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POLLUTION STRATEGY
PRElVENTION
DRAFT FIVEFINAL DRAFT - MARCH 28,, ¶994
PREPARED BY THE GOVERNOR'S POLLUTtON PRLVLNTlON DXVELOPMSNT WORKGROUP
GSOROE V. VOINOVICH, COVRRNOR~
ACKNOWLEDGMENTS ~
The Pollution Prevention Strategy for the State of Ohio was developed by the Pollution Prevention Development Workgroup. This strategy contains recommendations to state government, businesses and consumers for implementing pollution prevention activities and proposes policy and program initiatives to promote pollution prevention throughout all sectors of Clhio.
On September 20, 1991, Governor Voinovich formed the Pollution Prevention Development Workgroup (PPDW) to promote pollution prevention activities tluoughout state government and in business and consumer activities. This strategy was prepared with advice and input from the following organizations representing state government, business and consumer interests. Representatives from these organizations who form the Pollution Prevention Development Workgroup are identified in Appendix A.
Ohio Hospital Association County Commissioners’ Assoaation of Ohio
Ohio Manufacturers’ Association Ohio Chapter of the Sierra Club
Ohio Chemical Council League of Women Voters of Ohio Ohio Chamber of Commerce Ohio Farm Bureau Federation
National Regulatory Research Institute Ohio Municipal League
Ohio Department of Administrative Services Ohio Department of Agriculture Ohio Department of Development
Ohio Department of Rehabilitation and Correction Ohio Environmental Protection Agency
Ohio Department of Health Ohio Department of Industrial Relations Ohio Department of Natural Resources
Public Utilities Commission of Ohio Ohio Department of Transportation
THE STATE OF OHIO POLLUTION PREVENTION STRATEGY
TABLE OF CONTENTS
"RODUC'ITON ................................................. 1 The Need for a Pollution Prevention Strategy .......................... 1 Objectives of the Strategy ....................................... 2
THlS CONCEPT OF POLLUTION PREVENTlON ........................... 2 Definition of Pollution Prevention .................................. 2 Difference Between Pollution Revention and Pollution Control . . . . . . . . . . . . . . 3 Applicability to Energy Efficiency. Water Conservation
and Process Efficiency ......................................... 4
C U l " T P O L L U T I [ O N P R E W N T I O N A ~ S ........................ 4 Government ................................................ 5 OhioEPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Ohio Department of Natural Resources. Division of Litter Prevention
andRecycling ............................................... 6 Ohio Department of Development, Ohio Edison Centers . . . . . . . . . . . . . . . . . . 7 Business and Industry .......................................... 7 Consumer Sector ............................................. 8
RECOMMENDATIONS FOR POLLUTION PREVENTION XNITIA'I'AES . . . . . . . . . . . 9 Policy Statement ..........................................
STATEGO .RNMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AdministrativeSupport ..................................... Educational Outreach and Promotion ............................ Procurement ............................................ Recycling Initiatives ........................................ Economic Incentives .......................................
Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Energy Efficiency. Water Conservation and Process Effiaency . . . . . . . . . . .
Technical Assistance ....................................... Policy Modifications ....................................... Research ............................................... Joint State Efforts ......................................... Regulatory Development .................................... Nonpoint Source Initiatives ..................................
Overcoming Institutional Barriers to Pollution Revention . Local and County Government Initiatives . . . . . . . I . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .
lBUSZNESSANDINDUSTRY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Technical Assistance ....................................... Education and Outreach .................................... Trade Association Involvement ................................. Small Business Assistance ................................... AgridturalInitiatives ...................................... Energy Efficiency. Water Conservation and Process Effiaenq Initiatives . . . .
