PERFORMANCE TRACK SECOND ANNUAL PROGRESS REPOR T 

Building 

on the 

Foundation 
Location of 

Performance Track Members 
Table of Contents 

1 

Executive Summary 2 

Why Performance Track? 3 

Building on Experience 3 

Program Structure and Criteria 4 

The First Year of Progress 7 

Performance Track Member Goals 7 

Performance Track Member Achievements in 2002 7 

Caveats to the Results for 2002 15 

Performance Track Members’ Cumulative Achievements, 2000–2002 16 

Promoting Continuous Improvement 17 

Recognition and Awareness 17 

Creating a Learning Network 18 

Regulatory and Administrative Incentives 19 

Working With State, Industry, and NGO Partners 22 

State Programs 22 

Performance Track Network Partners 23 

Federal Partners 25 

Performance Track Assistance 26 
This report describes the mission and activities of Performance Track, its 

members’ achievements to date, and the goals for the future of the program. 

In the less than four years since it was launched, Performance Track has: 

• rown to include 344 members, from among the more than 500 that 

have applied; 

• Enlisted broad corporate support from more than a dozen major companies; 

• Engaged 23 trade, professional, and environmental organizations in the 

Performance Track Network; 

• Improved environmental management systems at member facilities 

through site visits and outreach; 

• Advanced the measurement of environmental performance; 

• reated a learning community of members, government, associations, 

and prospective members; 

• Strengthened links among federal and state performance-based 

excellence programs; and 

• Developed proposals for regulatory and policy changes that allow for 

better environmental and business performance. 

Commitment to continuous environmental improvement is a core value of 

Performance Track. Since the program’s inception, Performance Track members 

have gone beyond legal requirements to reduce: 

• Energy use by 3.1 million MMBTUs 

• ater use by 775 million gallons 

• Hazardous materials use by 17,996 tons 

• Solid waste by 176,126 tons 

• Hazardous waste by 6,558 tons 

• Emissions of greenhouse gases by 40,193 tons 

• Emissions of nitrogen oxides (NOx) by 2,152 tons 

• Emissions of sulfur dioxide (SO2) by 13,621 tons 

• oxic discharges to water by 6,834 tons 

Members also increased their use of reused and recycled materials by 13,760 

tons and preserved or restored 4,485 acres of habitat. 

EPA will continue to build Performance Track by increasing the environmental 

and the business value of the program, increasing membership, and expanding 

program ownership among Agency programs, states, corporations, and trade and 

environmental groups. 

Executive Summary 

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The U.S. Environmental Protection Agency’s z (Performance Track) program 

recognizes and rewards facilities that consistently exceed regulatory requirements, work closely with their communities, and excel in protecting the environment and public health. 

Performance Track is based on the premise that government should complement existing programs with new tools and strategies that not only protect 

people and the environment, but also capture opportunities for reducing costs 

and spurring technological innovation. The program’s mission is to improve 

environmental performance, transform relationships, and encourage innovation. 

Performance Track encourages performance improvements by supporting environmental goals that go beyond compliance, offering recommendations during 

site visits, and providing opportunities for the sharing of information among 

members. The program transforms the relationship between regulators and regulated facilities to make them more collaborative, cooperative, and focused on 

results. Innovation is encouraged through peer networking, regulatory changes, 

and the program’s focus on fostering a culture of continuous improvement. 

Launched in June 2000, Performance Track currently has 344 members in 44 

states and Puerto Rico, representing virtually every manufacturing sector as well 

as facilities in the public sector. All U.S. facilities, large and small, public and 

private, may apply for membership. Applicants must meet a set of criteria to be 

accepted into the program. Once accepted, members receive a range of benefits 

and incentives to motivate and enable them to make further improvements. 

EPA is pleased to present this second progress report, which describes the 

mission and activities of Performance Track, its members’ achievements (both 

for 2002 and cumulative since the program’s inception), and highlights of 

program benefits. 

Building on Experience 

Performance Track builds on lessons that EPA has learned from state environmental leadership programs and from its own efforts, such as the Common 

Sense Initiative, the Environmental Leadership Program, and EPA Region 1’s Star 

Track program. Through these early initiatives, EPA learned the importance of 

keeping program design simple, keeping transaction costs low, and delivering 

measurable results. 

EPA’s initial proposal to develop Performance Track was published in its July 

1999 report, Aiming for Excellence. The Agency consulted extensively with stakeholders and state environmental agencies to develop and refine the proposal. 

The program was launched officially on June 26, 2000. EPA accepted 228 facilities 

as Charter Members during its first round of applications, welcoming them at a 

ceremony in Washington, DC, on December 13, 2000. 

Why Performance Track? 

“Performance Track 

provides recognition, 

regulatory flexibility, 

and other incentives 

that promote 

high levels of 

environmental 

performance, and 

provides a learning 

network where best 

practices can be 

shared. The results 

captured in this 

report demonstrate 

the value of such 

collaborative 

approaches between 

government and 

industry. 

Performance Track 

is delivering value 

to the environment 

and to its member 

facilities.” 

Mike Leavitt


EPA Administrator 


3

The structure of Performance Track consists of a core staff in EPA’s Office of 

Policy, Economics, and Innovation and of regional Performance Track 

Coordinators in each of the Agency’s 10 regional offices. EPA staff work with 

state environmental agencies to review applications to the program, conduct site 

visits at member facilities, promote Performance Track and similar state 

performance-based programs, and develop program policy. 

Performance Track accepts applications twice each year: from February 1 to 

April 30, and from August 1 to October 31. The Performance Track application 

can be found at www.epa.gov/performancetrack/apps/app.htm. 

The application was designed to be as clear and user-friendly as possible 

while gathering enough information to demonstrate that an applicant meets 

Performance Track’s criteria in four key areas: 

1. Establishing and maintaining a comprehensive environmental 

management system (EMS); 

2. Going beyond legal requirements as evidence of its commitment to 

continuous environmental improvement; 

3. Informing and seeking input from its local community about the facility’s 

environmental performance; and 

4. Maintaining a record of sustained compliance with environmental 

requirements. 

In meeting the second criterion, applicants commit to four quantitative goals 

for improving their environmental performance. Small facilities commit to two 

goals. Facilities choose these goals from among the indicators listed in 

Table A (page 6), such as water use, hazardous waste generation, or 

emissions of nitrogen oxides. 

