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DRAFT

SOURCE REDUCTION PLANS: A PROPOSAL

Ken Geiser

Center f o r Environmental Management Tufts University

March, 1985

What Is a Source Reduction Plan?

Source Reduction Plans could be an effective tool in reducing

the amount and degree of hazard of toxic chemicals in society.

A Source Reduction Plan is a document describing the means

and timing by which corporations will reduce the risks of

toxic chemicals in production. Source reduction is here

defined in its broadest form to mean the reduction of toxic

chemical risks not only at the point of waste, but throughout

the production operations. Further, production is defined

broadly to include all functions of an organization including

maintenance, repair and source. The objective of source

reduction is fundamentally the reduction in the risk of

human exposure to toxic chemicals and, instrumentally, the

reduction in use of toxic chemicals.

Today, there is emerging a hierarchy of processes recommended

for reducing toxic chemical exposure and toxic chemicals.

These include

a. chemical substitution (less hazardous chemicals

substituted for more hazardous chemicals)

b. chemical process changes (changes in prodcution

that result in less chemical use or safer chemicals

used)

C.

d.

e.

f.

g.

improving production management (reducing spills,

leaks, vaporization, etc. and reducing mixture

errors and bad production runs)

product substitution (producing less toxic

1

products or products that are less hazardous

to produce)

reclaiming, recycling and reusing chemicals

point of production treatment and detoxification

improving waste management (including improved

storage, transport and on site disposal)

Most all of these changes require

a. increased awareness and attention about toxic

chemi ca Is

b. increased motivation to change existing patterns

C. knowledge of potential options for change

d. willingness to experiment and change

e. resources to implement changes

f. willingness to follow through, evaluate and

learn from such changes

All of these elements are advanced when corporations prepare

Source Reduction Plans. A Source Reduction Plan then becomes

a guide for raising the level of attention about toxic chemicals,

increasing motivation to change, presenting alternatives,

guiding decision making, advocating for resources and providing

information to evaluate the consequences of changes.

How Would a Source Reduction Plan Work?

Let’s assume an ideal. The management of a metal plating

shop decides to do a Source Reduction Plan. The management

hires an industrial engineering firm to prepare a plan.

The consultant first identifies all of the chemicals used

in production, notes the most hazardous chemicals and rates

them with priorities for attention. Next the consultant

notes the most hazardous uses of the high risk chemicals

and ranks those as well. The consultant then reviews technical

or management options that would reduce the risks, beginning

with the highest risk points and working down. Then the

consultant finds examples of experience of other firms with

these options or finds suppliers of equipment or services

that would implement the options. Then the consultant prepares

cost estimates for each option for each of the risk points

selected. Then the consultant considers payback periods,

liability reduction incentives, commercial or public financing

and effects on product pricing, profits and investment attractiveness.

Finally, the consultant, working with the management and

workers, analyzes changes, prepared schedules and projects

targets for future evaluation. As a final product, the

consultant prepares a planning document, with schedules

and projected risk reduction targets.

Following this model, the Source Reduction Plan document

would have as a minimum four elements.

a.

b.

C.

d.

a comprehensive inventory of all toxic and

hazardous chemicals used in the plant

a ranking of the chemicals as to priorities

for source reduction

a list of planned process changes that would

reduce the risk associated with the highest

priority chemicals

a schedule and set of performance targets that

would link process changes to reductions in

volume or degree-of-hazard of process chemicals

or waste

This then would constitute a Source Reduction Plan.

What Should Be the Role of the State?

In the ideal world a responsible management concerned about

toxic chemical liability would be currently trying to reduce

toxic exposure and a plan would be a sound way to advance

this. Here we can leave the world of ideals. Most managers

have little incentive to expend corporate resources on activities

that are costly, are risky, have other than short term benefits,

are not also being done by competitors and'are not required

by law. Even managers interested in reducing some chemical

exposures may not think comprehensively, may focus on the

easy to reduce, but insignificant, risks, may not know

about options and may have no way to assess benefits. Further,

it is not corporations that are advancing the goal of lowered

chemical risk. It is the public, acting through government, I

that is pressing for safer workplaces and less chemical

pollution. This public is not unjustifiably skeptical of

corporate volunteerism. Source reduction must somehow make

corporations accountable to the public. Further, it is

only the government that is in an effective position to

set rules equally for all firms and industries.

