Growth& 

 Renewal

Performance Track 

Third Annual Progress Report
Location of Performance Track members
Table of Contents

Executive Summary 1

Introduction 3

About Performance Track 4

Members’ Commitments and Performance Improvements 8

Environmental Commitments 8

Environmental Performance Improvements 8

Member Achievements in 2003 10

Cumulative Achievements, 2000-2003 12

Charter Members’ Achievements 12

Caveats to the 2003 Results 13

Member Services and Incentives 14

Public Recognition 14

Special Recognition Within Performance Track 15

Corporate Leaders 15

Regulatory and Administrative Incentives 16

Networking and Learning Opportunities 18

Performance Track Partnerships 21

Partnerships with States 21

Partnerships with Other EPA Voluntary Programs 22

Performance Track Network Partners 23

The Performance Track Members’ Survey 24

Conclusion 26
ii
1

For the U.S. Environmental 

Protection Agency’s National 

Environmental Performance 

Track program (Performance 

Track), 2004 was a year 

of growth, renewal, and 

the achievement of several 

important milestones: 

• The program’s charter members 

completed their first three-year 

term in the program, and more 

than 75 chose to renew their 

membership. 

• Former EPA Administrator Mike 

Leavitt signed the first Performance 

Track Rule, which provides regulatory and administrative incentives 

to members.

• Administrator Leavitt met with 

state officials in October, 2004 

to discuss their support for 

Performance Track and other 

performance-based programs. 

The meeting led to a state-bystate survey by the Environmental 

Council of the States and an 

action plan to implement recommendations.

• Performance Track created a 

new Corporate Leader designation to recognize companies 

that demonstrate an exceptional 

corporate-wide commitment to 

environmental stewardship and 

continuous improvement.

• Senior managers from EPA’s 

Office of Water and Performance 

Track met in September with 

25 Performance Track members 

to share ideas on incentives. 

Performance Track also worked 

with the Office of Water to develop 

incentives tied to the review of 

National Pollutant Discharge 

Elimination System permits, the 

Clean Water State Revolving Fund 

program, and the effluent guideline 

planning process.

• Three EPA regions developed 

Performance Track challenge 

commitments, specific goals that 

members may choose to adopt in 

order to help address regional environmental priorities.

• Performance Track members 

reported another year of outstanding results, with especially significant reductions in energy and 

water use, the generation of solid 

waste, and emissions of hazardous 

air pollutants.

• Eighty-six percent of members 

reported that they are satisfied with 

the level of recognition they have 

received from Performance Track. 

• Performance Track worked with 

its trade association Network 

Partners to build interest in 

Performance Track through workshops, articles in magazines, and 

coordinated communications. 

EPA signed an agreement with the 

American Chemistry Council and 

the Synthetic Organic Chemical 

Manufacturers’ Association to 

achieve closer collaboration 

between Performance Track and 

Responsible Care®.

• The Performance Track 

Participants Association (PTPA), 

an independent association 

for members of the program, 

held meetings and maintained 

ongoing communications with 

Administrator Leavitt and headquarters staff, EPA regional offices, 

and states to help build support for 

Performance Track.

None of these accomplishments 

would have been possible without the 

partnerships that Performance Track 

has forged with members, states, 

industry groups, and PTPA, all of 

which are working hard to build the 

program’s value to members and the 

environment. This year of growth 

and renewal for Performance Track 

has strengthened the program, added 

new incentives for facilities to go 

beyond compliance with environmental laws, and set the stage for a successful future. 

Executive Summary

Performance Track

Fast Facts

• The program currently has 351 

members in 46 states and Puerto Rico.

• To date, Performance Track 

members report that they have 

collectively reduced their water use 

by more than 1.3 billion gallons 

— enough to meet the water 

needs of New York City’s 8 million 

inhabitants for a day.

• Members report that they have 

cut their generation of solid waste 

by nearly 600,000 tons, and have 

decreased their energy use by more 

than 8.4 trillion British Thermal Units 

(BTUs), enough to power more than 

80,600 homes for a year.

• In 2003 alone, Performance Track 

members report that they collectively 

reduced their energy use by 5.3 trillion BTUs, water use by 566.3 million 

gallons, and solid waste by nearly 

300,000 tons.
2
3

To the Maori of New 

Zealand, the curled emerging frond of a tree fern 

symbolizes growth and 

renewal, new life rising in a 

perpetual cycle. The koru, 

as the unfurling frond is 

known, is an apt depiction of EPA’s National 

Environmental Performance 

Track (Performance Track) 

program at the current stage 

of its development. At the 

end of 2003, Performance 

Track’s charter members 

completed their first threeyear term in the program, 

and more than 75 percent of 

them applied to renew their 

membership. Many of these 

facilities brought others with 

them to join the program for 

the first time.

The first renewal season was 

an important milestone for 

Performance Track, as well as a 

litmus test. The decision of so many 

members to renew is a testament 

to the program’s ability to attract 

and retain the nation’s top environmental performers. It also speaks to 

member facilities’ belief in the basic 

tenets of the program and to their 

faith that the program will continue 

to grow and flourish, providing new 

benefits and incentives to strengthen 

the business case for participation.

To that end, EPA added a number 

of important new benefits for 

Performance Track members in 

2004, including the signing of the 

first Performance Track Rule by 

Administrator Leavitt in April and a 

notice of proposed rulemaking that 

would add regulatory and administrative incentives for Performance 

Track members under the Resource 

Conservation and Recovery Act 

(RCRA). EPA estimates that the first 

Performance Track Rule will save 

eligible Performance Track members a 

total of more than $700,000 by 2007. 

The Agency also took new 

steps to encourage states to adopt 

Performance Track incentives, 

with positive results in a number 

of states. EPA signed Memoranda 

of Agreement with four additional 

states in 2004, for a total of nine, 

to coordinate Performance Track 

with state performance-based programs and initiatives. The Agency 

also negotiated an agreement with 

the American Chemistry Council 

and the Synthetic Organic Chemical 

Manufacturers Association to 

streamline the Performance Track 

application process for Responsible 

Care®-certified facilities.

Performance Track created a new 

Corporate Leader designation to 

recognize companies that demonstrate an exceptional corporate-wide 

commitment to environmental stewardship and continuous improvement. The program also conducted 

its first survey of members to assess 

the value that they perceive from 

Introduction

“ The Performance 

Track program 

encourages 

companies to 

set their own 

environmental 

goals and stretch 

themselves to meet 

them. Performance 

Track promotes 

a more beneficial 

relationship with 

regulatory agencies, 

as it moves away 

from commandand-control 

measures and 

holds companies 

accountable for 

achieving their own 

targets.”

 Shannon Cox

 Environmental Specialist

 Interface Fabrics Group
4

the program. Seventy-six percent of 

current members responded to the 

survey, providing valuable feedback 

that will help EPA focus its efforts 

on future benefits.

About 

Performance Track

Now in its fifth year, Performance 

Track recognizes and rewards facilities that consistently exceed regulatory requirements, work closely 

with their communities, and excel 

in protecting the environment and 

public health. 

EPA provides exclusive regulatory and administrative benefits 

to members, places them at low 

priority for routine inspections, and 

offers public recognition, networking opportunities, and other benefits. But Performance Track facilities 

do not rest on their laurels: among 

the criteria for membership are a 

commitment to challenging environmental goals and a dedication to 

continuous improvement. Members 

report annually on progress toward 

their goals.

This report presents the achievements of Performance Track 

members for the year 2003, along 

with cumulative results since 

the program’s inception in 2000 

and final results from the charter 

members’ first full three-year cycle. 

It also describes the program’s new 

benefits, services, and incentives, 

including those announced during 

the first three months of 2005, 

along with key findings from the 

Performance Track member survey. 

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Figure 1: Performance Track Environmental Performance Indicators

Applicants to the program choose from among these indicators when setting their performance goals. See the description on page 5.

acronyms

VOCs = Volatile Organic Compounds

NOx = nitrogen oxides

SOx = sulfur oxides

PM-10 = particulate matter
5

Program Structure 

Performance Track is operated 

by a core staff in EPA’s Office of 

Policy, Economics, and Innovation, 

and by Performance Track coordinators in each of the Agency’s 10 

regional offices. EPA staff work 

with state environmental agencies to 

review applications for the program, 

conduct site visits at member facilities, promote Performance Track and 

similar state performance-based programs, and develop program policy.

