the
environmental impact encoun-
tered.

preventive actions, and periodic checking and review with corrective
action.

If a nonconformance has occurred, the responsible employees
determine how to correct it and prevent it from recurring. Management
review provides a broader, strategic look at the EMS and may be a
source of direction on preventing nonconformance. There are many
tools for developing solutions that have been discussed previously. The
next step is to prioritize the solutions for possible implementation. Use
of traditional business tools for prioritizing solutions can be used, such
as cost-benefit analysis.

Emergency Preparedness and Spill Prevention

Accidents and emergency situations can create environmental
impacts. Large amounts of waste may be generated through spills and
lack of emergency response procedures. The EMS must include pre-
ventive actions and how to mitigate environmental impacts. Improving
emergency preparedness procedures reduces accidental and mate-
tial losses while maintaining or increasing productivity (Figure 6-6, work
step 5.3).

Studies to implement preventive and corrective maintenance,
emergency response, spill prevention, and P2 programs should be
undertaken and their findings incorporated into the operational control
procedures. Improved procedures can range from a change in man-
agement approach to a change in waste handling practices and must
be a part of the overall emergency plan for the organization.

Preventive procedures should be reviewed and updated when nec-
essary after accidents and emergency situations. When it comes to
developing solutions, the EMS stipulates that the corrective and pre-
ventive actions be appropriate to the magnitude of the problem and
commensurate with the environmental impact encountered. P2 can be
implemented by changing existing procedures to reduce waste result-
ing from the cleanup of spills or leaks. Emergency plans already devel-
oped can be referenced in the overall emergency preparedness and
response procedure of the EMS.

LESSONS LEARNED

The EMS is based on a documented and clearly communicated
policy that includes three distinct guiding principles: compliance with
applicable environmental requirements, prevention of pollution, and a
commitment to continual improvement in environmental performance.
In some cases, organizations’ environmental policies, especially cor-
porate policies, may have become too long and broad to be under-
stood easily by employees and the public. An organization’s EMS policy
needs only to focus on the three guiding principles and to drive the
accomplishment of the EMS’s objectives and targets through training
and involvement.

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Major components of such a
long-term P2 commitment
include developing employees
and suppliers as key P2
participants in the long run and
fulfilling public responsibilities
over this period of time.

P2 measurements are driven
by the organization's strategy
and provide critical data and
information about key pro-
cesses, outputs, and P2
results.

Organizations can better

accomplish their overall goals .

by building internal and exter-
nal P2 partnerships.

mitments to all other interested parties. Organizations anticipate many
factors in their strategic planning efforts, such as interested party ex-
pectations, new business opportunities, the increasingly global mar-
ketplace, technological developments, new customers and market
segments, evolving regulatory requirements, community/societal ex-
pectations, and strategic changes by competitors. Short- and long-
term P2 plans, P2 strategic objectives, and P2 resource allocations
can reflect these influences. Major components of such a long-term
P2 commitment include developing employees and suppliers as key
P2 participants in the long run and fulfilling public responsibilities over
this period of time.

Management by fact. Organizations depend on the measurement and
analysis of P2 performance. Such P2 measurements are driven by the
organization’s strategy and provide critical data and information about
key processes, outputs, and P2 results. Many types of data and infor-
mation are needed for P2 performance measurement and improve-
ment. Performance areas should include (1) interested-party and em-
ployee satisfaction, (2) product and service offerings, (3) operations,
(4) market and competitive comparisons, and (5) P2 financial benefits.

Analysis refers to extracting larger meaning from P2 data and in-
formation to support evaluation, decision-making, and operational im-
provement within the organization. Analysis entails using data to deter-
mine P2 trends, projections, and cause and effect—knowledge that
might not be evident without analysis. Data and analysis support a va-
riety of purposes, such as P2 planning, reviewing overall P2 perfor-
mance, improving operations, and comparing P2 performance with
competitors or with “best practices” benchmarks.

P2 partnership development. Organizations can better accomplish
their overall goals by building internal and external P2 partnerships.

Internal P2 partnerships might include labor-management coop-
eration, such as agreements with unions. P2 agreements might entail
employee development, cross-training, or new work organizations, such
as worker teams. Internal P2 partnerships also might involve creating
network relationships among work units to improve flexibility, respon-
siveness, and P2 knowledge sharing.

External P2 partnerships might be with customers, suppliers, NGOs,
environmental regulatory agencies, and educational organizations for
a variety of purposes, including P2 education and training. An increas-
ingly important kind of external P2 partnership is the strategic partner-
ship of alliance. Such P2 partnerships might offer entry into new mar-
kets or a basis for new products or services. P2 partnerships also
might permit the blending of an organization’s core competencies or
leadership capabilities with the complementary strengths and capabili-
ties of P2 partners, thereby enhancing overall P2 capability, including
the elimination of waste from all business processes.



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from a National Laboratory in the United States. However, the cost of
disposal was the highest of all the items considered in the analysis.
Other examples of the use of Pareto analysis are presented on the
CD-ROM that accompanies this. Guide.

Analyzing Root Causes

“Root cause’ is the basic reason that a resource is being used or a
process loss is occurring. If this cause can be eliminated, the resource
use or loss would be prevented. This approach is the very basis of P2.

Root cause analysis refers to the process of identifying causal fac-
tors. Most people involved in P2 are ardent problem solvers, but in their
haste to get to a solution, some may skip over this very important prob-
lem-solving activity. P2 teams which skip this important step may sim-
ply take the most obvious action, rather than the one that would best
solve the problem.

For example, when faced with environmental problems caused by a
toxic chemical, P2 “problem solvers” might initially assume that the best
way to address the issue is to find a “safe” substitute. In fact, the problem
may be caused by howthe company is using the chemical, rather than by
the chemical itself. Changing work procedures or equipment or training
employees more effectively might offer a better and/or less costly solu-
tion. Root cause analysis teaches organizations to look at all potential
causes: materials, technology, work practices, and people.