. 9 11 11 11 12 12 13 14 14 15 16 16 16 17 18 18 18
20 20 21 22 23 24 25
THE STATE OF OHIO POLLUTION PREVENTIOI\T STRATEGY
TABLE OF CONTENTS (continued)
Compliance Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Economic Incentives ....................................... 26 VoluntaryManningPrograms ................................. 27
CONSUMER SECTOR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 EducationandOutreach .................................... 30 Economichcentives ......................................... 30 Energy Efficiency and Water Conservation Initiatives . . . . . . . . . . . . . . . . . 31 Citizen and Public Group Involvement ........................... 31 Purchasing Initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Technical Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Overcoming Barriers to Pollution Prevention ....................... 33 EducationaIOrganizations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Retailers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Labor Organizations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
SUGGESTED GUIDELINES FOR IMPLEMENTAION ...................... 36 Prioritization of Initiatives and Implementation ..................... 36 Implementation ofhitiatives ................................. 37
State Government . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Business and Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 Consumer Sector . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
IdenWicationofResources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 Recommendations Requiring Legislative Support .................... 43
CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
APPENDIX A:
APPENDK B: Definitions APPENDIX C: APPENDIX D: APPENDIX E: APPENDIX F: APPENDIX G: References
Pollution Revention Development Workgroup Mission Statement and List of Partiapants
Benefits and Barriers to Pollution Prevention Status of Environmental Protection in Ohio Detailed Summary of Current Pollution Prevention Activities Nonpoint Source Pollution Prevention
THE STATE OF OHIO POLLUTION PREVENTION STRATEGY
EXECUTIVE SUMMARY
In spite of impressive gains achieved by environmental regulation in the last two decades, regulations alone are not the answer to pollution and waste. Nor can there continue to be a focus exclusively on "end-of-pipe" pollution control. One of the primary methods for improving environmental quality lies in a systematic effort to prevent pollution before it occurs through the development and implementation of a pollution prevention strategy.
Pollution prevention primarily focuses on source reduction activities that minimize or eliminate waste before its generation, and as a secondary preference, recycling activities that beneficially use, reuse or reclaim a waste material. Pollution prevention is a " multi-media" concept encompassing all environmental media involving pollution released to the land, water and air. Pollution prevention practicea avoid cross-media transfers of pollutants from one environmental media to another. This pollution prevention strategy provides a basis for focusing and coordinating existing and proposed pollution prevention programs,
On September 20, 1991, Governor George V. Voinovich formed the Pollution Prevention Development Workgroup (PPDW) to promote pollution prevention activities throughout state government and in business and consumer activities, Ohio EPA coordinates this workgroup with participation and assistance from nine departments and agencies, and ten business and consumer groups. The purpose of the Pollution Prevention Development Workgroup (PPDW) is to develop and coordinate pollution prevention initiatives throughout state government, business and consumer activities.
?he Pollution Prevention Strategy (the strategy) for the State of Ohio was developed by the Pollution Prevention Development Workgroup and contains recommendations to state government, business and consumers in Ohio for implementation of pollution prevention activities. This strategy proposes initiatives to promote pollution prevention tl~roughout all sectors of Ohio.
The objectives of the Pollution Prevention Strategy of the State of Ohio are to define the concept of pollution prevention; provide a review of current pollution prevention activities; provide recommendations for pollution prevention initiatives for state government, business and consumer activities; and, suggest guidelines for implementing proposed pollution prevention initiatives.
The recommendations contained in this strategy were prepared to allow the flexibility to deade which recommendations will provide the greatest benefit to the State of Ohio and to implement those recommendations or groups of recomniendations that wilt provide the greatest degree of pollution prevention in a cost-effective manner.
Suggested guidelines for prioritizing and implementing recommendations contained in the strategy are identified in the Suggested Guidelines for Implemcmfafion section. The five highest priority recommendations for each of the three sectors covered in the strategy (State Govemment, Consumer and Business and Industy) are idenmed. Suggested guidelines are also provided for the remaining groups of recommendations. Funding mechanisms are also discussed and correlated to certain types of recommendations.
The five highest priority recommendations for the State Government Sector are in the areas of Administrative Support, Economic Incentives, Technical Assistance, Overcoming Institutional Barriers to Pollution Revention arid Regulatory Development. The five highest priority recommendations for the Business and Industry Sector are in the areas of Pollution Prevention Planning, Small Business Assistance, Compliance Assistance and Economic Incentives. The five highest priority recommendations for the Consumer Sector are in the areas of Technical Assistance, Education and Outreach and Energy Efficiency and Water Conservation.