There are also administrative reasons for government encouragement

of Source Reduction Plans. Amendments to the federal Resource

Conservation and Recovery Act passed last year focused increased

government attention on "waste minimization." The new regulations

require that waste manifests certify that the volume and

toxicity of the waste has been reduced to the maximum degree

economically feasible and that the biennial waste generator

reports indicate efforts to reduce waste volumes and the

degree of success achieved by these efforts. Thus the government

is already slowly creeping into a significant role in requiring

source reduction planning.

The public role in Source Reduction Plans could then be

significant. Policy options include

a. State mandated plans for all corporations. The

state requires all chemical using corporations

to prepare and submit Source Reduction Plans

b.

C.

d.

State mandated plans for specific industry

classifications. The state identifies the

top twenty or so industries that use toxic

chemicals and targets them

State required plans as a condition of state

action.

all corporations applying for grants or loans,

or permits and licenses or exemptions and tax

credits

State urging corporations to prepare plans.

State could provide training and education

and moral persuasion.

The state could require plans from

While any of these options might be considerec , the strongest and most effective policy option would be the first: state

mandated plans for all chemical using corporations. Such

a policy would be far-reaching and dramatic. It would serve

to raise attention throughout the state and it would create

a significant market for technical assistance.

What Role for Technical Assistance?

While the state should put itself squarely on line in demanding

that corporations begin now to reduce toxic exposure risks,

the state should as much as possible stay out of the technical

aspects of how firms go about this business. The state

does not have the resources or skills to train corporate

managers in new industrial processes. There are thousands

of corporations in the state, most with highly specific

conditions, resources and commitments. The state could

never effectively service all of them. Yet the state does

need

a. to effectively monitor the preparation and

implementation of Source Reduction Plans, and

to guarantee that hundreds of small businesses

get the technical help they need to stay in

business, but meet the goals of source reduction

b.

A l o o k at Massachusetts' recent experience with the "right

to know" law suggests a model. Few who struggled to achieve

passage of this law foresaw that it would create a small

market for technical assistance into which innumerable consultant

firms would leap. This experience suggests that mandating

Source Reduction Plans would likely create a similar market.

A s a means of inducing innovation and the diffusion of innovations,

this service industry has significant value, both to corporations

and the state. For corporations there would be technical

assistance services that could prepare Source Reduction

Plans, help broker equipment and financing packages, oversee

production changes and train employees in new processes.

For the state there would be a pool of technical consultants

who could be hired to review Source Reduction Plans filed

by corporations, assess plans, service small firms and monitor

corporate progress in achieving the objectives of the plans.

What Role for Local Communities?

While fairness and effectiveness both dictate that the state

should set the requirements and timetables for Source Reduction

Plans, it does not follow that the state should be the primary

agent for monitoring and compliance. After all, toxic exposure

is a local event. Local communities have the most to gain

from reducing the risk of chemical contamination. Local

officials and community residents have much to learn and

say about the kind of health and safety conditions that

should exist within their municipalities. Local participation

also builds a borader base of support for source reduction

and provides for the development of a public constituency

for this and further programs.

Several options exist at the local level. Local Boards

of Health, or fire companies or tax collectors, or hazardous

waste coordinators or right to know coordinators, or special

officially appointed committees could review Source Reduction

Plans and periodically assess progress and compliance. There

is probably a lot here to recommend special local Boards

of Public Safety that unite hazardous waste coordination,

right to know coordination, fire, police and civil defense

functions. Such local Boards of Public Safety, while not

necessary to implement Source Reduction Plans, would be

an attractive new local institution for coordinating and

monitoring the health and safety environments of local communities.

Nor should the voice of workers be neglected here. Employees

of local firms often are intimately familiar with the current

production processes in a firm.

with practical and inexpensive ideas about production improvements.