Root cause analysis can be an effective management tool for de-
termining the true or actual cause of resource use or loss in a process,
facilitating effective corrective action, and preventing recurrence of the
problem. It also provides obvious opportunities for improvement since
it identifies both the underlying reasons for problems and the obstacles
to correcting them.

The cause and effect diagram (also known as a fishbone diagram)
provides an effective tool for conducting root cause analysis (Reference
4-5). Studies have found that this tool is the most widely used problem-
solving tool in the world. However, it takes a little training and experience to
use this important tool effectively. This tool is to be used by the P2 team,
not by individuals. It provides a useful graphic to explain to management
and other interested parties exactly what may be causing a problem. Once
the diagram has been completed, the P2 team can count the number of
causes found. The 80/20 rule can be used to help focus on the most
probable causes by drawing circles around the 20% of the causes that
may account for 80% of the problem. The P2 team will be more effective if
it has this understanding and focus before attempting to generate P2 alter-
natives. An example of a cause and effect diagram can be found in Figure
4-5, Other cause and effect diagrams are included on the CD-ROM that
accompanies this Guide.

P2 Tools 59° -

Root cause analysis teaches
organizations to look at all
potential causes: materials,
technology, work practices,
and people.

The cause and effect diagram
(also known as a fishbone
diagram) provides an effective
tool for conducting root cause
analysis.



CHECKLISTS

Checklists are often necessary tools for P2 programs. A checklist
helps guide an organization's activities and progress. Checklists pro-
vide important steps and method information for measuring operational
performance and effectiveness and help the organization collect and
organize data for assessing its current status and how well it is operat-
ing. It is useful to make lists of questions and answers for anything
related to each of the problem-solving and decision-making tools pre-
sented in this Guide. Such lists form an outline of the entire problem
situation and are important entries in any record of the process.

Checklists also help the P2 facilitator and P2 teams by providing
guidance for further action and indicate things to do, process compo-
nents to visit, people to see, and questions to ask. By devising a series
of checklists, the P2 team provides itself with a means to review the
entire resource use or loss problem.

Checklists are a handy way to jot down ideas as they arise for
possible use at a later date. As the checklists increase in size and
number, they can be reorganized and combined to simplify dealing with
the problem as a whole and to clarify its parts. Checklists help the team
organize the tasks and provide an overall view of the situation, its re-
quirements, attributes, alternatives, and consequences.

Here are some simple steps for deriving checklists for a P2 pro-
gram.

quirements “and asks for specific data to. be recorded.
rovide Space for checking « off of completed d steps, ideas, or
“data items. snind
OQ Ask the subject matter expert to review he final draftofa |
““thecklist to ensure that nothing of importance has been
F overlooked or omitted.
* Q Perform revision and pilot-test the checklist before placing it
into use.

eee

P2 teams should compose checklists that complement the pro-
cess they use in their P2 program. The various components of a typi-
cal P2 effort using the Systems Approach tool are listed so that a P2
team nmay use checklists to achieve better results in these areas:

: p ‘rack 0 of the process characterization effort, ‘including all
and intermittent ‘operations.

_{ Assure proper resource accounting for uses and losses at
5 the work-step level.

P2 Tools

Checklists also help the P2
facilitator and P2 teams by
providing guidance for further
action and indicate things to
do, process components to
visit, people to see, and
questions to ask. By devising
a series of checklists, the P2
team provides itself with a
means to review the entire
resource use or loss problem.



The focus in P2 is on the
organization's main and
supporting processes, not on
the resulting waste or use of a
regulated material.

Lean generally focuses on “the
elimination of all waste from all
business practices.”

This Guide focuses on the
integration of P2 into core
business practices.

Many advocates for
sustainability seek not merely
to reduce waste but to elimi-
nate the generation of waste
altogether.

Having a strong P2 program is
a vital aspect of any program
that is set on eliminating
wastes from the organization.

the organization’s main and supporting processes, not on the resulting
waste or use of a regulated material.

Many states have enacted P2 and toxics use reduction planning
legislation. This legislation has had the unintended effect of making P2
a regulatory compliance effort and has done little to integrate P2 into
core business practices. Itis important to understand the organization's
main and supporting processes and all of the individual work steps so
that when the process is changed, the regulatory requirement is not
triggered. By seeking to avoid the need for regulatory compliance (i.e.,
compliance through P2), environmental professionals become impor-
tant resources to the organization’s work function; managers of orga-
nizations are beginning to recognize the value of these environmental
professionals as they reduce the costs associated with compliance
activities. .

An organization’s management is always searching for the new-
est trend to enhance its value and financial viability. Many organizations
use a version of a management practice called lean manufacturing.
Lean generally focuses on “the elimination of all waste from all busi-
ness practices.” Much has been written on seven types of organiza-
tional wastes: over-production, waiting time, transport, variable
process, inventory, motion, and defective goods. Environmental wastes
are rarely included in these programs because many organizations
rely on the environmental function to manage these wastes in accor-
dance with regulations. Many organizations with a strong focus on quality
have weak P2 programs because the environment and quality pro-
grams have not been sufficiently integrated. This Guide focuses on the
integration of P2 into core business practices. It will present P2 as a
necessary component of many common organizational management
programs and show you how to use the same problem-solving and
decision-making tools used in these programs.