A cooperative working relationship between government, business and consumers sectors is needed to ensure that recommendations are implemented in a cost effective and timely manner. The strategy identifies potential "lead" organizations for each recommendation. These organizations should involve all interested parties when directed to implement these recommendations.
The recommendations provided in this strategy were developed by the Pollution Prevention Development Workgroup in an effort to promote cost-effective pollution prevention programs throughout the State of Ohio. The policy and. program initiatives recommended in this strategy provide a framework for achieving substantial environmental improvements throughout all sectors of Ohio using pollution prevention. The members of the PPDW believe that impliementation of the recommendations provided in this strategy represent the next logical step toward achieving the environmental goals of the State of Ohio and that this strategy provides a basis for focusing and coordinating existing and proposed pollution prevention programs.
INTRODUCTXON
On September 20, 1991, Governor George V. Voinovich formed the Pollution Prevention Development Workgroup (PPDW) to promote pollution prevention activities throughout state government and in business and consumer activities. Ohio EPA coordinates this workgroup with participation a n d l assistance from nine departments and agencies, and ten business and consumer groups (listed in Appendix A). The mission statement of the PPIIW is also listed in Appendix A. The purpose of the Pollution Prevention Development Workgroup (PPDW) is to develop and coordinate pollution prevention initiatives throughout state government, business and consumer activities.
The Pollution Prevention Strategy (the strategy) for the State of Ohio was developed by the Pollution Prevention Development Workgroup and contains recommendations to state government, business and consumers in Ohio for implementation of pollution prevention activities. This strategy proposes initiatives to promote pollution prevention throughout all sectors of Ohio.
Recommendations in the strategy were prepared in order to provide the ma>;imum degree of flexibility in implementation. Many of' the reccnnmendations can be implemented as "stand alone" programs. These reccmmendations do not need to be implemented in a specific order to be effective. The recommendations contained in this strategy were prepared to allow the flexibility to decide which recommindations will provide the greatest benefit to the State of Ohio and to implement those recommendations or groups of recommendations that will provide the greatest degree of pollution prevention in a cost-effective manner,
Suggested guidelines for prioritking and implementing recommendations contained in the strategy are identified in the Suggested Guidelines for Impi'emenfation section. The five highest priority recommendations for each of the three sectors covered in the strategy (State Government, Consumer and Business and Indusfry) are identified. Suggested guidelines are also provided for the remaining groups of recommendations. Funding mlechanisms are also discussed and correlated to certain types of recommendations.
The Need for a Pollution Prevention Strategy
In spite of impressive gains achieved by environmental regulation in the last two decades, regulations alone are not the answer to pollution and waste.
- Pollution Prevention Strategy for the State of Ohio - DRAFT FNEIFinal Draft (March 28, 1994) Page 2
Nor can there continue to be a focus exclusively on "end-of-pipe" pollution control. One of the primary methods for improving environmental quality lieis in a systematic effort to prevent pollution before it occurs through the development and implementation of a pollution prevention strategy.
Pollution prevention primarily focuses on source reduction activities that minimize or eliminate waste before its generation, and as a secondary preference, recycling activities that beneficially use, reuse or reclaim a waste makerial. Pollution prevention is a "multi-media" concept encompassing all environmental media involving pollution released to the land, water and air. Pollution prevention practices avoid cross-media transfers of pollutants from one environmental media to another. This pollution prevention strategy provides a basis for focusing and coordinating existing and proposed pollution prevention programs.
Objectives of the Strategy
The objectives of the Pollution Prevention Strategy of the State of Ohio are to:
1.
2.
3.
4.
Define the concept of pollution prevention;
Provide a review of current pollution prevention activities;
Provide recommendations for pollution prevention hitiiatives for state government, business and consumer activities; and,
Suggest guidelines for implementing proposed pollution prevention initiatives.