Membership Criteria

Any facility, large or small, public 

or private, in the United States and 

its territories may apply for membership in Performance Track. The 

program accepts applications twice 

per year, from February 1 to April 

30, and from August 1 to October 

31. An online application form is 

available at www.epa.gov/performancetrack/apps/app.htm.

To be eligible for membership, 

facilities must have:

1. A comprehensive, independently assessed Environmental 

Management System (EMS)

2. A record of sustained compliance 

with environmental laws

3. A commitment to continual environmental improvement

4. Community outreach activities

In meeting the third criterion, 

applicants commit to four quantitative goals for improving their 

environmental performance. Small 

facilities commit to two goals. 

Applicants choose their commitments from among the indicators 

listed in Figure 1 (page 4), such as 

materials use, air emissions, or land 

conservation. Commitments can 

include upstream improvements, 

such as increasing the recycled 

content of purchased materials 

or improving the environmental 

performance of suppliers; improvements to inputs, such as decreasing 

the use of energy and water; reductions in nonproduct outputs such 

as air emissions, waste, and discharges to water; and downstream

improvements, such as decreasing 

the expected lifetime energy or 

water use of products. Each facility chooses its commitments based 

on its individual environmental 

impacts.

In 2004, Performance Track 

instituted a “challenge commitment” policy to encourage members 

to address specific regional environmental priorities. Each EPA 

region decides whether to create a 

Performance Track challenge commitment, which is made available 

only to facilities within that region. 

Challenge commitments count as 

two performance commitments; 

thus, members that adopt a challenge commitment need only set 

three environmental performance 

commitments rather than four. 

To date, EPA Regions 1, 2, and 6 

have set challenge commitments. 

Region 1 (Connecticut, Maine, 

Massachusetts, New Hampshire, 

Rhode Island, and Vermont) challenges New England Performance 

Track facilities to commit to reducing their energy use and associated greenhouse gas emissions by 

5 percent. Region 2 (New Jersey, 

New York, Puerto Rico, U.S. Virgin 

Islands) challenges members to 

reduce energy use or air emissions 

from mobile sources by 10 percent, 

or reduce air emissions from nonmobile sources by 20 percent. 

Region 6 (Arkansas, Louisiana, 

New Mexico, Oklahoma, Texas) has 

created an air emissions challenge 

commitment for facilities in ozone 

non-attainment areas, challengEnvironmental 

Management Systems

An Environmental Management 

System (EMS) is a continual cycle of 

planning, implementing, reviewing 

and improving the processes and 

actions that an organization undertakes to meet its business and environmental goals. EMSs are designed 

to identify, assess, and reduce facilities’ environmental impacts. 

Most EMSs are built on a “Plan, Do, 

Check, Act” model, which leads to 

continual improvement based on:

• Planning, including identifying 

environmental indicators and 

establishing goals;

• Implementing, including training 

and operational controls;

• Checking, including monitoring 

and corrective action; and

• Reviewing, including progress 

reviews and acting to make necessary changes to the EMS.

Facilities applying to Performance 

Track certify that they have adopted 

and implemented an EMS, and that 

it has undergone an independent 

assessment. Details on the EMS 

criteria for Performance Track are 

available at www.epa.gov/performancetrack/program/ems.htm.
6

ing facilities to make at least a 15 

percent reduction of NOx

or VOCs.

Facilities are accepted into 

Performance Track for a three-year 

period, after which they may apply 

to renew their membership and 

select a new set of commitments.

Reporting, Monitoring, 

and Site Visits

For each year of their membership, Performance Track members 

submit an annual performance 

report documenting their results 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 performance and continued 

conformance with the program’s 

criteria.

In addition to monitoring performance through annual reports, EPA 

Performance Track staff and state 

officials visit a number of the program’s member facilities each year. 

A site visit allows EPA to verify 

information presented in a facility’s 

application, such as the quality of 

its EMS, and to review progress 

toward its performance commitments. EPA provides the facility 

with an assessment of its performance relative to other facilities 

in the 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 

establish a relationship with the 

facility’s key environmental staff and 

top management, which may facilitate discussions on ways to improve 

Performance Track and its benefits.

Beginning in February, 2004, 

Performance Track established a criterion that all new applicants must 

have had an independent assessment 

of their EMS within the three-year 

period prior to the date of application. Because this criterion did not 

apply to existing Performance Track 

facilities, EPA focused the majority 

of its site visits in 2004 on facilities 

that had not had an independent 

assessment at the time of their application.

EPA conducted site visits at 25 

Performance Track facilities in 

2004. Twenty-two of the visits were 

“traditional” site visits, focusing 

on whether the facility’s EMS met 

the Performance Track criteria and 

how the facility was progressing 

on its performance commitments 

and public outreach activities. 

The remaining three facilities were 

visited for the purpose of testing a 

different direction in assessments, 

focused on evaluating data quality 

and whether the implementation 

of an EMS resulted in measurable 

improvements in environmental 

performance. As EPA becomes 

confident that the new independent 

assessment criterion provides assurance that applying facilities have a 

working EMS in place, the Agency 

will conduct more of these performance-based site visits and fewer 

traditional site visits. 

Of the 22 traditional visits conducted, only four facilities were 

ISO-certified (the International 

Organization for Standardization’s 

environmental management standard). Of the remaining 18 facilities, 

half had self-assessed their EMSs 

and half had a third party — but 

not necessarily an independent one 

— assess their EMSs. EPA found 

areas for improvement at 10 of the 

18 non-ISO facilities, and these 10 

facilities have agreed to implement 

these improvements. EPA asked two 

of the 18 facilities to withdraw from 

the program due to severe deficiencies 

Featured Facility

U.S. Steel 

Clairton Works

U.S. Steel Clairton Works of Clairton, 

Pennsylvania, employs 1224 people and is 

the largest metallurgical coke plant in the 

country. Built in 1901, it was the first coke 

plant in the world. Major products include 

blast furnace coke, coke oven gas, light oil, 

anhydrous ammonia, elemental sulfur, and 

crude coal tar.

Clairton Works was the first U.S. “smokestack” facility to become ISO 14001 certified. 

When the facility joined Performance Track 

in 2001, it committed to reducing its steam 

use from 764,400 MMBtus to 752,400 

MMBtus per year during its three-year 

membership period. The facility reduced its 

steam use each year, and in 2003 showed 

a particularly impressive reduction from 

728,532 to 664,100 MMBtus — a level far 

beyond the facility’s initial commitment. The 

accomplishments in 2003 resulted from a 

series of efforts to identify opportunities 

to reduce steam use, followed by a variety 

of energy conservation projects, such as 

repairing steam leaks. One benefit of these 

reductions was that more of the coke oven 

gas produced at this facility can be used to 

replace the use of natural gas at sister plants 

in the area. 

In 2004, the Clairton Works facility renewed 

its membership in Performance Track. 

Between now and 2007, the facility intends 

to further reduce energy use by installing 

variable frequency drives and better metering 

systems. 
7

associated with their EMSs. Overall, 

the findings from EPA’s 2004 site 

visits are once again consistent with 

previous years’ results, in which the 

Agency found that most EMS issues 

were associated with non-ISO facilities or facilities whose EMS was not 

certified by a third party. This finding 

led to the implementation of the 

independent assessment requirement 

described above.

Membership Profile

Performance Track currently 

has 351 members in 46 states and 

Puerto Rico. Members represent virtually every manufacturing sector, as 

well as public-sector facilities at the 

federal, state, and local levels. 

By the end of February, 2005, 

Performance Track had reviewed 

nine rounds of applications, receiving 601 applications and accepting 

482. A total of 131 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; facility closure, sale, or 

reorganization; and failure to submit 

an annual performance report. Some 

members also chose not to renew 

their membership upon completion of their three-year membership 

term. In all cases, EPA encourages 

facilities to reapply to Performance 

Track when they are again able to 

meet the program criteria.

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Figure 3: Distribution of Performance Track 

Members Across Sectors

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Figure 2: Size of Performance Track Facilities
8

Performance Track facilities 

have set challenging environmental commitments 

and achieved impressive 

results. Many members 

have managed to improve 

their performance well 

beyond the levels in their 

commitments. 

Performance Track is a beyondcompliance program: improvements 

reported by members exceed those 

required by law. In addition, many 

members choose to reduce impacts 

in areas that are essentially unregulated, such as materials use, water 

use, energy use, habitat preservation, and greenhouse gas emissions. 

One of Performance Track’s key 

environmental benefits is its ability 

to promote voluntary progress on 

these and other unregulated issues.