Many advocates for sustainability have called for a shift to biologi-
cally-inspired production models. They seek not merely to reduce waste
but to eliminate the generation of waste altogether. As a result, there is
a growing trend for organizations to set goals of zero wastes and/or
zero emissions. Organizations like DuPont, Xerox, Collins Pine, and
Interface have joined these ranks. The zero-waste trend stems from a
long-standing tradition of setting zero defects, zero injuries, and zero
incidents goals. Having a strong P2 program is a vital aspect of any
program that is set on eliminating wastes from the organization. How-
ever, integrating a strong P2 program with many other programs in the
organization is still essential to realizing these goals. Some organiza-
tions are implementing programs that direct them toward a sustain-
able performance level. Elimination of wastes and conservation of
resources are important first steps in such programs.





eee ere ee Ve Ve VV Ve VV VeVVEVTVEeETVVVeVVEVTVVeVeVeeVeVe Vee Vee Vee VT Uo

Process changes can result in new operational controls that re-
duce waste at the source, primarily during production. Good operating
procedures and improved housekeeping are the simplest P2 practices.
Improved housekeeping relies on using good common sense and is
often the most effective first step toward waste reduction. By properly
labeling materials and wastes, an organization can reduce the risk of
misuse or disposal of the wrong substance. By properly separating
wastes, an organization can assess the potential for reuse, recycling,
or exchange of the materials. Inventory control and handling materials
properly, including storage, will reduce loss of input materials and re-
duce expired shelf life of time-sensitive materials.

Substituting less toxic raw materials may be difficult in certain situ-
ations, but it can be an efficient part of P2 operational control to reduce
multimedia wastes. Changes may include equipment, layout, piping
changes, use of automation, waste concentration or volume reduction,
and energy conservation. Operational control ensures that equipment
is working properly and avoids faulty valves or pipes leaking materials
that become contaminated and a waste. Preventive maintenance pro-
cedures are designed to reduce incidents of equipment breakdowns,
inefficiency, or process fluid leakage. Another important operational
control is corrective maintenance, such as resetting control valves or
adjusting process temperatures to increase efficiency and prevent raw
material loss and waste generation.

The basic steps to success in P2 through operational control in-
clude building on existing systems, establishing procedures, assigning
responsibility, determining access, communicating and training, and
auditing procedures and records. These procedures are the core of a
P2 program’s operational phase and are often the “low-hanging fruit”
that are within easy reach. Without a Systems Approach, much of the
P2 “low-hanging fruit” will be lying on the ground.

Checking and Corrective Action

The checking and corrective action element in the EMS is the main
focus for continual improvement (Figure 6-5, work step 4.3). Manage-
ment involvement and commitment to reducing waste needs to deal
successfully with checking and corrective action. P2 may benefit from
closer supervision to improve production efficiency and reduce inad-
vertent waste generation through early detection of mistakes. EMSs
ensure that nonconformances to procedures are investigated, that root
causes of the nonconformity are identified, and that corrective and pre-
ventive actions are implemented, documented, and reviewed. This type
of analysis leads to increased efficiency of the EMS and P2 through
improved performance.

As systems are put in place, it makes sense to establish measur-
ing processes on how well the system is working, identify actual or

Good operating procedures
and improved housekeeping
are the simplest P2 practices.

Substituting less toxic raw
materials may be difficult in
certain situations, but it can be
an efficient part of P2 opera-
tional control to reduce multi-
media wastes.

The checking and corrective
action element in the EMS is
the main focus for continual
improvement.

EMS Approach to P2 Implementation |’, 93



Organization image concerns. Organizations may be hesitant to ad-
mit that the “old way” may not be the best way. Once easy-to-imple-
ment P2 practices such as improved operations are underway, for ex-
ample, some organizations may resist publicly acknowledging the
changes out of concern that such acknowledgment might expose pre-
vious, less environmentally sound practices. However, the implemen-
tation of P2 practices provides managers with an opportunity to lead
the organization through changes that will benefit everyone.

Available time/technical expertise. Some organizations may lack
sufficient time or technical expertise to develop and implement P2 prac-
tices. Even though many state and federal technical assistance pro-
grams (References 1-2, 1-3, 1-4) are available at little or no cost, some
organizations simply fail to take advantage of them.

Inertia. Whenever a production system is in place and working with
some degree of success, there is a tendency to leave well enough
alone. The old adage ‘if it ain’t broke, don’t fix it” still prevails in most
organizations. Overcoming resistance to change is a major challenge
for P2.

P2 IN STEPS

Previous editions of this Guide have defined a path (adapted from
Figure 3 in EPA/600/R-92/088) depicting how P2 should be implemented
(see Figure 1-1).

ESTABLISH P2 ORGANIZE p2 CONDUCT were p2
PROGRAM PROGRAM PRELIMINARY PROGRAM >
[>| assessment [>] PTMSUAN
4 2 3 4
T
DO DETALED. DEFINE P2 DO ast: JMBLEMENT
ASSESSMEN' ‘OPTIONS. FEASIBILITY SSESSMENT IE P2 PLAN
| P| p>] ‘anavses [>] “SReponr > la
5 . 6 z °
MEASURE P2 MAINTAIN P2
>| PROGRESS PROGRAM

10 1"

Figure 1-1. Process Map of a Traditional P2 Program.

Following is an alternative view of P2. The primary difference lies in
the fact that the P2 Program is established after much of the informa-
tion has been gathered rather than in the first step of the program. It
also uses quality tools that have been adapted to P2 programs and
published in the literature. This view of P2 consists of five simple steps
(see Figure 1-2):

Even though many state and
federal technical assistance
programs are available at little
or no cost, some organiza-
tions simply fail to take advan-
tage of them.

Overcoming resistance to
change is a major challenge
for P2.

The primary difference lies in
the fact that the P2 Program is
established after much of the
information has been gathered
rather than in the first step of
the program.



Organizations should imple-
ment any cost-effective
recommendations identified by
their P2 program planning
efforts. They are encouraged
to conduct periodic evaluations
of P2 program effectiveness to
provide feedback and to
identify potential areas for
improvement.

44

6. Conduct Program Evaluations

Organizations should implement any cost-effective recommenda-
tions identified by their P2 program planning efforts. They are encour-
aged to conduct periodic evaluations of P2 program effectiveness to
provide feedback and to identify potential areas for improvement. Dur-
ing the evaluation, it is important to determine what was learned from
each P2 activity and how that information will be utilized in constructing
P2 action plans for the coming year. P2 programs can also be
benchmarked against others. Reviews can be conducted internally or
performed with an independent third party. Many companies now ac-
cept the practice of using third-party individuals because they already
are employing them in their ISO 9000 and ISO 14001 programs. The
quality model (see Chapter 7) also offers a way to measure progress
made by a P2 program and have it scored by an independent team of
trained examiners.