Facilities are accepted into Performance Track for a three-year period, 

after which they can renew their membership by committing to four new 

goals (or two, for small facilities). 

Each year, members submit an annual performance report documenting progress toward meeting their goals and major activities undertaken 

as part of their EMS. This report is due on April 1 for the preceding calendar year. EPA reviews each report to monitor progress and continued conformance with Performance Track membership criteria. Results from the annual 

performance reports for 2002 are presented on pages 7–15. 

EPA designed Performance Track’s admission process to be simple and low in 

cost to both the Agency and facilities. Because the process does not include a 

site visit before each facility is selected into the program, EPA Performance Track 

staff and state officials visit up to 20 percent of Performance Track member facilProgram Structure and Criteria 

Size of 

Performance Track 

Facilities 

4

ities each year, based on available resources. A site visit provides EPA with the 

opportunity to verify the information presented in a facility’s application, particularly the quality of its EMS, and to review progress toward its performance goals. EPA provides an assessment of the facility’s programs and progress 

relative to other facilities in the Performance Track program and may suggest 

opportunities for improvements or partnerships with other firms and sources of 

technical expertise. The site visit also helps EPA and states to establish a relationship with the facility’s key environmental staff and top management. These relationships then can facilitate an ongoing dialogue between EPA and facilities on 

ways to improve Performance Track and its benefits. 

EPA conducted site visits at 24 facilities in 2003. The Agency focused these 

visits on facilities without ISO 14001 certification (the International Organization 

for Standardization's environmental management standard), because the first 

two years of site visits suggested that the EMSs at such facilities were less robust 

than those at certified facilities. Of the 24 facilities, only two were ISO 14001 

certified. EPA found areas for EMS improvement at 15 of the 22 non-ISO facilities. These findings are consistent with previous years’ results: because non-ISO 

facilities typically are not regularly evaluated by an independent auditor, they 

often are unaware of deficiencies in their EMS. The overwhelming majority of 

the 24 visited facilities are making good progress on their performance commitments and are maintaining active communication 

with their respective communities. Based on the findings from 

the first three years of site visits, EPA has revised the entry 

criteria for Performance Track to require facilities to have 

had an independent assessment of their EMS before they 

apply to the program. 

By the end of January 2004, Performance Track had 

reviewed seven rounds of applications, receiving 508 

applications and accepting 409. A total of 65 facilities have 

left the program since its inception. Facilities may be 

removed from Performance Track at their own request, for 

failing to continue to meet the program entry criteria, or for 

failing to submit a complete annual performance report. The most 

common reasons for leaving were: EMS deficiencies found during 

site visits (23 facilities), facility closure, sale, or reorganization (20 

facilities), and failure to submit an annual performance report (9 facilities). 

Thirteen facilities have left the program for other reasons. Note that facilities 

that left due to EMS deficiencies joined the program before the criteria for membership were revised to include an independent assessment of the applicant's 

EMS. In all cases, EPA encourages facilities to reapply to Performance Track when 

they are again able to meet the program criteria. 

Distribution of 

Performance Track 

Members 

Across Sectors 

5

TABLE A: Performance Track Environmental Performance Table 

Category Indicator Units 

Stage: Upstream 

Material Procurement Recycled content Pounds, tons 

Hazardous/toxic components Pounds, tons 

Suppliers’ Environmental Any relevant indicators from the As specified for the 

Performance Inputs or Nonproduct Outputs stages particular indicator 

Stage: Inputs 

Material Use Materials used Pounds, tons 

Hazardous materials used Pounds, tons 

Ozone depleting substances used CFC-11 equivalent tons, 

CFC-11 equivalent pounds 

Total packaging materials used Pounds, tons 

Water Use Total water used Gallons 

Energy Use Total (non-transportation) energy kWh/MWh or Btu/MMBTU 

use by fuel type 

Transportation energy use kWh/MWh, gallons, cubic feet 

Land Use Land conservation Square feet, acres 

Stage: Nonproduct Outputs 

Air Emissions Total GHGs


VOCs


NOx


SOx


PM10


CO


Air toxics


Odor


Radiation


Dust


Pounds, tons 

Pounds, tons 

Pounds, tons 

Pounds, tons 

Pounds, tons 

Pounds, tons 

Pounds, tons 

European Odour Unit 

Curies, Becquerels 

Pounds, tons 

Discharges to Water COD Pounds, tons 

BOD Pounds, tons 

Toxics Pounds, tons 

Total suspended solids Pounds, tons 

Nutrients Pounds, tons of Total N or P 

Sediment fr

Pathogens MPN/ml, CFU/ml 

om runoff Pounds, tons 

Waste Non-hazardous waste generation, Pounds, tons 

broken down by management method 

Hazardous waste generation, Pounds, tons 

broken down by management method 

Noise Noise dBA 

Vibration Vibration Inches per second 

Stage: Downstream 

Products Expected lifetime energy use kWh/MWh or Btu/MMBTU 

Expected lifetime water use Gallons 

Expected lifetime waste Pounds, tons 

(to air, water, land) from product use 

Waste to air, water, land from Pounds, tons 

disposal or recovery 

6

Performance Track members commit to making good-faith efforts to meet their 

performance goals within three years. Facilities commit to at least four environmental 

goals (two for small facilities), which they select from the categories and indicators 

shown in Table A on page 6. Table A is the Performance Track Environmental 

Performance Table and contains environmental indicators and measurement units 

organized by the stage in the life-cycle of a facility's process in which the environmental impact occurs. For example, the upstream stage contains those environmental 

impacts that occur before a facility's processes begin. Each facility chooses its goals 

based on its individual environmental impacts. For example, paper mills use large 

amounts of water, so many of the paper mills in Performance Track have committed 

to reducing water discharges. Facilities that use large amounts of solvent often 

commit to reducing their use of hazardous solvents or to reducing solvent emissions. 

Performance Track Member Goals 

Table B (see page 10) presents the three-year goals set by Performance Track 

members that were accepted through 2003. By fulfilling these goals, Performance 

Track members collectively will: 

• Reduce their emissions of volatile organic compounds by 704 tons, 

equivalent to the effect of taking approximately 45,000 cars off the road; 

• Reduce their annual energy consumption by 4.9 million MMBTUs, equivalent to the energy used by approximately 47,000 households in a year; 

• Reduce their generation of solid waste by 457,293 tons, roughly 2,000 

times the weight of the Statue of Liberty; 

• educe their water consumption by 5.2 billion gallons, enough to fill 

5,200 Olympic-size swimming pools; and 

• Increase preserved or restored habitat by 5,500 acres, an area 6.5 times 

the size of New York’s Central Park. 