Here we present the commitments 

of current members, environmental 

results reported for 2003, cumulative results for Performance Track 

since its inception, and the cumulative achievements of the program’s 

charter members, who completed 

their first three-year term in the 

program during 2003. The results 

are based on members’ annual performance reports for 2003, submitted to EPA in 2004 and available 

online at www.epa.gov/performancetrack/particip/index.htm.

Environmental 

Commitments

Performance Track members 

commit to at least four environmental goals (two for small facilities) 

that they aim to meet within the 

three-year term of their membership 

in the program. Table 1 summarizes the commitments of facilities 

accepted into Performance Track by 

the end of 2004. Collectively these 

members have pledged to:

• Increase their use of recycled 

content in purchased materials by 

137,493 tons;

• Reduce their use of hazardous 

materials by 20,468 tons;

• Reduce their water consumption 

by 4.16 billion gallons;

• Reduce their non-transportation 

energy use by 36.4 trillion British 

Thermal Units (BTUs);

• Expand the area of land set aside 

for conservation by 20,270 acres;

• Reduce their greenhouse gas emissions by 49,866 metric tons of 

carbon dioxide equivalents;

• Reduce their total discharges to 

water by 22,819 tons; and

• Reduce their generation of hazardous and non-hazardous waste 

by 235,570 tons.

Environmental 

Performance 

Improvements

Each year, Performance Track 

members submit a report on their 

environmental performance and 

other achievements during the previous year. EPA reviews each report to 

monitor performance and continued 

conformity with Performance Track 

membership criteria. 

Members’ Commitments and 

Performance Improvements

“ Performance Track 

members are at 

the forefront of 

innovation and 

environmental 

stewardship, 

fundamentally 

strengthening 

the relationship 

between business 

and government.”

 Stephen L. Johnson

 Acting Administrator, U.S. EPA
9

Categories and Indicators Number of Members With Goals* Projected Annual Improvement

by Year 3 of Membership

Upstream Materials Procurement

 Recycled content 44 137,493 tons (increase)

 Hazardous/toxic components 5 79 tons

Suppliers’ Environmental Performance

 Packaging materials 1 56 tons

 Hazardous materials 1 0.28 tons

Inputs Materials Use

 Hazardous materials 69 20,468 tons

 Ozone-depleting substances 3 33 tons

 Packaging materials 15 358 tons

Water Use

 Total water use 128 4.16 billion gallons

Energy Use

 Non-transportation energy use 153 36.4 million MMBTUs

 Transportation energy use 7 90,241 gallons

Land and Habitat

 Land and habitat conservation 29 20,270 acres (increase)

Nonproduct Outputs

Air Emissions

 Greenhouse gases 28 49,866 metric tons of CO2 equivalent

 Volatile organic compounds 46 700 tons

 Nitrogen oxides 21 2,406 tons

 Sulfur oxides 13 1,646 tons

 Particulate matter (PM-10) 7 88 tons

 Carbon monoxide 2 0.13 ton

 Air toxics 17 293 tons

 Radiation 1 1,117 Curies

Discharges to Water

 Biochemical oxygen demand (BOD) 7 1,056 tons

 Chemical oxygen demand 2 7,444 tons

 Total suspended solids 7 14,075 tons

 Toxics 9 130 tons

 Nutrients 4 14 tons

 Sediment from runoff 1 100 tons

Waste

 Non-hazardous waste 191 225,492 tons

 Hazardous waste 121 10,078 tons

Noise

 Noise 6 108 dBa**

Downstream

Products

 Expected lifetime waste (to air, water, land) 4 751 tons

*Values shown in this column represent the number of members whose goals for an indicator were included in the calculations for projected reductions.

Some goals were excluded from the calculations due to missing or nonstandard data. 

**A-weighted decibels, an expression of the relative loudness of sounds in air as perceived by the human ear.

Table 1: Current Performance Track Members’ Commitments

Accepted Through 2004
10

In many cases, the results reported 

by Performance Track members 

tell only part of the story. Some 

member facilities have improved 

their “eco-efficiency” by reducing 

their environmental impacts per unit 

of production. When these facilities’ 

production increases, they avoid 

impacts that otherwise would have 

occurred. For example, Performance 

Track facilities reported an absolute 

reduction in water use of 566.3 

million gallons in 2003, but when 

improvements in eco-efficiency are 

taken into account, they actually 

avoided using more than 1.9 billion

gallons of water. These avoidance 

figures are calculated by applying a normalizing factor (taking 

into account changes in production) to the actual impact during 

the baseline year to estimate what 

the impact would have been in the 

reporting year without environmental improvements. The reported 

actual environmental impact is 

then subtracted from this estimate, 

yielding the environmental impact 

avoided through the facility’s environmental performance improvements. Please note that the tables 

in this section present only actual 

reported results, not normalized 

estimates. The summary below discusses actual results except where 

indicated.

The aggregated results of 

members’ performance reports for 

the environmental indicators shown 

here may be strongly influenced by 

improvements or declines in performance at large Performance Track 

facilities — such as a major reduction or increase in energy use at a 

large, energy-intensive factory.

Although EPA works closely 

with members to standardize their 

reporting, not all data submitted 

by members could be standardized 

before this report went to print. The 

tables and graphs in this section 

indicate how many commitments 

contributed to the results shown.

Member 

Achievements 

in 2003

Performance Track facilities 

achieved outstanding results in 

2003, especially for their reductions 

in energy use, water use, emissions 

of hazardous air pollutants, and 

solid waste. However, there was an 

overall increase in members’ use of 

materials and hazardous materials 

in 2003, and an increase in certain 

discharges to water. 

Energy Use

Performance Track members 

reported an overall 2.5 percent 

decrease in energy consumption 

between 2002 and 2003, saving 

more than 5.3 trillion BTUs. On 

a normalized basis, taking into 

account changes in facilities’ 

production, Performance Track 

members avoided 14.8 trillion BTUs 

of energy use in 2003, equivalent 

to the amount used by more than 

140,000 average homes in a year.

Water Use

Members reported a 1.25 percent 

decrease in water use between 

2002 and 2003, saving more than 

566 million gallons of water. As 

with energy, the amount of water 

use avoided by improvements in 

eco-efficiency is much larger: on a 

normalized basis, members avoided 

using more than 1.8 billion gallons 

of water.

Featured Facility

Henkel Loctite

Henkel Loctite in Olean, New York, 

manufactures electronic encapsulants, 

including molding powders, coating 

powders, and formulated liquids, such as 

urethane and epoxy systems. Henkel Loctite 

is a recent recipient of the Good Neighbor 

Award for the Environment from the Greater 

Olean Area Chamber of Commerce.

This Performance Track member facility, 

which has 228 employees, is committed to 

dramatically reducing the amount of noncontact cooling water used in its production 

processes. Since 2000, the facility has 

improved the water use efficiency of these 

processes by 61 percent. Henkel Loctite 

achieved this result by installing closed-loop 

chiller systems on the process equipment and 

a cooling tower for the chiller systems.

Featured Facility

Andersen 

Corporation

Andersen Corporation of Bayport, Minnesota, 

employs about 3,500 people at this location to 

manufacture windows and patio doors. One 

of its four commitments during its first three 

years as a Performance Track member was to 

reduce emissions of volatile organic compounds 

(VOCs). During calendar years 2001 through 

2003, Andersen reduced its VOC emissions 

from 1,775 tons to 1,391 tons by improving the 

efficiency of its wood treating processes and by 

incorporating a slower evaporating solvent into 

its window paint line pretreatment process.