Other Program Elements

There may also be other elements that can be included in the
program. For example, the American Chemistry Council’s (ACC) Re-
sponsible Care® Program has a “Pollution Prevention Code of Man-
agement Practices” (Reference 3-4). One of the items required in this
program is: “Inclusion of waste and release prevention objectives in
research and in design of new or modified facilities, processes, and
products.” The National Pollution Prevention Roundtable has published
a white paper on facility pollution prevention planning (Reference 3-5)
that could also be helpful in finding other P2 program elements.

The ACC’s P2 Code states that each member company shall have
a P2 program that shall include the following:

at each of the compan

: Sabchateictemtees
n the generation of wastes.
' Was

if @ point o of generat

mane
n sufficient toa assist in estat
Ry

Rw rt eam

- ofthe public about the inventory, impact evaluation, and
risks to the communi

Establishment of priorities, goals, and plans for waste and
release reduction, taking into account both community
concerns and the potential health, safety, and environ-
mental impacts as determined under Practices 3 and 4.



Again, P2 (source reduction) practices and techniques succeed
best when promoted as the number one strategy for improving environ-
mental performance and meeting attainable and measurable goals. In
setting the EMS’s objectives and targets, the organization must con-
sider (1) significant environmental aspects, (2) legal and other require-
ments, (3) the views of external parties and societal concerns, (4) tech-
nical options and operational feasibility, (5) financial requirements for
paybacks, and (6) business requirements for marketability and profit-
ability. All of these are usually taken into consideration when P2 op-
portunities are being examined for inclusion in an organization's P2 plan.

An EMS encourages innovative P2 solutions to waste and loss prob-
lems at all levels of the organization. Documented objectives and tar-
gets of the EMS must be provided for all relevant levels and functions of
the organization that impact the environment. The objectives and tar-
gets may be different for various levels of the organization such as
management, plant engineer, and line supervisors and operators. The
keys are consistency with the environmental policy and the inclusion of
P2. The EMS standard requires organizations to set objectives and
targets for reducing their environmental impacts, select activities to
achieve the identified targets, and then use a continual improvement
cycle to evaluate and correct the system.

EMS Training and Responsibility

The EMS requires that all employees be made aware of their envi-
ronmental responsibilities and trained to exercise care when perform-
ing duties with environmental consequences (Figure 6-4, work step 3.4).
Consider what type of EMS training is needed to achieve the
organization’s objectives and targets and integrate this training into ex-
isting environmental, health and safety, and emergency preparedness
training programs. This training requirement provides the opportunity to
involve all employees in P2. If the absence of correct procedures could
lead to deviations from your EMS policy, objectives, or targets, the pro-
cedure or work instruction should be documented and used in training.
This is an extremely important part of a successful EMS.

Employees will need to be trained in the procedures relevant to
their roles and responsibilities for meeting the objectives and targets
and in the potential results of departure from specified operating proce-
dures. It is important to ensure that EMS internal auditors are trained
and familiar with the waste management hierarchy and P2 strategies.
Training will ensure that EMS objectives and targets are assessed and
are being met using source reduction methods.

One company created a bulletin board displaying the company’s
policy, significant aspects and impacts, and objectives and targets of
the EMS. During morning line meetings, the line supervisors went with
the line team to the bulletin board and reviewed this information all the

In setting the EMS’s objec-
tives and targets, the organi-
zation must consider (1)
significant environmental
aspects, (2) legal and other
requirements, (3) the views of
external parties and societal
concerns, (4) technical op-
tions and operational feasibil-
ity, (5) financial requirements
for paybacks, and (6) busi-
ness requirements for market-
ability and profitability.

The EMS requires that all
employees be made aware of
their environmental responsi-
bilities and trained to exercise
care when performing duties
with environmental conse-
quences.

It is important to ensure that
EMS internal auditors are
trained and familiar with the
waste management hierarchy
and P2 strategies.

EMS Approach to P2 Implementation.|



WHEN WILL YOU BEGIN?

As mentioned previously, you may have already started your P2
efforts. Perhaps you have had some P2 successes and are now seek-
ing ways to formalize and sustain the program. Maybe this is the first
time you have formally looked at eliminating waste from the organiza-
tion. If so, you might wish to start by preparing a list of all the projects
you have implemented in the past two or three years that would fit un-
der the heading of P2. Make sure that representatives of all parts of the
organization participate in the creation of this list. As you begin to focus
on P2, many organizations are able to double or triple the number of P2
projects appearing on their listing of past accomplishments. As more
people get involved in P2, they may begin to recognize that they have
most likely been doing some of this all along. Resolve to keep this list
current and share it with regulators, customers, suppliers, community
organizations, and all other interested parties. Then prepare to start
your new P2 program.

LESSONS LEARNED FROM PAST P2 PROGRAMS

There is a substantial body of literature on P2 efforts in the United
States and internationally. References to much of this P2 literature is
included on the companion CD-ROM. Some of the lessons learned
during those efforts specific to the preplanning phase are described in
the following paragraphs.

The implementation of P2 projects can yield some modest, imme-
diate benefits. However, the big payoff from P2 often requires a pro-
gram that is integrated into the operations of the organization and sup-
ported for a minimum of two to three years. Like quality, P2 is a mindset
that needs to permeate into the culture of the organization. One of the
greatest P2 myths is that a P2 program is a “quick fix” used to turn
around organizations. Many P2 programs do not offer instant financial
success. P2 is a long-term effort with both long- and potential short-
term bottom-line benefits.

P2 success requires full financial support as well as management
commitment. Resources that will be needed include funds, people, train-
ing, facilities, support structure, and, in some cases, the adoption of
new technology. Often projects that are already funded can be turned
into P2 projects by emphasizing different aspects. Other financial com-
mitment concerns will be covered in Chapter 4.