Local workers and unions might play an important role in

helping to develop Source Reduction Plans, to review and

comment on plans and to monitor plans for compliance.

of local unions might add depth and insight if also included

on local Boards of Public Safety.

Workers often are filled

Representatives

What About Enforcement and Compliance?

The preparation and filing of a Source Reduction Plan has

much value in its own right. Attention would be raised

and options explored. Public access to such plans would

provide some incentive toward implementation, due to the

perceived threat of embarrassing corporations in default

of their plans. Yet, perhaps, there needs to be some "bigger

stick." Corporations that fail to file plans of course

should be penalized with some significant weight.

corporate papers is always possible, but perhaps something

more like fines or civil sanctions would do. Failure to

Revoking

follow out a plan must, in fairness, be more judicial.

Many factors could lead to failure to implement. If local

communities are to monitor plans, there must also be local

discretion and the right to negotiate and alter plans.

The incentive at this point might be no more than a referral

to state sanctions, such as loss of permits, licenses or

access to public resources. An interesting planning experience

in New Jersey offers a useful parallel here. In 1976 New

Jersey passed legislation that mandated that all firms that

purchased and used chemicals from a list of some 155 priority

chemicals report to the state quantities purchased and exactly

how those chemicals left the plant, either as product or

waste. This simple chemical inventory ran for three years

between 1978 and 1981, and covered all industries in the

state. During that period compliance was extremely high.

What Protections Do Corporations Have?

It is always best to start by assuming that corporate managers

will do their best to comply with social objectives. That

they fail, and fail often, is a lesson worthy of learning

anew each time. Yet corporations do need some protections

against arbitrariness, excessive burden and, particularly,

against losing competitive position. If local Boards of

Public Safety or other agents are designated as monitors

of compliance, then criteria need to be strict and limits

on local sanctions well marked. There also needs to be

an effectie appeals process that settles disputes and relieves

corporations of vindictiveness and harrassment at the local

level. Further, there will need to be careful trade secret

protections defined so that corporations may hide aspects

of production that truly yield competitive advantage. Much

of this was handled in the right to know legislation and

lessons learned there would be helpful here.

Another lesson learned from the right to know experience

is the value to corporations of having effective advance

notice and clear guidelines. Phasing in of mandates for

Source Reduction Plans could be tied to size of firm or

industrial classification. Targeting less than all firms

at once would lead to learning lessons as the program develops

and avoid the managerial and fiscal traumas of overwhelming

either business or government.

There is also no need to target all corporations equally.

Some corporations employ significant amounts of toxic chemicals,

while others may do little more than purchase janitorial

supplies.

by standard industrial category, by volume of hazardous

waste produced or by use of particular priority chemicals.

Those of particularly high priority could be targeted first

Priority could be given to corporations defined

or plans could be required of only certain of the priority

classifications.

Source Reduction Plans in the Larger Context

Source reduction planning does not solve the problems of

new, safer technology development or the access to capital

that firms may need to finance changes in production processes.

But planning does raise consciousness and attention, does

produce and communicate information and does provide the

basis for more effective action. Source Reduction Plans

are a tool for requiring the private sector to present its

responsibility for guaranteeing a less risky work and community

environment. But, such planning in the private sector must

be coordinated with public sector planning as well. The

aggregate of private Source Reduction Plans should provide

an effective base for the development of state Toxic Substances

Management Plans. The role of the state as regulator and

motivator must be carefully coordinated with private plans

to guarantee that transitions to less toxic production are

fair and comprehensive and do not overly burden any single

sectors or individuals. The state must therefore develop

and follow its own plans -- something on the order of a

Toxic Substances Management Plan.

Nor should the state act independently of its own local

districts. For local communities and local Boards of Public

Safety to effectively monitor and encourage firms to comply

with their own Source Reduction Plans, there will need to

be local plans as well. The private Source Reduction Plans

f . I

of all firms in a local city or town should easily become

the basis for local Hazardous Materials Management Plans

as well. Only with such careful coordination at both the

state and local levels can source reduction be advanced

as a benefit to industry, workers, residents and the larger

state commonwealth.