Performance Track Member Achievements 

in 2002 

Performance Track facilities improved their environmental performance significantly during their first years in the program. All improvements reported to the 

program exceeded those required by law. Some of these achievements were in areas 

such as air pollution, water pollution, and solid waste, which have been the focus of 

environmental regulations and industry efforts for many years. Other achievements 

reduced impacts in areas that are recent or emerging environmental priorities and 

are essentially unregulated, such as materials use, water use, energy use, and habitat 

preservation. One of Performance Track’s key environmental benefits is its ability to 

promote voluntary progress on unregulated environmental issues. 

The First Two Years of Progress 

R

“We’re very proud of 

our environmental 

management 

system. Joining 

Performance Track 

allows us to 

demonstrate our 

environmental 

performance 

to others, and 

to continue to go 

above and beyond 

regulatory 

compliance.” 

Rick Rupert 

Environmental Engineer, 

Pro-Tec Coating Company 

7

This report presents results from the 2002 annual reports submitted by 

member facilities, as well as cumulative results for the program since its inception 

in June, 2000. Results are presented only for members admitted by the end of 2002. 

EPA received data on progress on 26 types of environmental impacts. 

Aggregate performance in 2002 improved in the following areas: 

• Air emissions (volatile organic compounds, nitrogen oxides, greenhouse 

gases, carbon monoxide, sulfur oxides, air toxics, particulate matter, 

ozone-depleting chemicals); 

• ischarges to water (suspended solids, biochemical oxygen demand, 

chemical oxygen demand, toxics); 

• Hazardous and nonhazardous waste; 

• onsumption of energy, water, materials, recycled/reused materials, and 

packaging materials; and 

• Habitat preservation and restoration. 

The graphs in this section may understate the aggregate achievements of 

Performance Track members. They do not include some results reported in nonstandard terms that could not be converted to common measures. EPA worked 

closely with many members to standardize their reporting so that their achievements could be included in this report, but not all data could be standardized 

before the report went to print. The graphs starting on page 11 show how many 

facilities contributed to the results shown. 

In addition to aggregate data, this section also presents achievements of 

individual Performance Track facilities that have improved their “eco-efficiency” 

by reducing their environmental impacts per unit of production. For example, 

member facility LSI Logic of Gresham, Oregon, in 2002 made more than 10 times 

the amount of semiconductors it made in 1999, but it used less than 4 times as 

much hazardous material. Thus from 1999 to 2002, LSI Logic reduced its use of 

hazardous material per unit by 66 percent, representing a significant improvement in eco-efficiency. 

One way of aggregating the eco-efficiency gains of individual facilities is to 

calculate the environmental impacts they have avoided. This is done by multiplying the actual impact during the baseline year by a normalizing factor (taking 

into account changes in production) in the reporting year to estimate what the 

environmental impact would have been in the reporting year without environmental improvements. The reported actual environmental impact is then subtracted from this estimate, and the result is the environmental impact avoided 

through the facility’s environmental performance improvements. 

Performance Track members showed eco-efficiency improvement in 62 percent 

of the impacts included in their 2002 reports. In 59 percent of the cases, they 

showed absolute reductions in impacts. Note that a facility with increasing production could increase its eco-efficiency while also increasing its environmental impact. 

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Each facility’s Annual Performance Report is available at the Performance Track 

Web site www.epa.gov/performancetrack/particip/index.htm. The following pages 

present Performance Track members’ progress during 2002 by type of environmental impact. 

Energy Use 

Members reported an overall 4 percent decline in energy consumption 

between 2001 and 2002, saving 2.9 million MMBTUs. On a normalized basis (taking 

changes in facilities’ production into account), Performance Track members avoided 

5.1 million MMBTUs of energy use in 2002, equivalent to the amount used by more 

than 48,000 homes in a year. 

Water Use 

Members reported a 1.4 percent decline in water use, saving 300 million gallons of water. On a normalized basis, however, members avoided 2.5 billion gallons 

of water, enough to fill almost 2,500 Olympic-size swimming pools. 

Materials Use 

Members reported a 23 percent decrease in materials use in 2002, a 54 percent 

decrease in the use of hazardous materials, and a 2 percent increase in the use of 

recycled or reused materials. 

Air Emissions 

Members reported decreases in nearly all areas of air emissions. The one exception was in toxic emissions to air, which increased 5.6 percent. However, on a normalized basis (accounting for changes in production), members avoided emitting 

22 tons of air toxics. In addition to the results shown here, four members reduced 

their emissions of ozone-depleting compounds by 60 percent. 

Solid Waste 

Members’ reports show that their generation of solid waste remained 

essentially flat in 2002, declining by less than one percent. On a normalized 

basis, however, members avoided 149,000 tons of solid waste in 2002, a 3.6 percent reduction from the reported level in 2001. Members reduced their use of 

packaging materials by 11 percent (21 percent decrease in avoided use on a 

normalized basis). 

Hazardous Waste 

Members reported a 22 percent reduction in their generation of hazardous 

waste, eliminating 5,866 tons of hazardous waste. 

Habitat Preservation and Restoration 

Members preserved or restored an additional 1,786 acres of habitat. 

Discharges to Water 

Members reported decreases in discharges to water, as measured by reductions 

in biochemical oxygen demand (BOD), chemical oxygen demand (COD), total suspended solids (TSS), and toxics. 