The facility plans to reduce its VOC emissions 

by at least another 200 tons during its next 

three-year commitment (2004 through 2006) 

through process improvements to solvent-borne 

preservative and coating operations. Andersen 

continues to implement process improvement 

projects that align with the principles of lean 

manufacturing, including projects to increase 

transfer efficiencies in its paint line coating 

processes and alternative technologies and 

process improvements to reduce solvent-based 

wood preservation treatment. 
11

Indicator

Improvements 

made in 20031 Units

Number of 

results2

Energy use 5,327,423 MMBTUs 131

Water use 566,290,593 gallons 98

Materials use (26,017)3 tons 47

Hazardous 

materials use (1,576) tons 47

Use of reused/ 

recycled materials 62,933 (increase) tons 46

Greenhouse gases 28,103 metric tons of 

CO2 equivalent 42

Volatile organic 

compounds (VOCs) 565 tons 48

Air toxics 175 tons 19

Nitrogen oxides (NOx) 1,746 tons 19

Ozone-depleting 

substances 1.1 tons 5

Particulate matter 55 tons 12

Sulfur oxides (SOx) 2,635 tons 8

Solid waste 295,815 tons 160

Hazardous waste 1,763 tons 103

Land & habitat 

conservation 3,386 (increase) acres 27

Discharges of BOD, 

COD, TSS, nutrients 

to water4

(13,932) tons 19

Discharges of toxics 

to Water (5,489) tons 12

Product packaging 163 tons 6

1. Represents the difference between 2002 and 2003 actual quantities.

2. These numbers represent the number of commitment results included in the analysis, rather than the total number 

of commitments under the particular indicator. Some members’ results are not included in the analysis because their 

2003 Annual Performance Reports were not completed by the cut-off date.

3. Numbers in parentheses indicate an overall decline in performance.

4. BOD=biochemical oxygen demand; COD=chemical oxygen demand; TSS=total suspended solids.

Table 2: Performance Track Members’ 

Results for 2003

Air Emissions

Air emissions reported by 

Performance Track members 

decreased in 2003, with a 37 

percent reduction in emissions of 

hazardous air pollutants (air toxics), 

a 16 percent reduction in volatile 

organic compounds (VOCs), a 14 

percent decrease in nitrogen oxides 

(NOx), and a 12 percent reduction 

in sulfur oxides (SOx).

Solid and 

Hazardous Wastes

Performance Track members 

reported a 14 percent decrease in 

their generation of solid waste in 

2003, a reduction of nearly 300,000 

tons. Hazardous waste generation 

decreased by 1,763 tons, a 4.5 

percent reduction.

Land and Habitat 

Conservation

Members preserved or restored an 

additional 3,386 acres of habitat in 

2003, an area four times the size of 

New York City’s Central Park.

Materials Use

In the aggregate, members showed 

an increase in materials use in 2003. 

This was due largely to a 42 percent 

increase in production at one large 

facility. Not surprisingly, that facility showed an increase in materials 

use, but also showed an increase 

in materials efficiency. In fact, with 

production changes taken into 

account, members showed an aggregate improvement in their efficiency 

of materials use, avoiding 1,046 

tons of materials use in 2003. 

Hazardous Materials Use

Hazardous materials use increased 

in 2003, despite the fact that more 

than half of the members with 

commitments to reduce their use 

of hazardous materials showed 

improvements in efficiency. The 
12

result can be attributed almost completely to three facilities that, despite 

very good overall performance 

records, showed some negative fluctuations in hazardous materials use 

in 2003.

Discharges to Water

The results of commitments to 

reduce discharges to water were 

dominated by a decline in performance at two large facilities. 

Discharges increased by 19,421 

tons in 2003.

Cumulative 

Achievements, 

2000-2003

Since the inception of the 

program, Performance Track 

members have:

• Reduced their energy use by 

nearly 8.5 trillion BTUs, enough 

to power 80.5 million homes 

for a year;

• Reduced their water use by more 

than 1.3 billion gallons, enough to 

meet all of New York City’s water 

needs for a day;

• Reduced their generation of solid 

waste by nearly 600,000 tons;

• Reduced their generation of hazardous waste by 8,321 tons;

• Reduced their use of materials by 

74,562 tons;

• Reduced their use of hazardous 

materials by 16,420 tons; and

• Set aside 7,871 acres of land for 

conservation, an area larger than 

7,000 football fields.

Charter Members’ 

Achievements

During Performance Track’s first 

year, it accepted 253 facilities into 

the program. The results reported 

by these facilities, which completed 

their three-year term of membership 

in 2003, are presented here. These 

results represent the achievements of 

Performance Track’s first complete 

membership cycle. 

Among these members’ notable 

achievements were a reduction in 

energy use of more than 1 trillion 

Indicator

Cumulative 

Reductions Units

Number of 

Results1

Energy use 8,466,262 MMBTUs 131

Water use 1,341,708,688 gallons 98

Materials use 74,562 tons 47

Hazardous 

materials use 16,420 tons 47

Use of reused/ 

recycled materials 76,695 (increase) tons 46

Greenhouse gases Not available2 tons 42

Volatile organic 

compounds (VOCs) 1,017 tons 48

Air toxics 209 tons 19

Carbon monoxide 1.6 tons 2

Nitrogen oxides (NOx) 3,898 tons 19

Ozone-depleting 

substances 7.7 tons 5

Particulate matter 69 tons 12

Sulfur oxides (SOx) 16,257 tons 8

Solid waste 582,213 tons 160

Hazardous waste 8,321 tons 103

Land & habitat 

conservation 7,871(increase) acres 27

Discharges of BOD, 

COD, TSS, nutrients 

to water4

(12,530)3 tons 19

Discharges of 

toxics to Water (1,345) tons 12

Product packaging 1,829 tons 6

1. These numbers represent the number of commitment results included in the analysis, rather than the total number 

of commitments under the particular indicator. Some members’ results are not included in the analysis because their 

2003 Annual Performance Reports were not completed by the cut-off date.

2. Cumulative results for greenhouse gases are not available due to a change in reporting after 2002. In 2001 and 2002, 

all members reported total tons of greenhouse gas emissions; after 2002 the program began a transition to reporting 

emissions in terms of CO2 equivalents.

3. Numbers in parentheses indicate an overall decline in performance.

4. BOD=biochemical oxygen demand; COD=chemical oxygen demand; TSS=total suspended solids.

Table 3: Performance Track Members’

Cumulative Results, 2000-2003
13

Indicator

Cumulative 

Reductions Units

Number of 

Results2

Energy use 1,038,815 MMBTUs 77

Water use 1,932,873,264 gallons 67

Materials use 65,137 tons 35

Hazardous 

materials use 1,015 tons 29

Use of reused/ 

recycled materials 147,255 (increase) tons 23

Greenhouse gases 39,337 tons 41

Volatile organic 

compounds (VOCs) 850 tons 33

Air toxics (2,418)3 tons 8

Nitrogen oxides (NOX) 2,030 tons 9

Particulate matter 36 tons 9

Solid waste 518,069 tons 95

Hazardous waste (157,958) tons 64

Land & habitat 

conservation 5,492 (increase) acres 20

Discharges of BOD, 

COD, TSS to water4 (2,041) tons 9

1. These figures reflect the cumulative results from charter members and the second round of applicants; 

i.e., all facilities accepted in the first year of Performance Track.

2. These numbers represent the number of charter member commitment results included in the analysis, 

rather than the total number of commitments under the particular indicator.

3. Numbers in parentheses indicate an overall decline in performance.

4. BOD=biochemical oxygen demand; COD=chemical oxygen demand; TSS=total suspended solids.

Table 4: Performance Track Charter 

Members’ Cumulative Results1

BTUs — enough to power nearly 

10,000 households for a year — 

and a reduction in water use of 1.9 

billion gallons, enough to supply the 

water needs of more than 66,000 

homes for a year. 

Caveats to the 

2003 Results 

1. Data are self-reported by member 

facilities and not verified by EPA. 

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

rounded data.

3. The baseline year for members that entered the program in Rounds 4 and 

5 is 2001. Their results actually rep- resent changes occurring over a twoyear period.

4. The avoidance figures in the summary 

of 2003 results are based on the 

normalizing factors calculated and 

provided by individual facilities. 

A facility’s avoidance figures for 

2003 were calculated by dividing 

the 2003 normalizing factor by the 

2002 normalizing factor, multiplying 

that result by the 2002 performance 

level, and then calculating the difference between that product and 

the actual 2003 results. Thus, the 

accuracy of the avoidance figures 

depends on both the accuracy of 

the reported actual results and the 

reported 2002 and 2003 normalizing 

factors. Normalizing is an inexact 

science. Normalizing factors often tell 

an incomplete story about changes 

in production in a facility, and they 

often fail to explain fully the causes of 

environmental pollution or resource 

consumption. 

5. Approximately 15 percent of member 

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 thus reflect 

the commitments made and the 

results relevant to those commitments. 

Therefore, 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. 

6. Similarly, facilities’ commitments 

may relate to one “component” of 

an environmental indicator rather 

than to the indicator 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.
14

EPA offers exclusive benefits to Performance Track 

members in three key areas: 

public recognition, regulatory and administrative 

incentives, and networking 

opportunities. The Agency 

added a number of new benefits in 2004, and continues 

to develop additional incentives to attract and retain 

facilities in the program.