THE CONCEPT OF POLLUTION PREVENTION
Definition of Pollution Prevention
The Pollution Prevention Development Workgroup recommends the folhwing definition of pollution prevention be used in the State of Ohio:
"Pollution prevention" means the use of source reduction techniques in order to reduce risk to public health, safety, welfare and the environment and, as
Pollution Prevention 'Strategy for the Stute of Ohio - DRAFT mVE/Final Drafr (March 28, 1994) Page 3 ( -
second preference, the use of environmentally sound recycling to achieve these same goals. Pollution prevention avoids cross-media transfers of waste and/or pollutants and is multi-media in scope. It addresses all types of waste anti environmental releases to the air, water and land.
Off '-site waste management, incineration or other the& treatment, treatment to reduce waste volume or toxicity, bankruptcy or reduction in prcduction volume, energy recovery (including burning in boilers) does not constitute pollution prevention.
Other definitions which are used to either assist in the definition of pollution prevention or distinguish activities separate from pollution prevention are defined in Appendix B.
Difference Between Pollution Prevention and Pollution Control
Pollution prevention focuses on minimizing or eliminating a waste before it is generated. Pollution control deals with managing the waste after it is generated, including the collection, treatment and disposal or discharge of wastes. Pollution control refers to the conventional approach to environmental protection of achieving clean &,.water and land through "end-of-the-pipe" measures. Ohioans have invested billions of dollars in poUution control such as wastewater treatment, scrubbers, incinerators, and similar measures to achieve environmental improvements. Pollution prevention seeks better and lower cost solutions to achieve these same impovements by focusing on source reduction and recycling techniques.
Not all pollution can be prevented. The safe treatment, storage and disposal of pollution that cannot reasonably be reduced at the source or recycled will continue to be important components of an environmental protection strategy. Better environmental protection must include pollution prevention in conjunction with existing pollution control programs. Pollution prevention is a much more effective response to dealing with cross-media releases and natural resource consumption. It reduces or eliminates many costs and concerns about environmental impacts, and substantially reduces the amount of regulatory control and oversight needed to protect the environment.
Pollution Prevention Strategy for the State of Ohio - DRAFT W E I F i n a l Draft (March 28, 1994) Page 4 - Applicability to Energy Efficiency, Water Conservation and Process Efficiency
Pollution prevention is directly related to energy effiaency, water conservation and process effiaency. The use of less energy results in less pollution from both the extraction of materials used for fuels and in fuel corisumption to produce energy. Every kilowatt-how of electricity not used prevents the emission of 1.5 pounds of carbon dioxide (a greenhouse gas), 5.8 grams of sulfur dioxide (a component of acid rain) and 2.5 grams of nitrogen oxide (a component of both aad rain and smog). For example, if energy efficient lighting were used wherever profitable, the amount of carbon dioxide reduced would be equivalent to taking 42 million cim off the road and would reduce the emissions of carbon dioxide by 232 million tons, s d i h r dioxide by 1.7 million tons and nitrogen oxide by 9Ob,OOO tons.
Other types of "efficiency" are also related to polluticin prevention. Water conservation measures can reduce the amount of pollution generated in extraction and purification processes, and reduces the amount of energy needed to produce more potable water. Process efficiency, particularly in the manufacturing setting, can reduce the amount of pollution generation through improved product yields, lower energy usage and lower requirements for raw materials.
CURRENT POLLUTION PREVENTION ACTIVITIES
A number of pollution prevention initiatives are being implemented in federal and. state government, business and industry, and consumer activities. These activities constitute one portion of the overall envirorunentd protection effort in the State of Ohio. A summary of Ohio's overall environmental protection efforts is included in Appendix D.
A review of existing pollution prevention activities provides a foundation for recommending future pollution prevention initiatives in government, business and consumer sectors. This section provides an overview of source reduction and recycling programs currently underway in these three sectors. A detailed review of these activities are included in Appench E.