9

TABLE B: Performance Track Members’ Goals Accepted Through 2003 

Number of Members 

With Goals In Y

Projected Reduction 

ear 3 of Membership 

Energy Consumption 162 4.9 million MMBTUs1 

Water Consumption 147 5.2 billion gallons2 

Materials Use 

Total Materials Use 82 39,955 tons3 

Hazardous Materials Use 51 15,487 tons4 

Recycled/reused Materials Use 49 132,057 tons (increase)5 

Air Emissions 

Greenhouse Gases 58 178,749 tons6 

Volatile Organic Compounds 60 704 tons7 

Air Toxics 18 166 tons8 

Nitrogen Oxides 21 3,426 tons8 

Particulate Matter 14 41 tons9 

Sulfur Dioxide 11 10,197 tons 

Ozone-depleting Compounds 7 9 tons 

Carbon Monoxide 2 0.1 ton10 

Solid Waste Generation 220 457,293 tons11 

Hazardous Waste Generation 121 21,999 tons12 

Habitat Preservation 29 5,493 acres (increase)13 

Remediation 5 7,224 acres (increase)14 

Discharges to Water 

Biochemical Oxygen Demand (BOD) 12 900 tons15 

Chemical Oxygen Demand (COD) 5 12,271 tons 

Total Suspended Solids (TSS) 5 113 tons13 

Toxics 15 9,937 tons16 

Product Packaging Materials Use 12 1,348 tons17 

1 Represents commitments from only 138 members due to missing or nonstandard data. 

2 Represents commitments from 102 members due to missing or nonstandard data. 

3 Represents commitments from 55 members due to missing or nonstandard data. 

4 Represents commitments from 44 members due to missing or nonstandard data. 

5 Represents commitments from 42 members due to missing or nonstandard data. 

6 Represents commitments from 37 members due to missing or nonstandard data. 

7 Represents commitments from 54 members due to missing or nonstandard data. 

8 Represents commitments from 20 members due to missing or nonstandard data. 

9 Represents commitments from 8 members due to missing or nonstandard data. 

10 Represents commitments from 1 member due to missing or nonstandard data. 

11 Represents commitments from 156 members due to missing or nonstandard data. 

12 Represents commitments from 102 members due to missing or nonstandard data. 

13 Represents commitments from 26 members due to missing or nonstandard data. 

14 Represents commitments from 3 members due to missing or nonstandard data. 

15 Represents commitments from 11 members due to missing or nonstandard data. 

16 Represents commitments from 14 members due to missing or nonstandard data. 

17 Represents commitments from 9 members due to missing or nonstandard data. 

10

FEA TURED F ACILITY 

BASF Belvidere 

BASF Belvidere, an automotive 

coatings plant in Belvidere, 

New Jersey, has far exceeded 

its own goal for reducing the 

amount of hazardous materials used in its production 

processes. When the facility 

was accepted into 

Performance Track, it committed to cut its use of hazardous cleaning materials by 

25 percent over three years. 

But just one year later it 

already had decreased its use 

of the substances by 85 percent on a normalized basis 

(taking into account changes 

in production). This means 

that over its two years of 

membership, the facility 

avoided the use of 346,800 

pounds of hazardous cleaning materials. The facility 

replaced two circulating shot 

mills (used for grinding pigment) with dispersion equipment that requires much less 

material to clean between 

batches. The cleaning materials consist of resins and 

organic solvents containing 

a variety of volatile organic 

compounds. 

11

FEA TURED F ACILITY 

U.S. Department 

of Energy, 

Kansas City Plant 

The U.S. Department of 

Energy’s Kansas City Plant, 

operated by Honeywell 

Federal Manufacturing and 

Technologies, manufactures 

non-nuclear electrical and 

mechanical components for 

national defense. A charter 

member of Performance 

Track, the plant has made 

great strides in reducing its 

water use, avoiding 5.7 million gallons on a normalized 

basis from 2001–2002. 

The facility achieved its savings by installing a reverse 

osmosis system that treats 

industrial wastewater and 

recycles the treated effluent 

for use in the plant’s cooling 

towers. The treatment system 

not only reduces the facility’s 

water demand, but also 

places a lower demand on 

the city’s sanitary sewer. 

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FEA TURED F ACILITY 

Pfizer Inc. 

Pfizer Inc.’s facility in Lititz, 

Pennsylvania, has done an 

exemplary job of pollution 

prevention, monitoring, and 

reporting. Pfizer Lititz was 

the first pharmaceutical facility in the nation to achieve 

ISO 14001 certification, and 

is a charter member of 

Performance Track. The facility set challenging three-year 

goals and exceeded all of 

them during its first two 

years in the program. 

Between 2000 and 2002, on 

a normalized basis (taking 

into account increases in 

production), Pfizer Lititz 

reduced its generation of 

solid waste by 30 percent, 

hazardous waste by 

47 percent, energy use by 

25 percent, and biological 

oxygen demand discharges 

to water by 62 percent. The 

facility achieved its results 

through improvements in 

cleaning processes and manufacturing controls, and by 

implementing an energy cost 

reduction program. Pfizer 

Lititz also has begun developing an environmental 

accounting system and 

implemented or upgraded 

a number of other systems, 

procedures, and databases 

to further improve its environmental management 

and recordkeeping. 

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FEA TURED F ACILITY 

USGen New 

England, Inc. 

USGen New England, Inc., 

a hydroelectric firm based in 

Concord, New Hampshire, 

engages actively with communities and organizations 

in its service area. In 2002, 

USGen representatives met 

with several regional and 

community groups to 

describe Performance Track, 

USGen’s environmental 

progress under the program, 

and a variety of environmental issues of concern to the 

public. The company also 

distributed the Performance 

Track progress report to its 

visitor centers, local and 

regional environmental 

groups, and interested individuals. USGen is involved in 

community and regional 

environmental organizations, 

and has a team of employees who coordinate the 

company’s interactions with 

53 host communities and 

local, regional, state and 

federal stakeholders. 

14

1. Data are self-reported by member facilities and not verified by EPA. 

2. Although EPA asks for exact figures, some facilities appear to round 

their data. 

3. The baseline year for members that entered the program in Rounds 3 and 

4 is 2000. Their results actually represent changes occurring over a twoyear period. 

4. These numbers represent the number of members included in the analysis 

rather than the total number of members that have made commitments 

under the particular aspect. Some members’ results are not included in the 

analysis because their 2002 Annual Performance Reports were not completed 

by a cut-off date. 

5. The avoidance figures are based on the normalizing factors calculated and 

provided by individual facilities. A facility’s avoidance figures for 2002 were 

calculated by dividing the 2002 normalizing factor by the 2001 normalizing 

factor, multiplying that result by the 2001 performance level, and then calculating the difference between that product and the actual 2002 results. Thus, 

the accuracy of the avoidance figures depends on both the accuracy of the 

reported actual results and the reported 2001 and 2002 normalizing factors. 