Some have said that P2 is a way of life, not a new program. P2
requires many changes in behavior that cannot be demanded. The goal
of P2 is to institutionalize the philosophy and guiding principles as part
of the organization. This can only be accomplished by continual ac-
tions that reinforce P2 behaviors. Since people resist change, a move
to new prevention methods involves a campaign for their hearts as well
as their minds.

Getting Started

As more people get involved
in P2, they may begin to
recognize that they have most
likely been doing some of this
all along.

Like quality, P2 is a mindset
that needs to permeate into
the culture of the organization.

P2 is a long-term effort with
both long- and potential short-
term bottom-line benefits.

P2 success requires full
financial support as well as
management commitment.

P2is a way of life, not anew
program.

The goal of P2 is to institution-
alize the philosophy and
guiding principles as part of
the organization.



MARA ABAASLAAASAAASAAAA AAAALAAAAAAA AAA AAA Ae ett bh tet tet eee

ership. Senior leaders must demonstrate a commitment in this
approach. Refer to the questions in Box 8-2 to see how to reach best-
in-class status in this area. Striving to get positive answers to these — How does senior management
questions will help the organization improve the management compo- demonstrate commitment to
nent of the P2 program. continual environmental

= = Tn z z improvement on par with other
major organizational goals?

at with other major organizational goals?
Conduct proactive communication with all interested parties?

upport for continual environmental improvement?
“Assure that continual environmental improvementis integrated, reviewed,
id tracked?

community leadership

: RES
:_ Initiate and support environmental protection and sustainability efforts
- in the community?
E Seek to understand environmental issues specific to the community
‘_ and address those issues with strategies, actions, and collaborative
© efforts?

* Support mentoring of other organizations in the community to promote

P2 and continual improvement?
* Set affirmative procurement goals?
* Communicate your environmental performance to the community?

Many senior managers also recognize the importance of being a
good corporate citizen in the local community. In the quality approach,
good corporate citizenship goes beyond giving to local charities. The
P2 ideals of the organization need to be promoted to all the local inter-
ested parties as a demonstration of the senior leadership's commit-
ment to these ideals. . Senior leadership must “walk
the talk” to provide true leader-

Senior leadership (i.e., those people to whom the environmental ship to the P2 program.

manager reports) must “walk the talk” to provide true leadership to the
P2 program. A good “bottom-up” program with a results focus may —_The Jiterature on quality im-
help senior management go this extra distance. The literature on qual-_—_ provement and change man-
ity improvement and change management stresses the importance of — agement stresses the impor-
having serious commitment from top management. Finding a way to —_ tance of having serious com-
gain this advantage will promote the implementation of your mitment from top manage-
organization’s P2 program. ment.

to Implement P2 127



‘This Guideis not intended to be an exhaustive review of case stud-
ies and company examples. In order to keep this Guide to a reason-
able length, examples have been cited in the references section of
each chapter and links have been provided in the CD-ROM that ac-
companies this Guide. In addition, many EPA and other programs sup-
port P2 efforts;.e.g., Environmentally Preferable Purchasing (EPP),
Design for Environment (Df), Environmental Accounting Project (EAP),
P2 Resource Exchange (P2Rx) and a number of other voluntary pro-
grams. Links to these programs are provided on the CD-ROM. This
CD-ROM will also provide more detailed supporting information on many
of the concepts described in the Guide.

BENEFITS OF P2

The benefits of practicing P2 have long been noted. Despite the
clear advantages, however, some managers are still reluctant to rec-
ognize the P2 efforts that are underway in their organizations. To pro-
vide better focus on the benefits, environmental coordinators are now
showing how P2 is enhancing other management initiatives by linking
P2 to the core values of the organization. It may be best to think of the
following categories of benefits in this new light.

‘educed operating cost
mproved worker safety

Increased environmental protection
Reduced exposure to future liability
Continual improvement” “~~~ ~~
Resource conservation
Enhanced public image

ce eee

Reduced operating costs. P2 activities usually save an organization
money in the long term. Many P2 projects have good returns on invest-
ment and short payback periods. Even if an organization is not subject
to complicated regulations, P2 can still result in cost savings by reduc-
ing energy and water use while increasing materials productivity. Or-
ganizations may also save money in solid waste disposal costs, new
material costs, and improved operating efficiency. Unfortunately, too
few P2 professionals communicate the economic benefits of P2
progress to management.

Improved worker safety. Reducing the use of toxic materials in the
workplace should be a major component of P2. By reducing or elimi-
nating toxic substance use, the safety of the work environment can be
improved and the use of personal protective equipment requirements
decreased. Also, reducing the likelihood of leaks, ‘spills, and harmful
releases can decrease worker, visitor, and contractor exposure to those

This Guide is not intended to
be an exhaustive review of
case studies and company
examples.

Unfortunately, too few P2
professionals communicate
the economic benefits of P2
progress to management.

By reducing or eliminating
toxic substance use, the
safety of the work environment
can be improved and the use
of personal protective equip-
ment. requirements de-
creased.



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Glass Rags
Cleaner
Gloves ABS Aprons Lubricant
rly 4 :
Camera/Processor
Mixing Solutions A Filling Solution Maintenance
(Gror and developer) [Sottiony| Sates tedt
4-4-a1 - 1-4-a2
{ weet iY { ’ Waste Dirty Rags
Dirty Spilled Spilled Dirty Cleaner
Aprons, Solution Solution Aprons
Gloves
Spent Fixer
Dirty Clean Containing Silver,
Washwater Washwater Washwater —Silver/Mercury| Silver Recovery Mercury
——>|___ Recycling Unit +|——> — Unit -—>
4-4-1 14-01
1 Sludge J Spent
Silver Wastewater Fixer

Figure 4-2. Hierarchical Process Maps (continued).