- Pollution Prevention Strategy for the State of Ohio - DRAFT FiVE/FiiMf Drafr (March 28, 1994) Page 5
Government
State environmental agencies were among the first to promote pollution prevention by providing pollution prevention infomtion and technical asriistance to businesses and consumers. The Ohio Environmental Protection Agency (Ohio EPA), the Ohio Department of Natural Resources (ODNR) and the Ohio Department of Development (ODQD) are responsible for implementing recycling and pollution prevention initiatives in Ohio. These Agencies have been promoting resource conservation and recycling activities for nearly two decades. Both of these activities are directly related to pollution prevention. The majority of these efforts have concentrated on the bwiness and industrial sectors although significant achievements are visible in providing consumers with opportunities in pollution prevention.
U.S. EPA has instituted a number of voluntary pollution prevention initiatives to facilitate the incorporation of pollution prevention into business and industry practices. A brief description of some of the more prominent programs is included in Appendix E.
Ohio EPA
The majority of pollution prevention activity within the Ohio EPA is carried out by the Office of Pollution Prevention (OPP). The OPP coordinates pollution prevention activities for all Divisions at Ohio EPA. with a goal to "Develop and bnplement pollution prevention initiatives that effectively reduce pollutants in Ohio." The OPP also coordinates and jointly works with other state agencies on external pollution prevention programs.
Specific pollution prevention initiatives occurring at Ohio EPA include: incorporation of pollution prevention into Ohio EPA enforcement activities; incorporation of pollution prevention into Agency permitting activities; implementation of pollution prevention related initiatives under the Clean Air Act Amendments of 1990; implementation of the solid waste source reduction and recycling initiatives of House Bill 592; support and promotion of U.S. EPA's voluntary poLlution prevention initiatives, such as the Ohio 33/50 Prop.-m and the Green Lights Program; incorporation of pollution prevention into Remedial Action Plans that identify efforts to remediate poll~ltion along major waterways emptying into Lake Erie; suppol't of polliltion prevention activities funded under the Ohio Environmental Education Fund; completion of a number of pollution prevention projects
Pcdlution Prevention Sfrategy for the Sfafe of Ohio - DRAFT FIVE/Final Draft (March 28, 1994) Page 6 - fccusing on the Lake Erie Basin of Ohio; administration of the Govemor’s Pollution Prevention Awards Program; coordination of the Govemor’s Pollution Prevention Development Workgroup; and the integration of pollution prevention concepts throughout Ohio E M ‘ S regulatory programs.
Ohio Department of Natural Resources, Division of Litter Prevention and Recycling
Tlie Division of Litter Revention and Recycling coordinates the implementation of the Recycle, Ohio! program and assists Ohio EPA in the implementation of Ohio’s Solid Waste Management: Plan. Through the Recycle, Ohio! Program the Division: 1) encourages and assists Ohioans to reduce, reuse and recycle waste materials, 2) develops new or expands existing recycling programs, and 3) increases the mimufacixring, purchase and use of recycled products. Program assistance in these three areas is provided to both the public and private sectors.
Major projects and programs coordinated by Division of Litter Prevention and Recycling include the following recycling collection and recycled market development initiatives: 1) Community Grants to assist lccal governments in implementing recycling programs; 2) State agency recycling programs; 3) The Great Lakes Recycle Governor’s Agreement was signed by Governor George V. Voinovich and seven other states in an effort to pool individual state efiorts by drawing on economies of scale created by joint state procurement pclwer; 4) A Voluntary Newsprint Recycling Agreement wfas signed between the Ohio Newspaper Assoaation, Governor George V. Voinovich, and the leadership in the General Assembly to increase the amount of recycled co:ntent newsprint will be used by Ohio newspapers; 6) House Bill 25 was passed July 1993 allowing the Department of Administrative Services to develop rules regarding the purchase of recycled content products; 7) Each of Ohio’s 88 boards of county commissioners have entered into an agreement with the Division to encourage recycling and to increase the use of recycled content products throughout county government; 8) A Center for the Development of Products from Recycled Materials is being created through a partnership including Sandia National Laboratories, Batte1.e Memorial Institute and Environmental Plastics to develop prototype products from recyclable materials.