Normalizing is an inexact science. Normalizing factors often tell an incomplete story about changes in production in facility, and they often fail to 

explain fully the causes of environmental pollution or resource consumption. 

Additionally, in cases where a facility did not provide a normalizing factor in 

2001, we assumed a 2001 normalizing factor of 1.0. This assumption could 

lead to both under- and over-estimates of the 2002 avoidance figures. 

6. Approximately 15 percent of facilities’ commitments relate to a specific process 

rather than to the facility as a whole. For example, a facility may have committed to reducing its VOC emissions from a particular production line by 50 

percent. The numbers reported in this document therefore reflect the commitments made and the results relevant to those commitments. It would be a misinterpretation of the data to assume that a demonstrated improvement is, or 

could be projected to, represent the performance of entire facilities. 

7. Similarly, facilities’ commitments may relate to one “component” of an environmental aspect rather than to the aspect as a whole. For example, a facility 

may commit to reducing one particular waste stream or one particular toxic 

air emission rather than to reducing its total solid waste or all releases of 

toxic chemicals. The parameters of each facility’s commitments may be determined by viewing its application and/or annual performance reports at 

www.epa.gov/performancetrack/particip/alphabet.htm. 

Caveats to the Results for 2002 

FEA TURED F ACILITY 

The Aaron 

Oil Company 

The Aaron Oil Company, of 

Saraland, Alabama, is an 

industry leader in public outreach and education on the 

recycling of used oil. An oil 

recycler and petroleum reclamation company, Aaron Oil 

has hosted two nationally 

broadcast video productions 

to better educate the public 

about oil recycling. The company participated in 

community-sponsored 

Recycling Day/Earth Day 

events, and supports local 

nonprofit organizations that 

collect used motor oil at collection centers throughout 

Alabama. Aaron Oil provides 

its services to the collection 

centers at no cost. 

FEA TURED F ACILITY 

Ricoh Electronics’ 

Ricoh Electronics’ Office 

Machine Group, in Tustin, 

California, has remanufactured more than 2,000 copier 

systems since 1996. More 

than 95 percent of the disassembled parts are recycled 

and used again during 

reassembly. Cover parts are 

cleaned with high-pressure 

water, which is 100 percent 

recycled. Empty document 

feeder boxes from copier 

production are given to 

remanufacturing for slide 

modification and reuse, 

saving $30 per box. 

15

The results presented on the previous pages show Performance Track 

members’ achievements for one year only (2002). Since the program’s inception in 

2000, Performance Track members have cumulatively achieved the following 

environmental results: 

• Reduced energy use by 3.1 million MMBTUs, enough to power nearly 

30,000 homes for a year. 

• Reduced water use by 775 million gallons, enough to fill 775 Olympic-size 

swimming pools. 

• Reduced hazardous materials use by 17,996 tons, a weight equivalent to 

60 Washington monuments. 

• Reduced solid waste by 176,126 tons, which is 787 times the weight of the 

Statue of Liberty. 

• Reduced hazardous waste by 6,558 tons. 

• Reduced emissions of greenhouse gases by 40,193 tons, equivalent to planting more than 11,000 acres of trees. 

• Reduced emissions of nitrogen oxides (NOx) by 2,152 tons, more than that 

emitted by 112,000 passenger cars in a year. 

• Reduced emissions of sulfur dioxide (SO2) by 13,621 tons. 

• Reduced toxic discharges to water by 6,834 tons. 

• Increased use of reused and recycled materials by 13,760 tons. 

• reserved or restored 4,485 acres of habitat. 

Performance Track Members’ 

Cumulative Achievements, 2000–2002 

P

16

EPA seeks to establish Performance Track as a “gold standard” for environmental performance—a standard that facilities will strive to attain. To encourage 

facilities to aim for this standard, EPA adds value to Performance Track membership 

through recognition, networking, and regulatory and administrative incentives. 

Recognition and Awareness 

With today’s heightened awareness of environmental concerns, facilities 

value their environmental reputations among their regulators, peers, 

investors, customers, employees, and local communities. Performance Track 

provides recognition for facilities, raising their environmental profile among 

these key constituents. 

Facilities admitted to the program are recognized by the EPA Administrator 

at the Performance Track Annual Members Event. They receive a certificate from 

the Administrator and may use the Performance Track logo to demonstrate their 

commitment to environmental excellence to their employees, customers, and 

their neighboring community. Many members display the logo on a flag outside 

their facility, and some facilities have produced caps, shirts, and other 

Performance Track logo items for their employees. The program’s new Member 

Services site provides art files for hardhat stickers, fleet signage, a flag, and other 

Performance Track logo items. 

EPA highlights members’ participation in Performance Track in letters sent to 

elected officials at the local, state, and national levels. Members’ achievements 

also appear in trade publications read by facilities’ peers and customers. 

In 2003, articles featuring Performance Track 

and its members appeared in 58 publications. 

Since the program’s inception, Performance Track 

has been featured in 174 articles, news stories, 

and other media coverage. The Performance Track 

Web site has received more than 930,000 hits since 

it was launched in 2000. 

EPA initiated discussions with two social 

investment advisory firms, Calvert Group and 

Innovest Strategic Value Advisors, which resulted 

in both firms adding membership in Performance 

Track to the factors they consider in their rating 

analyses of companies. KLD Research & Analytics, Inc., another socially responsible 

investment firm, also reviews Performance Track data for use in its environmental 

ratings of companies. In addition, Performance Track has begun distributing press 

Promoting Continuous Improvement 

“Since management 

quality is the 

primary driver 

of stock returns, 

environmental 

performance 

turns out to be an 

excellent indicator 

of stock market 

potential.” 

Frank Dixon 

Managing Director 

Innovest Strategic 

Value Advisors 

EPA Region 2 Administrator 

Jane M. Kenny (third from left) 

presents a Performance Track 

Outreach Award to Baxter 

Healthcare Corporation of 

Puerto Rico. 

17

releases through CSRwire, a corporate social responsibility news service that 

reaches a global network of two dozen syndication partners and more than 

5,000 journalists and investment analysts who track socially responsible initiatives. 

Performance Track provides special recognition to members who have made 

outstanding efforts on outreach and recruitment through the program’s annual 

Outreach Awards. Seven facilities received Outreach Awards in 2003. 