Throughput In —pp]

Non-product Resource Use

WORK STEP

‘

Non-product Resource Loss

-—> Interim/Final Product

Figure 4-3. Using the Process Map as a Resource Accounting Template.


In the EMS-based implemen-
tation P2 program, much of the
planning is specified in the
guidance set forth in ISO
14001 or other EMS guidance
documents.

The quality-based P2 program
places more emphasis on the
recognition of environmental
matters in the organization's
strategic plan.

124

There is some upfront planning involved in the traditional P2 pro-
gram. It is modeled around assessments that are conducted in the
workplace. Adding process mapping to this approach will help find more
opportunities for P2. This does not greatly increase the amount of plan-
ning in the process, however. When this program was prepared in the
late 1980s, many people saw a need to just get in there and get started.
A program can be developed from these initial efforts. What happened
is that the initial efforts ran out of steam, since there was no program to
guide continual improvement. Once the easy issues were addressed,
it was difficult for the P2 efforts to continue.

In the EMS-based implementation P2 program, much of the plan-
ning is specified in the guidance set forth in ISO 14001 or other EMS
guidance documents. You will recall that the EMS implementation in-
volves employees and has action plan requirements. Also, recall that
the EMS implementation includes management involvement and con-
tinual improvement. In setting the EMS objectives and targets, the or-
ganization must consider the following items: (1) its significant envi-
ronmental impacts, (2) legal and other requirements, (3) the views of
external parties and societal concerns, (4) technical options and op-
erational feasibility, (5) financial requirements for paybacks, and (6)
business requirements for marketability and profitability. This involves
planning. Planning is very important in the EMS approach to P2. While
there is no requirement that the EMS program be integrated into the
strategic planning of the organization, as shown in Chapter 6 the pro-
gram would be much more successful if it was so integrated.

The quality-based P2 program involves planning in the following
areas:

Mal ACHON os wens .
Integration and implementation

This approach to P2 places more emphasis on the recognition of
environmental matters in the organization's strategic plan. Even if the
organization does not have a formal strategic planning capability, envi-
ronmental thinking must make it into the executive suite. An entire part
of the evaluation is dedicated to strategic planning. Some questions to
ask of the P2 planning efforts in this regard may be found in Box 8-1.
These questions, which also can be used in the traditional and EMS
approaches, can help align the P2 program with the strategic thrust of
your organization. Any progress made in this direction will help inte-
grate P2 into mainstream activities.

“Chapter 8



By using the proper scoring
methodology, you will be able
to see the areas that require
more effort as you seek to
improve the P2 program.

You need to find a way to
integrate each of the guiding
principles with the proper
criteria in the quality model if
you wish to integrate the P2

program into the organization.

108

Another interesting fact about the Green Zia method is that there area
number of more detailed questions that can be asked within each criterion
that describe what might be the best one can do (i.e., if you can answer
every question in a positive manner within an example, your organization
may be considered to be doing a great job in that area). A complete list of
these questions can be found on the CD-ROM.

It is not important for your organization to be the best in all seven
criteria areas. You will certainly do better in some than you do in others.
The point is to make sure that the P2 program addresses all seven
criteria in a forthright manner.

The Green Zia program assigns points to each of these criterion.
These points emphasize the greater importance of results in a P2 pro-
gram. By using the proper scoring methodology outlined on the CD-
ROM, you will be able to see the areas that require more effort as you
seek to improve the P2 program. Once you address these opportuni-
ties to improve the program using the Systems Approach tools, you
can measure the amount of improvement in the overall program score.
This concept will be described later in this chapter.

ELEVEN QUALITY MODEL GUIDING PRINCIPLES

Guiding principles, often referred to as core values, are used to set
acontext for all activities in an organization. They are meant to provide
guidance for decision-making at all levels in the organization. You need
to find a way to integrate each of the guiding principles with the proper
criteria in the quality model if you wish to integrate the P2 program into
the organization. Your organization may have already published a set
of guiding principles. If so, consider how P2 can be addressed within
each of these areas. If your organization does not have a set of guiding
principles, consider how you can introduce the following principles into
the culture. Keep in mind that it may take a long time (i.e., perhaps
more than two years of concerted effort) to change the culture by ad-
dressing these guiding principles in the statement of the criteria. How-
ever, once this change takes place, the P2 program will be integrated
within the organization. There are 11 guiding principles that can be con-
sidered in this quality model:

Int ted-pal rive’
g Ip. .
improvement and learnin j

sais wenn CMTS EES
3

ing employees
5, Fast response

6. Efficient product, ‘Service, and process design ~~
-=7. Long-range view of the future" °

8. Management by fact
9. Partnership development

10. Public responsibility and citizenship
11. Results focus

cereeeeemeesaote ene ee |

a

‘
Let’s take a look at what is meant by each of these guiding principles.

Chapter 7

00 COCO OOOO OOOO OH OHOHOH8SHHHOEOHTHOOHEHHOHIHOOHHOH8HHHOOO



An organization's P2 success
depends increasingly on the
knowledge, skills, innovative
creativity, and motivation of its
workforce.

way the organization operates. The term embedded means that im-
provement and learning:

3. bs
4. “Are driven n by opp rtunitie:
P2 program.

ovate and do better in the

P2 improvement and learning include:

ayer

Ree an

tania iene

eloping, shew business Seer Gg from P2 °
pA RTS AE DE:

Pdischarges and related

ou rN a

mode

“costs.
Improving responsiveness to production and quality in
- waste (nonvalue added activity) reduction programs.
.. Increasing productivity and effectiveness in the use of all
: resources (e.g., energy, water, and materials).
6. Enhancing the organization's performance in fulfilling its
public responsibilities and service as a good citizen.

Thus, improvement and learning are directed not only toward bet-
ter products and services but also toward being more responsive, adap-
tive, and efficient—giving the organization additional marketplace and
performance advantages.