Public Recognition

When EPA publicly recognizes a 

Performance Track facility for its outstanding environmental performance, 

the facility’s reputation is enhanced 

among its regulators, peers, investors, customers, employees, and local 

community. The Agency recognizes 

Performance Track members through 

a variety of means.

• Upon request, EPA notifies elected 

officials at the local, state, and 

national levels when it selects 

new members for participation in 

Performance Track.

• The Agency works with trade 

publications, Performance Track 

Network Partners, and local 

media to place articles about 

members and the program. In 

2004, 81 publications carried 

articles about Performance Track, 

reaching a circulation of more 

than 2 million people.

• Facilities admitted to the program 

are recognized by senior EPA 

officials at the Performance Track 

Annual Members’ Event, and they 

receive a framed certificate of 

membership suitable for display.

• Performance Track members may 

use and display the Performance 

Track logo. The program’s 

Member Services site provides 

art files for hardhat stickers, fleet 

signage, and a flag. Some facilities 

have produced caps, shirts, and 

other items using the logo.

• Members are listed on the 

Performance Track website (www.

epa.gov/performancetrack), which 

has received more than 2 million 

visits since it was launched in 2000.

• Several leading social investment 

advisory firms, including Calvert 

Group, Innovest Strategic Value 

Advisors, and KLD Research and 

Analytics, include membership 

in Performance Track among 

Member Services 

and Incentives

Former EPA Administrator Mike Leavitt speaks about Performance Track 

at Hoover Dam, October, 2004.

“ We have demonstrated

that we are on a track 

toward continuous 

improvement 

and success in 

environmental 

performance. Joining

Performance Track 

was another way 

of challenging us 

to continue those 

successes.”

 Ken Gallant

 Environmental Supervisor

 International Paper-Bucksport
15

Performance Track 

Award Winners, 

2004-2005

Environmental Performance Awards 

2004

• Baxter Healthcare, Inc., 

Guayama, Puerto Rico

• Pfizer, Inc., Lititz, Pennsylvania

• Bridgestone/Firestone South Carolina, 

Graniteville, South Carolina

• The City of Scottsdale, 

Scottsdale, Arizona

2005

• Durango-McKinley Paper Company, 

Prewitt, New Mexico

• Ideal Jacobs Corporation, 

Maplewood, New Jersey

• Rohm and Haas – La Mirada Plant, 

La Mirada, California

• 3M Nevada, Nevada, Missouri

Director’s Award for 

Mentoring, 2004

• New Hampshire Ball Bearings, Inc., 

Peterborough, New Hampshire

Director’s Award for 

Corporate Outreach, 2005

• 3M Corporation, St. Paul, Minnesota

Outreach Awards

2004

• American Ref-Fuel Company of 

Hempstead, Westbury, New York

• DuPont-Spruance Plant, 

Richmond, Virginia

• Pfizer, Inc.-Lincoln Operations, 

Lincoln, Nebraska

• Texas Instruments-Sensors and 

Controls, Attleboro, Massachusetts

2005

• International Paper, Franklin, Virginia

• Motorola GTSS Ocotillo, 

Chandler, Arizona

• Pfizer, Inc., Terre Haute, Indiana

• 3M ESPE Dental Products, 

Irvine, California

Special Commendation for 

Outstanding Achievement in 

Enviromental Management and 

Wildlife Habitat Restoration, 2004

• Monsanto Company, Monsanto, Iowa

(conferred jointly by Performance Track 

and the Wildlife Habitat Council)

the factors they consider in their 

rating analysis of companies. 

EPA also distributes Performance 

Track press releases via CSRwire, 

a globally syndicated social 

responsibility news service.

Special Recognition 

Within Performance 

Track

Performance Track members that 

achieve particularly outstanding 

results or make exceptional efforts 

to promote the program may be eligible for special recognition. 

• The Performance Track 

Environmental Performance Award 

recognizes members that have demonstrated exemplary environmental 

performance during their participation in the program. 

• The Performance Track Outreach 

Award recognizes current 

members that make a special 

effort to inform the public about 

what it means to be a member of 

the Performance Track program. 

• The Performance Track Director’s 

Award recognizes members that 

the director has selected for outstanding achievements in any one 

of several areas, including mentoring, recruiting, public outreach, 

and community leadership.

Corporate Leaders

In 2004, Performance Track added 

the Performance Track Corporate 

Leader designation to recognize 

companies that have multiple facilities in Performance Track and that 

demonstrate an exceptional corporate-wide commitment to environmental stewardship and continuous 

improvement. EPA will designate a 

select number of Performance Track 

Corporate Leaders each year for a 

five-year membership.

Performance Track Corporate 

Leaders meet all of the following 

criteria:

• At least five of the company’s 

facilities are members of 

Performance Track;

• The company’s facilities that are 

enrolled in Performance Track 

and/or in similar state performance-based programs represent 

at least 25 percent of its U.S. 

operations, based on the number 

of facilities or employees (alternatively, the company has at least 25 

facilities in Performance Track);

• The company commits to increasing its level of Performance Track 

membership to at least 50 percent 

of its U.S. operations within five 

years of designation (alternatively, 

the company commits to having at 

least 50 of its facilities enrolled in 

Performance Track and/or similar 

state programs within that period).

• The company makes environmental issues a priority at the 

corporate level and uses a system 

to identify, prioritize, manage, 

measure, review, and continuously 

improve environmental performance throughout operations;

• The company demonstrates a 

strong compliance record with 

environmental regulations; and

• The company commits to improve 

its environmental performance 

and that of its suppliers and/or 

customers.

The first three Performance Track 

Corporate Leaders, selected by 

EPA and announced in early 2005, 

are Baxter Healthcare, Johnson & 

Johnson, and Rockwell Collins. For 

more information, see www.epa.

gov/performancetrack/corporateleaders/
16

Regulatory and 

Administrative 

Incentives

Performance Track members’ 

history of strong compliance, commitment to measurable improvement, 

and effectiveness in environmental 

management set them apart from 

other facilities. Accordingly, EPA 

believes they should be eligible for 

exclusive regulatory and administrative benefits. These benefits help 

Performance Track facilities focus on 

continuous improvement by reducing 

some of the routine administrative 

costs of regulation, and by allowing 

them additional procedural flexibility 

in certain cases. Performance Track 

regulatory and administrative incentives can also help regulatory agencies 

focus their assistance, inspection, and 

enforcement resources on higher priorities, such as facilities that require 

closer oversight.

Developing and 

Institutionalizing 

Incentives 

EPA’s general approach to developing regulatory and administrative 

incentives for Performance Track is 

to focus first on policy or administrative changes and then regulations. 

Within these broad categories, the 

Agency works to develop innovative incentives that are available to 

Performance Track members; that 

reduce burden, increase flexibility, 

and streamline and expedite processes; and that will be applicable 

widely among existing and likely 

future member facilities. 

The process to develop, propose, 

and finalize changes in a federal 

regulatory program typically takes 

at least two years. Once finalized, 

each state must first adopt the 

changes and then reapply for authorization to implement the regulatory 

program. This stage of development 

varies across states and according to 

the media covered by the regulation, 

such as air or water. States are not 

required to adopt federal regulations 

for Performance Track because it is 

a voluntary program.

Progress on Incentives 

in 2004

EPA has made considerable 

progress during the past year to 

advance Performance Track’s 

ability to deliver quality incentives 

to members. On Earth Day, 2004, 

former EPA Administrator Mike 

Leavitt signed the first Performance 

Track Rule. This rule provides benefits to eligible Performance Track 

facilities under the Clean Air Act 

and the Resource Conservation and 

Recovery Act (RCRA), described 

in the air and waste sections below 

under “Current Regulatory and 

Administrative Incentives.”

Within the Agency, Performance 

Track staff have continued to 

develop relationships with EPA’s 

program offices. In September, 

senior managers from the Office 

of Water and Performance Track 

met with 25 Performance Track 

members to share ideas on incentives and discuss key water program 

issues. Performance Track also 

worked with the Office of Water 

to develop incentives tied to the 

Clean Water State Revolving Fund 

program and the effluent guideline 

planning process. 