EPA continues to build brand recognition for Performance Track by marketing the program at important industry conferences, distributing media kits and 

video segments, and holding regional workshops. In 2003, Performance Track 

exhibited at 28 conferences around the United States, reaching approximately 

20,850 participants. 

Creating a Learning Network 

The Performance Track program helps members share best practices and 

lessons learned, effectively creating a learning network. 

Each EPA regional office holds meetings during which members exchange 

ideas with each other and with regional administrators and staff. These meetings 

also generate feedback and suggestions for improving and expanding the 

Performance Track program. Performance Track also holds tele-seminars to 

feature member facilities’ best practices. For example, representatives from 

Rockwell Collins and Lockheed Martin Manassas recently discussed their facilities’ 

efforts to capture and enhance the environmental benefits of lean manufacturing. Another recent tele-seminar featured a discussion of the business case for 

wildlife habitat improvements, with input from the Wildlife Habitat Council, 

Bridgestone/Firestone, Invista Corporation, and Rockwell Collins. 

Performance Track worked with the National Environmental Education and 

Training Foundation to develop a leadership practices database that helps facilities 

share information and learn from one another to improve their environmental 

performance. The database, which is online at www.greenbizleaders.com, 

includes all Performance Track members and their commitments. During 2003, 

the site received an average of 500 hits per day, with each viewer spending an 

average of 8 minutes on the site. 

Every two months, EPA publishes an online publication entitled “P-Track 

News” for members and other stakeholders. This electronic newsletter contains 

program updates, member achievements, and information on EPA activities of 

interest to members. 

Performance Track members have formed a private, independent membership association, the Performance Track Participants’ Association, that provides 

a forum for members, trade associations, and public entities dedicated to 

improving their environmental performance. Additional information on the 

Performance Track Participants’ Association may be found at www.ptpaonline.org. 

“We consider a 

company’s decision 

to participate in 

Performance Track 

a good indicator of 

its overall corporate 

environmental 

management and 

therefore we give 

credit in our 

environmental 

screening for 

companies that 

have enrolled two 

or more facilities in 

Performance Track.” 

Julie Frieder 

Environmental Analyst 

Calvert Group, Ltd. 

18

Regulatory and Administrative Incentives 

Members clearly value the recognition, networking, and learning benefits of 

participating in Performance Track. The program goes further, however, by 

working within EPA and with state agencies to offer regulatory and administra


tive benefits. Performance Track members’ history of strong compliance, commit


ment to measurable improvement, and effectiveness in environmental 

management distinguishes them from other regulated facilities, and EPA believes 

they should be eligible for special benefits. 

These benefits help members focus on continuous improvement by reducing 

some of the routine administrative costs of regulation and allowing them addi


tional procedural flexibility in certain cases. Performance Track’s regulatory and 

administrative incentives allow member facilities to operate more efficiently and 

to respond more rapidly to changes in their business environment. The benefits 

also enable members to dedicate more of their efforts to developing best prac


tices and identifying opportunities for innovation. 

The regulatory and administrative changes described below, some of which 

are still under development, benefit government as well as members of 

Performance Track. They enable agencies to focus their assistance, inspection, and 

enforcement resources on other higher priorities if they choose, such as facilities 

that require closer oversight. These agencies may exchange certain kinds of 

routine information (which is necessary for facilities with less exemplary records 

and capabilities) for information related to performance and management that 

may offer more value for government, customers, communities, and others. 

Cross-Media Incentives 

Low Priority for Routine Inspections 

Performance Track facilities are deemed by EPA to be a low priority for 

routine inspections. Generally, this means that Performance Track facilities 

will not be inspected unless there is reason to believe that a serious violation 

or threat to human health or the environment may exist at a facility. Senior 

enforcement officials in each EPA region are responsible for ensuring that 

this policy is implemented and incorporated appropriately into internal plan


ning and accountability processes. EPA will work with states to implement 

the low inspection incentive at the state level, although currently only a few 

states implement this incentive. 

The First Performance Track Final Rulemaking 

In Spring, 2004, EPA will finalize a regulation that is available only to 

members of Performance Track. This rule includes the following incentives: 

Extended Hazardous Waste Accumulation Period—The regulation allows large-quantity gener


ators of hazardous waste who are Performance Track members up to 180 days to accumulate 

their hazardous waste without a Resource Conservation and Recovery Act (RCRA) permit or 

interim status. 

Reduced Reporting Frequency for Air Sources—The regulation reduces the frequency of reports 

required under the Maximum Available Control Technology (MACT) provisions of the Clean Air 

Act such that semi-annual reports may be submitted annually, and in certain cases members 

may submit an annual certification for these requirements in lieu of an annual report. 

Performance Track Outreach 

Award Recipients, 2003 

• Baxter Healthcare Corporation 

(Puerto Rico-Aibonita) was 

instrumental in recruiting three 

Baxter facilities into 

Performance Track, securing 

management support for the 

program, and introducing 

Performance Track to key trade 

groups in Puerto Rico. 

• Ideal Jacobs Corporation 

(Maplewood, NJ) promoted 

Performance Track during 

numerous speaking 

engagements, provided many 

outreach opportunities for EPA, 

and promoted Performance 

Track in the small business 

community and within the 

printing industry. 

• Lockheed Martin Naval 

Electronics and Surveillance 

Systems (Manassas, VA) 

provided mentoring and 

technical assistance to 

prospective Performance Track 

members, developed education 

programs in the local 

community, and assisted EPA in 

promotional activities. 

• Madison Chemical Company 

(Madison, IN) conducted a direct 

mail campaign for Performance 

Track, spoke at conferences 

about the benefits of 

Performance Track, and 

targeted its communications 

toward facilities that fit the 

Performance Track model 

of excellence. 

• Motorola-IL02 (Schaumburg, IL) 

employees spoke regularly at 

Performance Track and other 

innovation events, hosted 

recruitment events, educated 

other Motorola facilities about 

program benefits, and helped 

forge relationships between 

Performance Track and 

key groups. 

• Norco Cleaners (Dolton, IL) 

made creative use of the 

Performance Track logo, 

participated in many speaking 

engagements, and increased 

Performance Track program 

awareness in community and 

political arenas. 

• Nucor Steel Auburn, Inc.(Auburn, 

NY) made creative use of the 

Performance Track logo, placed 

strategic articles on Performance 

Track, promoted Performance 

Track to key trade organizations 

in New York State, and was 

instrumental in the recruitment 

of a new Performance Track 

Network partner. 