Valuing employees. An organization’s P2 success depends increas-
ingly on the knowledge, skills, innovative creativity, and motivation ofits
workforce. Employee success depends increasingly on having oppor-
tunities to learn and to practice new skills. Organizations can take ad-
vantage of the workforce’s potential by investing in its development
through education, training, and opportunities for continuing growth.
Opportunities might include enhanced P2 awareness and increased
pay for demonstrated P2 awareness, knowledge, and skills. On-the-
job training offers a cost-effective way to train and to better link P2
training to work processes. Education and training programs may need
to utilize advanced technologies, such as computer-based learning and
satellite broadcasts. Increasingly, training development needs to be tai-
lored to a diverse workforce and to be more flexible for high perfor-
mance P2 work practices.

Major challenges in the area of valuing employees include:



ACRONYMS

ACC = American Chemistry Council

BAT = best available technology

BMP = best management practice

CSI = Common Sense Initiative

DfE = Design for Environment

EHS = environment, health, and safety

EMAS = eco-management and audit scheme

EAP = Environmental Accounting Project

EMP = environmental management program

EMS = environmental management system

EPA = Environmental Protection Agency

EPP = Environmentally Preferable Purchasing
FDA = Food and Drug Administration

ISO = International Organization for Standardization
JIT = just-in-time

MSDS = material safety data sheet

MSWG = Multi-State Working Group

NGO = non-government organization

OSHA = Occupational Safety and Health Administration
P2 = pollution prevention

P2Rx = P2 Resource Exchange

PCB = polychlorinated biphenyl

PSM = process safety management

QA/QC = quality assurance/quality control -

SGP = Strategic Goals Program

SOP = standard operating procedure

TQM = total quality management

VOC = volatile organic chemical

WBCSD = World Business Council for Sustainable Development
XL = eXcellence and Leadership

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Thraugh the procedure of aspect identification and ranking, P2
should emerge as a core part of the environmental management plan(s).
The P2 assessment is a systematic, periodic survey of the
organization’s operations designed to identify areas of potential waste
reduction and conservation. A well-designed EMS can go far beyond
the traditional process-driven view for characterization of wastes and
losses. In evaluating all of its environmental aspects, an organization
can take activities such as solid waste, energy and water use, land-
scaping, commuting, sound, and other impacts into consideration al-
though they are not regulated. The organization can question suppliers
about contents of materials, use and types of packaging, and methods
of delivery. Aspect identification procedures include the following:

>Process mapping
“Interviews
ese” Questionnaires
=*~Checklists
“Benchmarking
Cost/benefit, energy, and life cycle analysis
Inspections and audits

Review of records and emergency responses

Material balances of inputs and outputs

Consideration of operating conditions and controls and their effect
on environmental impacts is an important part of identifying the
organization’s significant aspects. The organization should select cri-
teria to determine the significance of its aspects. The criteria might
include regulated activities, costs to manage, and risks associated with
use of raw materials. What is most important is that the criteria reflect
the organization's values as stated in the policy. Several good examples
of ranking potential significant aspects/impacts can be found in US
EPA's Integrated Environmental Management Systems Implementa-
tion Guide and NSF International's Environmental Management Sys-
tems: An Implementation Guide for Small and Medium-Sized Organi-
Zations (References 6-4 and 6-5). See the CD-ROM for more informa-
tion on EMSs.

Identifying operations and monitoring and measuring activities as-
sociated with significant environmental aspects leads to the develop-
ment of procedures that minimize the risk of those environmental im-
pacts. This systematic approach can help foster P2 solutions by en-
couraging an organization to identify opportunities for doing things in
new ways, for finding new products from “waste,” and for going beyond
the traditional view that environmental issues are the responsibility of
the environmental, health, and safety managers.

Typically, organizations separate their environmental strategies by
media—land, air, and water—to address their environmental impacts

EMS Approach to P2 Implementation |

Through the procedure of
aspect identification and
ranking, P2 should emerge as
a core part of the environmen-
tal management plan(s).

In evaluating all of its environ-
mental aspects, an organiza-
tion can take activities such
as solid waste, energy and
water use, landscaping,
commuting, sound, and other
impacts into consideration
although they are not regu-
lated.

The organization should select
criteria to determine the
significance of its aspects.
The criteria might include
regulated activities, costs to
manage, and risks associated
with use of raw materials.

This systematic approach can
help foster P2 solutions by
encouraging an organization to
identify opportunities for doing
things in new ways, for finding
new products from “waste,”
and for going beyond the
traditional view that environ-
mental issues are the respon-
sibility of the environmental,
health, and safety managers.



A key component of a P2 Plan
is the vision statement. It
provides a way of seeing or
conceiving what the organiza-
tion wants to achieve in the P2
program. The vision of the
organization usually provides a
concise word picture of the
organization at some future
time,

32.

Vision Statement

A key component of a P2 Plan is the vision statement. \t provides
a way of seeing or conceiving what the organization wants to achieve
in the P2 program. The vision of the organization usually provides a
concise word picture of the organization at some future time. This helps
set the overall direction of the organization. The vision statement de-
fines what the organization strives to be. (If you are seeking environ-
mental excellence, the criteria described in Chapter 7 may be helpful in
defining what you want to achieve.)

Sustainable development programs, like “The Natural Step,” have
successfully posed a vision of the future framed by four system condi-
tions. Reviewing a vision statement from a sustainable development
program such as this can help you develop a general direction, image,
and philosophy to guide your organization in its P2 program.

Itis difficult to find a perfect example of a vision statement. Several
samples are provided so you can see how others have addressed this
issue. Does your organization already have a vision statement? How
would the statement change if some element of P2 or sustainable de-
velopment were added to it?

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The National Park Service strives to facilitate a culture of environ-
mental stewardship and sustainable development.

Reference: http://es.epa.gov/oeca/fedfac/complian/emsrcemp.pdf

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{east on a quarterly basis. At the end of the year, they can be audited
both internally and externally (i.e., by interested parties). The final P2
plan should now have internal plan approval and is ready for implemen-
tation.