Performance Track staff interact 

with regulatory officials at EPA 

headquarters and regional offices 

to help spread implementation of 

the first Performance Track Rule, 

and program staff participate frequently in conference calls among 

Performance Track 

Corporate Leaders 

Baxter Healthcare Corporation, a 

global medical devices, pharmaceuticals, and biotechnology company, 

has eight of its 16 major facilities and 

two smaller facilities in Performance 

Track. Among Baxter’s future commitments as a Corporate Leader are 

further reductions in energy use, 

further reductions in solid waste, 

and increasing the number of its key 

suppliers participating in EPA’s Green 

Suppliers Network.

Johnson & Johnson is a healthcare 

products and services company. 

More than three-quarters of its 46 

major facilities and 15 of its smaller 

ones are members of Performance 

Track. As a Corporate Leader, J&J 

has pledged to further reduce its 

greenhouse gas emissions and water 

use, and increase its use of paper 

packaging derived from sustainably 

managed forests or with recycled 

content

Rockwell Collins provides design, 

production, and support of communications and aviation electronics. 

Eight of its 14 major facilities and 

two of its smaller ones are Performance Track members. Among its 

commitments as a Performance Track 

Corporate Leader are a pledge to 

purchase 10,000 Megawatt-hours 

of renewable energy certificates per 

year, improving the environmental 

performance of key suppliers, and 

reducing its purchase of chemicals.

State Support for the 

Performance Track Rule

Eleven states report that they have 

adopted the Resource Conservation 

and Recovery Act (RCRA) provisions 

of the first Performance Track Rule, 

including Colorado, Florida, Georgia, 

Idaho (adopted but not yet finalized), Maryland, New Jersey, North 

Carolina, Pennsylvania, Tennessee, 

Virginia, and Washington. The rule 

also is available in states or territories 

where EPA administers the RCRA 

program, including Alaska, Iowa, and 

Puerto Rico.
17

RCRA permit writers and regional 

air toxics coordinators to provide 

regular updates and encourage them 

to consider incentives for members.

Finally, Performance Track and 

other EPA staff have been working 

externally with key organizations, such as the Environmental 

Council of States (ECOS), the 

Association of State and Territorial 

Solid Waste Management 

Officials, the Association of State 

and Interstate Water Pollution 

Control Administrators, and the 

Performance Track Participants’ 

Association to build support for 

Performance Track incentives at the 

state and local level.

Current Regulatory and 

Administrative Incentives

Low priority for 

routine inspections

Since the beginning of the 

Performance Track program, EPA 

has placed members at a low priority for routine inspections. This 

benefit has been successfully implemented at the federal level in each 

of EPA’s 10 regions. Twelve states 

have adopted this policy to date, 

and the Agency continues to encourage broader state support for this 

important benefit of membership in 

Performance Track.

Air incentives

The first Performance Track Rule 

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 has made 

progress on developing new air 

incentives since last year’s report. At 

that point EPA was developing flexible permits for major air sources. 

These permits typically include 

provisions that approve in advance 

process changes that would otherwise require major permit modifications. These types of permits have 

been found to save facilities and 

states substantial time and money 

over the life of the permit, and lead 

to more significant reductions in air 

emissions. Flexible permits are currently in the final stages of development at three Performance Track 

facilities, and will be available for 

public review and comment in the 

spring of 2005.

Waste incentives

Under the first Performance Track 

Rule, EPA allows Performance 

Track members that are largequantity generators of hazardous 

waste up to 180 days (instead of the 

normal 90 days) to accumulate their 

hazardous waste without a RCRA 

permit or interim status.

Geoff Grubbs, director of EPA’s Office of Science and Technology, addresses 

Performance Track’s September, 2004 meeting with the Office of Water.

Spotlight on 

Performance Award 

Recipients, 2004

Baxter Healthcare Corporation’s

facility in Guayama, Puerto Rico, 

reduced its hazardous waste by 

195,000 pounds in its first two years 

of membership, along with reducing 

its energy use by 57,000 MMBTUs. 

It also reduced its generation of solid 

waste by 62 percent and its biological oxygen demand (BOD) discharges 

to water by 95 percent.

Pfizer Global Manufacturing in Lititz, 

Pennsylvania, reduced its total solid 

waste by 820 tons and its hazardous waste by 780 tons during its 

first two years in Performance Track. 

It reduced its total energy use by 

more than 3.6 million kilowatt-hours, 

and cut BOD discharges to water by 

82,000 pounds.

Bridgestone-Firestone South Carolina, in Graniteville, South Carolina, 

avoided the generation of 22 million 

pounds of solid waste over two years 

and improved its energy use efficiency by 19 percent.

The City of Scottsdale, Arizona,

reduced its total energy use by 

more than 300,000 kilowatt-hours 

and its emissions of volatile organic 

compounds by nearly 6,000 pounds. 

The city also reduced its generation 

of solid waste by 4,188 tons, a 31 

percent improvement.
18

Water incentives

As a followup to the September, 

2004 meeting with EPA’s Office 

of Water and Performance Track 

members, Performance Track 

staff worked with the Office of 

Water to develop a process to 

expedite the review of National 

Pollutant Discharge Elimination 

System (NPDES) permits held by 

Performance Track members. This 

process will be finalized in 2005. 

In 2004, EPA began encouraging states to provide more favorable terms to Performance Track 

facilities in their Clean Water State 

Revolving Fund (CWSRF) programs. CWSRF programs provide 

loans for a variety of water quality 

projects, including municipal 

wastewater treatment projects, as 

well as nonpoint sources, watershed protection or restoration, and 

estuary management. The CWSRF 

loans can help Performance Track 

facilities achieve environmental 

commitments that are important 

to state and local environmental 

priorities. The support also could 

encourage facilities to increase their 

community involvement, perhaps 

linking facilities with watershed 

groups. Working with Performance 

Track facilities also allows states to 

support activities that are beyond 

regulatory requirements. More 

information is available in EPA’s 

CWSRF fact sheet at www.epa.gov/

owm/cwfinance/cwsrf/performancetrack.pdf. 

Finally, in its analyses to determine whether to develop or revise 

effluent guidelines for various industry sectors, the Office of Water considers the sectors’ voluntary efforts 

to reduce water pollution, such as 

facility improvements through programs like Performance Track.

Looking Ahead

EPA is developing a new 

Performance Track rule for RCRA 

and expects to propose it in 2005. 

The Agency is also expected to finalize a new RCRA Burden Reduction 

Rule that contains several provisions 

available exclusively to Performance 

Track facilities. In addition, EPA has 

proposed a hazardous air pollutants 

rule that provides compliance alternatives under MACT with special 

provisions for Performance Track 

members.

Performance Track’s work with 

the EPA Office of Water has moved 

forward with developments in expedited permitting, and EPA expects 

further developments in the coming 

year. In addition, Performance Track 

is working closely with the Air 

Office to develop more incentives 

for members, and to develop a rule 

for flexible air permitting. 

Networking 

and Learning 

Opportunities

Performance Track offers valuable opportunities for its members 

to learn from each other and share 

best environmental practices. The 

program also offers opportunities 

for members to meet EPA officials 

from national headquarters and 

regional offices.

Annual Members’ Event

Each year, Performance Track 

members and EPA officials gather 

for award ceremonies, panel discussions, and breakout sessions on 

topics important to Performance 

Track facilities and partners. This 

meeting is an excellent opportunity for members to meet EPA 

Performance Track staff, network 

EPA Acting Administrator Stephen 

Johnson praised the tremendous 

accomplishments of Performance 

Track members during the 2004 

Annual Members’ Event in Baltimore.
19

with their colleagues, learn about 

program developments, and share 

their experiences. 

Regional meetings

Each of EPA’s 10 regional 

offices holds periodic meetings for 

Performance Track members in 

its region. Some regions also have 

hosted recruitment workshops for 

facilities interested in learning more 

about the program, and several 

regions have organized special 

events to recognize top environmental performers. 

Teleseminars

All Performance Track members 

are invited to attend bimonthly 

seminars, conducted by conference 

call, on timely and relevant topics. 

In 2004, teleseminars were held on 

topics such as intangible drivers 

that link environment, health, and 

safety performance to shareholder 

value; efforts by Performance Track 

members to work on watershed 

issues; and an information session 

on the Chicago Climate Exchange. 

Past teleseminars have focused on 

such topics as lean manufacturing, 

the business case for including a 

wildlife habitat commitment under 

Performance Track, community 

involvement strategies, and flexible 

permitting.

Online Newsletter

P-Track News is a bimonthly 

newsletter that keeps Performance 

Track members informed of new 

program developments, member 

achievements, news from the EPA 

regions, a calendar of upcoming 

events, and other information of 

interest to members.