19

“We’re looking at 

this as the future 

of how EPA and 

companies can 

work together.” 

Tom DayEnvironmental Health andSafety Specialist, HeidelbergWeb Systems, Inc.­

Air Incentives 

Flexible Permitting 

EPA is developing a number of flexible air permits for Performance Track 

facilities that are “major sources” under the Clean Air Act. The flexible 

permits typically include provisions that approve in advance process changes 

that otherwise would require a major permit modification. Flexible permits 

save facilities and states time and money, and may allow facilities to make 

advance approved process changes based on business conditions rather than 

permit conditions. 

Faster Agency Turnaround and a Designated Contact for Member Facilities 

The Clean Air Act and the National Emissions Standards for Hazardous Air 

Pollutants currently require sources of air pollutants to use MACT. EPA has 

proposed a rule that provides compliance alternatives for sources that reduce 

or eliminate their hazardous air pollutants. These alternatives are available to 

all facilities, not just Performance Track members. However, the ruling also 

proposes two provisions for Performance Track facilities only: 

Designated Contact—State permit engineers handling MACT flexibility applications from 

Performance Track members will be provided with a designated EPA Headquarters contact who 

will offer technical support and help expedite the application process. 

Faster Agency Turnaround—Performance Track facilities will receive a shorter turnaround time 

by EPA for facility applications for alternative compliance: 30 days instead of 45. 

tree-planting projects. 

A number of Performance Track 

facilities are improving wildlife 

habitat through efforts such as 

20

Water Incentives 

Reducing Procedural Burden and Adding Greater Flexibility for 

Top Performers 

EPA currently is exploring options to expedite the renewal of water permits 

and to reduce related monitoring and reporting for Performance Track 

members. The Agency also is discussing incentives that would be tied to the 

effluent guidelines planning process and state revolving fund program. As 

the planning process moves forward and decisions are made, Performance 

Track will keep members informed and solicit their feedback as appropriate. 

Waste Incentives 

Benefits to Performance Track Members Subject to RCRA Requirements 

Proposed RCRA Rulemaking for Performance Track—EPA intends to propose a 

new rulemaking in 2004 for Performance Track facilities that generate, treat, 

store, or dispose of wastes under the Resource Conservation and Recovery 

Act (RCRA). The rule may provide Performance Track members with flexibility 

in permitting, performance standards for hazardous waste generators, 

performance based tank standards, and flexibility in RCRA air requirements 

as long as controls and management practices are equivalent. 

Less Frequent Self-inspections for Performance Track RCRA Facilities—In 2003, EPA published a 

“Notice of Data Availability” that clarified the Agency’s intent to provide specific benefits for 

Performance Track facilities. Under this rule, the Agency would provide Performance Track 

RCRA facilities the opportunity to reduce self-inspections from 52 per year to as few as 12. 

Flexibility in RCRA Generator Standards—EPA intends to publish a “Notice of Information” that 

will solicit public comment on how RCRA standards could be improved. Included in this provi


sion is a section specifically asking the public what provisions could be made that would be 

appropriate for facilities that are members of Performance Track. EPA will use the public com


ments received to build the generator provisions in the “RCRA Rulemaking for Performance 

Track Facilities,” noted above. 

21

To promote Performance Track and coordinate it with other programs, EPA 

has established partnerships with states, trade associations, non-governmental and 

professional organizations, federal agencies, and other EPA voluntary programs. 

State Programs 

EPA and state governments are partners in implementing the Performance 

Track program and delivering benefits to member facilities. EPA works with the 

states to advance the principle that high-performing facilities should be recog


nized and rewarded for their accomplishments by enabling them to focus more 

on environmental progress than on process. 

Performance Track complements and builds on the successful environmental 

performance programs launched by the program’s state partners. Some of the 

state programs were established prior to Performance Track’s inception and served 

as models for the national program. The establishment of Performance Track then 

helped to spur the development of additional state programs. Although some 

state programs are rooted in EMSs and others in pollution prevention, they all 

support environmental performance that goes beyond compliance. 

EPA and the states believe they can achieve more by working together than 

by pursuing their goals independently. Therefore, representatives of EPA and 

state agencies are in frequent contact as they coordinate the development and 

implementation of their programs. EPA consults with states on policy issues such 

as member implementation of EMSs. States participate in site visits to Performance 

Track facilities, as well as in Performance Track member events at the national 

and regional levels. EPA considers state input crucial to its decisions on applicants 

applying to admit facilities into Performance Track. State governments implement 

and enforce many environmental requirements and frequently have greater 

knowledge of potential member facilities than EPA has. 

States that wish to maximize the coordination of their performance-based 

incentive programs with Performance Track may enter into a Memorandum of 

Agreement (MOA) with EPA. To date, EPA has signed MOAs with Colorado, 

Massachusetts, Tennessee, Texas, and Virginia, and is working with several others 

to develop state-specific agreements. These MOAs provide a framework for joint 

recruitment, admissions, and delivery of incentives to program members. Texas 

and EPA have worked together on a plan to integrate their performance-based 

programs, which is expected to be implemented incrementally throughout 2004. 

Beginning in August 2003, Virginia facilities that have been accepted into 

Performance Track no longer need to follow the traditional admission process for 

the Virginia Environmental Excellence Program (VEEP).The facility only needs to 

send a letter to Virginia’s Department of Environmental Quality (DEQ) requesting 

Working With State, Industry, and NGO Partners 

22

admission into the VEEP at the top-tier “E3” level. Virginia DEQ has determined 

that a facility’s Performance Track Annual Performance Report will satisfy E3’s 

annual reporting requirement, and it will waive the reapplication process for 

renewal in E3 for a facility accepted for a second term in Performance Track. 

These are just some of the steps EPA and the MOA States are taking to work 

together to enhance performance-based programs and reward program 

members for their leadership in environmental protection. Each step forward 

serves to affirm the growing strength of the federal-state partnership—the 

benefits of which will be reaped by the American public and the environment. 

Performance Track Network Partners 

EPA established the Performance Track Network (PTNet) to help promote 

Performance Track to key constituencies. Through PTNet, EPA collaborates with 

select national trade associations, nongovernmental organizations, and profes


sional organizations to inform top environmental performers about Performance 

Track and the benefits of membership. For example, the Wildlife Habitat Council 

created a special Performance Track page on its Web site, and WHC Executive 

Vice President Bob Johnson gave a presentation at a Performance Track tele


seminar in September, 2003. More than 20 Performance Track member facilities 

are also member sites of the Wildlife Habitat Council. 