Step 4. Maintain Your P2 Program

Once the P2 plan is implemented, it must be maintained over time
(Figure 7-5). It is important to review the quality model criteria for infor-
mation analysis and results. The results criterion examines your
organization’s real and anticipated P2 results related to your continual
environmental approach to zero waste and emissions. It suggests that
you consider levels and trends as they relate to impacts on the environ-
ment, worker health and safety, other interested party impacts, and key
financial indicators. Managers love results and continue programs that
deliver good results. Remember that “what gets measured, gets man-
aged.” P2 programs cannot survive on success stories. The informa-
tion analysis criterion ensures that these results are used in running
the organization and not simply sent off to the interested parties. The
P2 plan must be improved with feedback received on the actual
progress that is made. Each year, the sequence of preparing action
plans using the Systems Approach is repeated.

> MAINTAIN P2 PROGRAM

Information Analysis

Results

Continual Improvement with Feedback
Reports to Interested Parties

Action Plans for Year 2

Figure 7-5. Maintain the Pollution Prevention Program.

Step 5. Measure Your Progress Toward Zero Waste and
Emissions

After a few years, the P2 program can be scored in light of what it
has contributed to the organization's stretch goal of zero waste and
emissions (Figure 7-6). This scoring can be accomplished in a man-
ner like the Green Zia program. It provides the ultimate scorecard for
how important the P2 plan has been for the organization. Trending
information helps the organization point to its accomplishments. The
organization can also trend itself in comparison to other similar organi-
zations using benchmarking techniques. This information can be used

Managers love results and
continue programs that deliver
good results. Remember that
“what gets measured, gets
managed.” P2 programs
cannot survive on success
Stories.



The EMS standard requires
procedures to monitor and
measure your environmental
performance, to record infor-
mation that allows perfor-
mance tracking of operational
controls and conformance with
the objectives and targets, and
to evaluate compliance with
environmental regulations.

Determining what to monitor
and measure and what infor-
mation to record is critical.

potential problems, and act to eliminate them. This element of the EMS
establishes measures of environmental performance and identifies
where corrective actions are needed, if any. Organizations that have
implemented an EMS have realized internal efficiency gains. Internal
efficiency gains may be realized by the identification of root causes of
waste and by easier access to environmental reporting information,
records, and permits.

EMS MONITORING AND MEASUREMENT

The EMS standard requires procedures to monitor and measure
your environmental performance, to record information that allows per-
formance tracking of operational controls and conformance with the
objectives and targets, and to evaluate compliance with environmental
regulations (Figure 6-6, work step 5.1). This element leads to success
in determining real measurements that can be communicated inter-
nally or externally.

Determining what to monitor and measure and what information to
record is critical. The objectives and especially the targets of the EMS
are quantifiable and measurable so that progress toward achieving them
can be tracked. EMS measures are used as environmental performance
indicators. Legal and other requirements were considered in setting
objectives and targets so monitoring of effluents and air emissions are
measured and tracked. Key operational characteristics and param-
eters associated with significant environmental aspects are tracked
and can serve as measures. Choose the number of indicators care-
fully—too many create information overload and an ineffective system,
but too few mean you won't have enough information to make good
business decisions. To ensure good measurement, the key questions
to answer are the following:

MONITORING AND
MEASUREMENT

WITH CORRECTIVE
AND PREVENTIVE
ACTIONS
5.1

Measure Environmental Performance

‘Track Operational Controls

‘Track Conformance with Objectives
and Targets

Evaluate Compliance with
Environmental Regulations

PERIODIC REVIEW
IMPROVE
BY MANAGEMENT EMEROENCY
IMPLEMENTATION RON
AND EFFECTIVENESS
52 53
Detect Overall EMS Trends Review and Update Procedures and
Review Corrective Actions Training After Accidents
for Continual Improvement
Provide Commitment and Support

Figure 6-6. Evaluation and Management Review.



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Indicators

During the planning stage, many organizations start considering the
use of indicators. An indicator is a metric that helps you understand where
you are, which way you are going, and how far you are from where you
want to be. Indicators can be based at the organizational level (e.g., envi-
ronmental training hours per worker, conservation of resources, reduction
in emissions, good housekeeping, operational and maintenance practices)
or at the government level (e.g., area-wide greenhouse gas concentra-
tions, biodiversity in major rivers, acres of trees impacted by acid rain).
Indicators are used to express the outcomes of the performance improve-
ments that are made in the P2 program and are further covered in the
“results” section of the quality model presented in Chapter 7. These envi-
ronmental results actually link the performance indicators with the cost to
and benefits for the organization.

Sustainable development programs use indicators that link
economy, environment, and the community. The element of commu-
nity represents both workers and the other interested parties associ-
ated with the organization. Examples of indicators are given in Box 3-2
(Reference 3-1).

ndfilled annually
Recycling Tate asa percentage of m
ercentage of residents, businesses, and institutions that partici-
pate in recycling programs
:... Recycled water use
.Mass of pollutants in wastewater
Number of enterprises adopting ISO 14001 standards
Number of hazardous materials incidents
Number of schools that integrate and progressively update environ-
mental education in their curricula
* Number of organizations with formal pollution prevention plans

These components of the P2 plan help determine the strategy of
the organization’s P2 program. The strategy or actions decided upon
reflect the way the organization plans to achieve its objectives and goals.
Organizations should develop strategies for every goal that it plans to
implement. A good way to develop these strategies is by preparing an
action plan. This tool and other tools useful in implementing P2 pro-
grams are discussed in Chapters 6 and 7.

CORE VALUES

Because the P2 program deals with change in the organization, it
is essential that you express the core values that must be achieved as

P2 Program Elements

An indicator is a metric that
helps you understand where
you are, which way you are
going, and how far you are
from where you want to be.

Sustainable development
programs use indicators that
link economy, environment,
and the community.

Organizations should develop
strategies for every goal that it
plans to implement. A good
way to develop these strate-
gies is by preparing an action
plan.