Resource Center and 

Case Studies

Performance Track’s website 

provides a Resource Center to help 

existing and prospective members 

learn more about Environmental 

Management Systems, Performance 

Track’s environmental improvement 

categories, industry-specific environmental performance resources, 

and more. The Resource Center also 

provides case studies highlighting the 

achievements of selected Performance 

Track members. The Performance 

Track Member Services site includes 

a series of Innovative Practices 

Spotlight articles that describe particularly innovative approaches that 

Performance Track members have 

developed to address environmental 

challenges. The Resource Center is 

available at: www.epa.gov/performancetrack/tools/index.htm.

Spotlight on 

Performance Award 

Recipients, 2005 

Durango-McKinley Paper Company,

in Prewitt, New Mexico, exceeded 

its materials use reduction goal by 

1,000 tons and showed a 20 percent 

improvement in materials efficiency 

during its first three years of membership in Performance Track. It 

reduced its water use by 2 million 

gallons per year and its landfill waste 

by more than 3,200 tons.

Ideal Jacobs Corporation, in Maplewood, New Jersey, reduced its solid 

waste to a mere 6 percent of its 

2001 levels in part by directly linking 

waste amounts to employees’ salaries 

and responsibilities.

Rohm and Haas’s plant in La 

Mirada, California, decreased its 

annual energy use by nearly 10,000 

MMBTUs and its generation of 

hazardous waste by more than 10 

tons. It also improved its water use 

efficiency by 7 percent in 2002 and 8 

percent in 2003.

3M Nevada, in Nevada, Missouri, 

has reduced its energy use by nearly 

50,000 MMBTUs, and cut its emissions of volatile organic compounds 

and toxic emissions by 57 percent.

Performance Track members in EPA Region 3 received certificates in October, 2004 

for renewing their membership in the program. Left to right: Marie Holman, U.S. 

EPA Region 3 Performance Track Coordinator; Charles Souders, Pfizer Global 

Manufacturing; Tom Murphy, Montenay Energy Resources of Montgomery Co.; Colleen 

Davis, U.S. Steel Clairton Works; Joe Loschiavo, DuPont Spruance; Phil Dahlin, 

Johnson & Johnson, McNeil Consumer & Specialty Pharmaceuticals.
20

Performance Track 

Participants’ Association

Performance Track members 

have formed a private, independent membership association that 

provides a forum for members of 

the program. Performance Track 

Participants’ Association (PTPA) 

members exchange information and 

benchmark best practices with each 

other, work closely with EPA in the 

development and implementation 

of Performance Track incentives, 

educate and inform the public and 

other stakeholders of the work 

being done by Performance Track 

members, and work toward educating and informing policy makers of 

the important role that Performance 

Track plays in improving the environment. PTPA organized the 2004 

Annual Members’ Event in cooperation with EPA, and has held meetings 

and maintained communications with 

the EPA Administrator and headquarters staff, EPA regional offices, 

and states to help build support for 

Performance Track. For more information, visit the association’s website 

at www.ptpaonline.org. 

Featured Facility

Arizona Chemical

Arizona Chemical of Pensacola, Florida, a 

facility with 43 employees, manufactures 

terpene-phenolic and polyterpene resins that 

are used in hot-melt adhesives, box-sealing 

adhesives, book bindings, chewing gum, and 

inks and coatings. This facility committed to 

reduce its toxic air emissions of xylene and 

ethylbenzene. By the end of its first year 

of participation in Performance Track, the 

facility had reduced its emissions of these 

two chemicals from 19,334 pounds to 9,258 

pounds. Reductions projects included tying in 

emissions from the distillation column to an 

existing vapor condenser, modifying the vent 

header, and installing equipment to remove 

toxics from wastewater, thus reducing air 

emissions from wastewater trenches and 

process sewers
21

EPA partners with states, 

trade associations, and other 

public- and private-sector 

organizations to promote 

Performance Track and collaborate with other performance-based programs.

Partnerships 

with States

EPA and state governments 

are partners in implementing 

Performance Track and delivering 

benefits to member facilities. EPA 

works with the states to advance 

the principle that high-performing 

facilities should be recognized 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 these programs were established prior to 

Performance Track’s inception and 

served as models for the national 

program, which in turn 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 facilities 

applying to Performance Track. 

To further facilitate this partnership, each year EPA organizes a 

conference for state and regional 

officials to discuss topics that 

are important to their varied, 

but aligned, performance-based 

programs. Sessions range from 

brainstorming the development of 

new incentives to presentations by 

program members, with a focus on 

providing an opportunity for participants to benefit from problemsolving discussions and exposure to 

state-of-the art approaches to measuring performance. 

Progress in 2004

In some respects, the most significant work between EPA and 

the states has taken place during 

the past year. On October 4, 

2004, former EPA Administrator 

Mike Leavitt hosted a discussion 

at the Environmental Council of 

States (ECOS) 2004 fall meeting in 

Oklahoma City. The Administrator 

invited senior managers from strong 

partner states as well as from EPA 

Headquarters and regional offices. 

Leavitt and state officials discussed 

the value of performance-based programs and the elements of these proPerformance Track Partnerships

“ Before we started 

in Performance 

Track, we’d 

reached a 

plateau in our 

environmental 

improvement at 

some of our plant 

locations. Now 

we’re leveraging 

Performance 

Track to help 

us with further 

improvements 

in reducing our 

environmental 

footprint.”

 Sara Ethier

 Director, Environmental Operations

 3M
22

grams that are important to future 

success. He then asked the states to 

advise him if they were interested in 

engaging in the necessary steps to 

support and meaningfully expand 

these leadership programs.

In response to this challenge, representatives from ECOS conducted 

a nationwide survey, polling states 

on their support for Performance 

Track and state performance-based 

programs. With responses from 41 

of the 50 states, ECOS was able to 

formulate goals and objectives for the 

coming year. The results showed that 

many states are interested in performance-based leadership programs and 

in learning how to improve them.

Another aspect of the ECOS 

research included a meeting of 

officials from ECOS, EPA, and the 

Performance Track Participants’ 

Association to obtain input 

from the perspective of performance-based program members. 

Participants in this meeting agreed 

to continue to work together to 

identify and target new states in 

the effort to expand the reach of 

performance-based programs. 

On January 13, 2005, ECOS 

issued its final report, which focused 

on recommendations for improving 

the effectiveness of performancebased environmental programs. 

The report made several specific 

recommendations: 1) to support 

state programs and state efforts to 

work with Performance Track; 2) 

to assure program support from all 

EPA program offices; 3) to provide 

incentives to participants faster; and 

4) to conduct more strategic marketing and education to promote the 

programs. These recommendations 

have been transformed into action 

plans that will be addressed by 

senior EPA management and ECOS 

representatives, with participation 

by members of Performance Track 

and state programs. This group will 

work toward meeting the action 

plans’ goals during 2005.

Agreements With States

States that wish to maximize the 

coordination of their performancebased incentive programs with 

Performance Track may enter into a 

Memorandum of Agreement (MOA) 

with EPA. To date, EPA has signed 

MOAs with nine states: Colorado, 

Georgia, Maine, Massachusetts, 

Tennessee, Texas, Utah, Virginia, 

and Washington. EPA is currently 

working to develop agreements 

with several other states. These 

MOAs provide a framework for 

joint recruitment, admissions, and 

delivery of incentives to program 

members. Through EPA’s MOA 

with Texas, for example, Texas and 

EPA have worked together on a 

plan to integrate their performancebased programs. That plan has been 

implemented on an incremental 

basis throughout 2004.

EPA and the states continue 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 federalstate partnership — the benefits of 

which will be reaped by the American 

public and the environment.

Partnerships 

with Other EPA 

Voluntary Programs

Many other EPA voluntary programs share Performance Track’s 

goal of achieving continuous environmental improvement. The Sector 

Strategies program works closely 

with 12 industry sectors to promote 

the use of EMSs, overcome regulatory and other barriers to environmental improvement, and improve 

the ability to measure performance. 

Featured Facility

Johnson & Johnson 

Pharmaceutical 

Research and 

Development

Johnson & Johnson Pharmaceutical 

Research & Development, L.L.C. of Spring 

House, Pennsylvania, is a campus of 

1,100 employees conducting research 

and development from laboratory-scale 

drug discovery to pilot-scale chemical 

development. Between 2000 and 2003, 

the facility reduced its annual solid waste 

by eight tons, despite a 22 percent growth 

in the number of employees, by making 

changes to its animal caging system; 

capturing waste from overspray powders 

and enzyme bead, and reselling it for reuse 

by an off-site third party; and implementing 

Design for the Environment principles, a 

systematic process to identify and minimize 

the environmental impacts of products and 

processes across their entire life cycle.