PTNet leverages EPA’s efforts to market and brand Performance Track, retain 

current members, recruit new facilities, and share environmental insights and 

expertise with current and prospective program participants. 

EPA recognizes network partners by acknowledging their efforts in publica


tions and events, and gives them materials to help them market Performance 

Track. EPA officials also speak about Performance Track at partners’ conferences 

and meetings. 

Currently PTNet includes 23 partners: 

• Academy of Certified Hazardous Materials Managers 

• American Chemistry Council 

• American Furniture Manufacturers Association 

• American Textile Manufacturers Institute 

• The Associated General Contractors of America 

• The Auditing Roundtable 

• Cement Kiln Recycling Coalition 

• lobal Environment & Technology Foundation & Public Entity 

EMS Resource Center 

• reening of Industry Network 

• International Carwash Association 

• National Association of Chemical Distributors 

G

G

“As a corporation, 

one of our major 

objectives is to be 

a ‘best citizen.’ 

Performance Track 

is very well aligned 

with this goal and 

gives us the 

tracking mechanisms 

and indicators so 

that we are sure, on 

a continuous basis, 

that we are indeed 

a best citizen for 

our communities.” 

Eladio AlvarezPlant Manager, BaxterHealthcare Corporation23

“Performance Track 

underlines the fact 

that companies 

that reduce their 

pollution run more 

effectively and 

more profitably.” 

Andrew Jacobs 

President/Owner, Ideal Jacobs 

Corporation 

• National Defense Industrial Association 

• National Paint and Coatings Association 

• National Pollution Prevention Roundtable 

• National Ready Mixed Concrete Association 

• National Stone, Sand, and Gravel Association 

• NORA, an Association of Responsible Recyclers 

• North American Die Casting Association 

• Screenprinting & Graphic Imaging Association International 

• Steel Manufacturers Association 

• Synthetic Organic Chemical Manufacturers Association 

• oluntary Protection Programs Participants’ Association 

• ildlife Habitat Council 

Four of these partners joined the network in 2003: 

The Academy of Certified Hazardous Materials Managers, with more than 

5,000 members, fosters the professional development of hazardous materials 

managers. Its members are certified by the affiliated Institute of Hazardous 

Materials Management. 

The Auditing Roundtable is the professional organization for environmental, 

health, and safety auditors. The roundtable, which currently has 800 members, 

has established a code of ethics and standards for the performance of environ


mental audits. 

The International Carwash Association, with 3,000 members, serves the needs 

and represents the interests of carwash and detail shop operators. 

The National Defense Industrial Association serves more than 1,100 corpo


rate members and more than 29,000 individuals in the defense and national 

security industries. 

V

W

24

Federal Partners 

Performance Track has established agreements with federal agencies that 

share a common vision. In 2002, EPA signed a Memorandum of Agreement with 

the U.S. Occupational Safety and Health Administration (OSHA) to coordinate the 

two agencies’ efforts on their respective voluntary incentive and recognition 

programs: EPA’s Performance Track and OSHA’s Voluntary Protection Programs. 

The two agencies have pledged to explore opportunities to jointly recruit facilities 

into both programs; recognize facilities that participate in both programs; and 

communicate regularly to share program policies, procedures, and lessons learned. 

EPA signed a Memorandum of Understanding with the U.S. Department of 

Interior (DOI) in 2003. Under the agreement, DOI and EPA will work together to 

advocate the implementation of EMSs at DOI facilities, encourage the participa


tion of high-performing DOI facilities in Performance Track, promote 

Performance Track and EMSs to DOI facilities through internal publications, and 

other activities. 

Executive Order 13148 (Greening the Government Through Leadership in 

Environmental Management) requires federal agencies to provide leadership in 

Postal Service. 

the development and implementation of EMSs that help organizations sustain or 

exceed compliance with environmental regulations. The participation of federal 

facilities in Performance Track helps agencies fulfill the spirit and intent of 

Executive Order 13148. More than a dozen federal facilities currently are 

members of Performance Track, including sites operated by the National Park 

Service, NASA, the Navy, the Coast Guard, the Department of Energy, and the 

25

EPA is creating an “on-ramp” to Performance Track to help facilities qualify 

for membership. Performance Track works with other EPA programs and with 

state programs to build capacity among facilities interested in improving their 

environmental performance, compliance, and management. Through this assis


tance, businesses may, over time, qualify for higher-level tracks in state programs 

and for membership in Performance Track. 

The Performance Track Assistance Project (PTAP) helps trade associations work 

with their members to develop “better than compliance” EMSs that will meet the 

criteria of Performance Track as well as reduce facilities’ costs and increase 

competitiveness. These efforts are focused particularly on trade associations that 

work with small businesses. As a result of this work, several trade associations 

have decided to modify their EMS guidelines so that they meet the Performance 

Track EMS criteria. The Performance Track Assistance Project coordinates these 

efforts with state partners and with EPA’s Small Business Office, the Office of 

Environmental Policy and Innovation, the Design for the Environment Program, 

the Sector Strategies Program, and the Compliance Assistance Office. 

EPA’s Sector Strategies Program works closely with industry sectors to find 

solutions to the particular environmental challenges faced by facilities in each 

sector. These sector strategies often involve strengthening facilities’ EMSs, compli


ance records, community outreach, and continuous improvement efforts—the 

same qualifications needed for Performance Track membership. The Sector 

Strategies Program thus helps to nurture and identify good candidates for 

Performance Track. 

The Performance Track Mentoring Program assists facilities as they prepare 

their Performance Track application. Mentors, who are Performance Track 

members, help candidate facilities identify appropriate beyond-compliance goals, 

develop measures of progress, describe community outreach, and otherwise 

demonstrate that they meet Performance Track criteria. 

Performance Track Assistance 

26

27

Notes 

28


Office of Policy, Economics, 

and Innovation (MC 1808T) 

EPA-100-R-03-004 Recycled/Recyclable www.epa.gov/performancetrack Printed with Vegetable Oil-Based Inks on Recycled Paper

April 2004 (Minimum 50% Postconsumer) Process Chlorine Free