When this facility renewed its membership 

in 2003, it committed to making further 

reductions in waste generation and other 

improvements in waste management 

practices. 
23

Released in June 2004, the Sector 

Strategies Performance Report documents the environmental results that 

are being achieved in each of these 

12 sectors. This report can be found 

online at www.epa.gov/sectors/

performance.html. Several current 

members of Performance Track — 

among them Chicago White Metal, 

Bath Iron Works, Baker Petrolite, 

and the Port of Houston — built 

their qualifications for Performance 

Track by participating in the Sector 

Strategies program.

Members also are finding value 

in linking their Performance Track 

efforts with other EPA voluntary programs. For example, the Corporate 

Leaders are expanding their involvement in EPA’s Green Suppliers 

Network, as a way to influence the 

environmental performance of their 

supply chain. Many members also 

are linking their participation in programs such as Climate Leaders and 

the Resource Conservation Challenge 

with Performance Track. More information on the wide range of EPA 

voluntary programs is available at 

www.epa.gov/partners/programs/.

Performance Track 

Network Partners

Performance Track Network 

Partners are national trade associations, non-governmental organizations, and professional organizations 

that work in partnership with 

Performance Track to promote the 

program and its benefits. There are 

currently 22 partners in the program. 

EPA recognizes partners by 

acknowledging their efforts in publications and at Performance Track 

events. The Agency provides partners with materials to assist them in 

marketing Performance Track, and 

EPA representatives may be available to speak about Performance 

Track at partners’ conferences 

and meetings. If a partner has its 

own voluntary environmental performance initiative, EPA works 

with the partner to identify similarities to Performance Track and 

potential opportunities for further 

collaboration. The Agency periodically arranges opportunities for 

roundtables and other information 

exchanges involving network partners, agency decision makers, and 

EPA subject matter experts. 

In June, 2004, EPA signed a 

Memorandum of Agreement 

with two network partners, the 

American Chemistry Council 

(ACC) and the Synthetic Organic 

Chemical Manufacturers Association 

(SOCMA), to achieve closer collaboration between Performance Track 

and Responsible Care®. The new 

agreement will streamline the EMS 

component of the Performance Track 

application process for Responsible 

Care-certified facilities, including 

members of ACC, SOCMA, and 

ACC Responsible Care Partners. 

EPA also will coordinate with ACC 

and SOCMA on the scheduling 

of site visits to Responsible Care/

Performance Track facilities, minimizing disruption by combining the two 

programs’ site visits and audits wherever possible. In addition, EPA, ACC, 

and SOCMA will collaborate to share 

lessons and ideas on performance 

measurement between Performance 

Track and Responsible Care to 

increase awareness of Performance 

Track within the chemical industry.

In November, 2004, Performance 

Track and another network partner, 

the Wildlife Habitat Council (WHC), 

held a joint technical workshop at 

WHC’s 16th Annual Symposium in 

Baltimore, Maryland. During the 

workshop, EPA and WHC recognized a number of companies and 

facilities for their participation in both 

Performance Track and WHC. The 

facilities received a joint certificate of 

recognition for their commitment to 

outstanding environmental performance and wildlife habitat enhancement and restoration. Performance 

Track and WHC also conferred a 

special commendation to Monsanto 

Company’s facility in Muscatine, 

Iowa, for its outstanding achievements in environmental management 

and wildlife habitat restoration.

Performance Track 

Network Partners

• Academy of Certified Hazardous 

Materials Managers

• American Chemistry Council

• American Furniture Manufacturers 

Association

• The Associated General 

Contractors of America

• The Auditing Roundtable

• Cement Kiln Recycling Coalition

• Global Environmental & 

Technology Foundation & Public 

Entity EMS Resource Center

• Greening of Industry Network

• International Carwash Association

• National Association of Chemical 

Distributors

• 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

• Voluntary Protection Program 

Participants’ Association

• Wildlife Habitat Council
The Performance Track 

Members’ Survey

During the summer of 2004, 

Performance Track conducted an online survey to 

determine how members 

value the services provided 

by the program. Seventysix percent of current 

Performance Track members 

responded to the survey, providing valuable information 

that will help EPA determine 

the future benefits offered to 

members. Eighty-six percent 

of respondents reported that 

they are satisfied with the 

recognition they receive from 

Performance Track.

The survey produced the following 

key findings:

• The most important reason 

members join and stay in 

Performance Track is the opportunity for a collaborative relationship with EPA and the states. 

• Members want state buy-in of 

Performance Track. 

• Members want to publicize their 

Performance Track membership 

to the local community and local 

regulatory agencies. 

• Although regulatory incentives are 

not the primary reason for joining 

or continuing in Performance 

Track, members want to see the 

regulatory incentives expanded. 

• Members are aware of, and in 

general find useful, the services 

offered by Performance Track. 

Performance Track staff created 

a workgroup to develop an action 

plan that would address the survey’s 

findings. The actions are organized 

around cultivating more collaborative relationships, encouraging state 

support of the program, increasing 

community outreach, and continuing to expand incentives.

Among the action items in the 

plan are:

• Hold meetings on Performance 

Track incentives with each EPA 

program office and conduct 

follow-up;

• Develop new case studies that 

show how Performance Track 

contributes to environmental protection goals;

• Better publicize online tools for 

member community outreach; and 

• Set up meetings with regional administrators and state commissioners to 

discuss Performance Track.

EPA staff have begun to work 

on a number of the goals and will 

continue to work toward achieving all goals in order to improve the 

program for each member. The action 

plan is available online at www.epa.

gov/performancetrack/downloads/

survey_action_plan.pdf.

24

“ The Performance 

Track program 

makes sense 

from a business 

perspective. Not 

only in terms of 

costs vs. benefits, 

but also from a 

general public 

perception 

standpoint, by 

improving your 

image within your 

local community.”

 Leah Wood

 Environmental Counsel

 Associated General Contractors 

of America
25

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Figure 6: Survey respondents’ recommendations for ways 

Performance Track could improve the recognition members receive

“ The best thing 

about Performance 

Track is that it’s 

truly a partnership 

between businesses 

and EPA; it’s a 

great approach to 

address common 

environmental 

issues.”

 Steve Green

 Environmental Manager

 Nucor Steel Auburn, Inc
26

Conclusion

“ As aggressive and 

proactive stewards 

of the environment, 

we are honored 

to be a part of the 

program. That’s 

why we added 

the Performance 

Track logo to 

our company 

letterhead.”

 Rex Query

 Vice President and General Manager

 Nucor Steel

With the successful completion of its first three-year 

membership period and 

its first renewal season, 

Performance Track has 

passed an important milestone in its growth and 

development. By renewing 

their membership, more 

than three-quarters of 

Performance Track’s charter 

facilities demonstrated that 

they value the recognition 

and other benefits they 

receive from the program. 

At the same time, EPA and 

its partners worked hard 

to strengthen the business 

case for membership in 

Performance Track by developing new incentives and 

encouraging broader support 

of Performance Track incentives by states. 

The member survey conducted 

during the summer of 2004 provided EPA with its first in-depth 

look at how members view the 

program. It helped the Agency identify the features that members value 

most, and provided clear direction 

for the steps that should be taken to 

add to that value in the future.

Performance Track launched a 

new Corporate Leader designation 

in 2004 to recognize companies 

that have multiple facilities in the 

program and that demonstrate an 

exceptional corporate-wide commitment to environmental stewardship.

Looking ahead, Performance 

Track will continue working to 

broaden and deepen its membership, enhance its business value and 

appeal as a standard of achievement, and increase the environmental value of the program. In 

March, 2005, EPA announced that 

it had selected 54 new Performance 

Track members in the most successful recruiting round since 2000. 

The Agency and its partners look 

forward to another year of growth 

and renewal for Performance 

Track as the program builds on the 

achievements and promise of 2004.

26
27

Notes
28

Notes
29

Notes
30

Recycled/Recyclable

Printed with Vegetable Oil Based Inks on Recycled Paper

(Minimum 50% Postconsumer) Process Chlorine Free

Office of Policy, Economics,

and Innovation (MC 1807-T)

EPA 240-K-05-002

www.epa.gov/performancetrack

April 2005