. - Pollr~tion Prevention Strategy fir the State of Ohio - DRAFT FWE/Fid Drajt (Mmh 28, 1994) Page 7
Ohio Department of Development, Ohio Edison Centers
T h e Ohio Thomas Edison Program is administered by the Ohio Department of Development @OD) and is designed to foster an innovative partnership between Ohio Industry, state government, and academic researchers. The program was initiated in 1983 to increase Ohio's cornpetitiweness in r eg iod a n t i global markets. This program is related to pollution prevention because many of the technological changes or developments sponsored by the Th~mas Edison Program promote pollution prevention initiatives. Every major university and over 700 businesses participate in anti partially fund the publidprivate partnership. The Cleveland Advanced Manufacturing Program anti the Instifxte of Advanced Manufacturing Sciences in Cincinnati both provide pollution prevention technical assistance to business in conjunction with their Ohio Edison Center activities. These ceni:ers have received furtding from the Ohio Environmental Education Fund through the Pollution Prevention Education and Training Grants Program to increase the technical assistance activities.
Business and Industry
Many businesses and industries have been practicing and promoting pollution prevention for years. Pollution preveAtion programs in business and industry have generally resulted from the fact that reducing waste and improving efficiency makes good environmental and economic sense. Most industrial pollution prevention programs are tailored to the specific needs of each company, and in some cases, to the needs of specific facilities. The Pollution Prevention Code of Management Practices' of the Chemical Manufacturers' Association (CMA) Responsible Care Program is designed to achieve ongoing reductions in the amount of all contamhants and pollutants released to the air, water and land from member company facilities. This prclgram applies to all CMA members and is implemented throughout much of the chemical industry. Many individual companies andlor facilities have either corporate-wide or facility specific pollution prevention programs. Examples of these programs are provided in Appendix E.
The Ohio Manufacturers' Association, the Ohio Chamber of Commerce and the Ohio Chemical Council have sponsored training, seminars and conferences related to pollution prevention. Various other trade associations such as the Ohio Petroleum Council, Ohio paint Council and the Ohio Steel Coinpanies have participated in and sponsored these type of activities.
Poll‘ution Prevention Strategy for the State of Ohio - DRAFT €lVE/Rd Draft (March 20, 1994) Page 8 -
Consumer Sector
Milch of the consumer sector’s activity related to pollution prevention has focused on recycling. Although some source reduction activities have been implemented, the major emphasis has been directed towards removing recyclable materials from the municipal solid waste stream to minimize the impacts of disposal. Examples of some these programs are provided in Appendix E.
Consumers have been purchasing products with reduced packaging and implementing energy conservation measures at home. Energy tax credit programs initiated in the 1970’s are now being induded in some utilities’ deinand-side management programs. Use of compact fluorescent lighting and other environmentally benefiaal products is on the rise. Carpooling and use of mass transit have also prevented pollution through decreased energy usage.
Mtich has been done to raise consumer awareness regarding pollution prevention. Some environmental groups have embraced the pollution prevention concept and have launched public awareness ccwnpaigns to increase the public’s knowledge of the benefits of pollution prevention. Groups such as the Ohio Environmental Council, Ohio Citizen Action and the Ohio Chapter of the Sierra Club promote pollution prevention activities thmughout the state. The Ohio Environmental Education Fund has provided grant funding to community based organizations to increase environmental education and awareness in the consumer sector.
RECOMMENDATIONS FOR POLLUTION ]PREVENTION hIITIATWES - - Pollution prevention initiatives include: education; technical assistance; economic incentives; and laws, policies and plans that provide pollution prevention opportunities and allow for and encourage the use of pollution prevention practices. Recommendations are provided for each of the three sectors addressed by the Pollution Prevention Development Workgroup: state government, business and industry, and consumers.
policy State ment
The Pollution Prevention Development Workgroup recommends the following statement be adopted as public policy for the State of Ohio:
Pollution Prevention as the Prefewed Approach
That wherever feasible, the release of toxic chemicals and the generation of solid and haairdous waste are io be prevented or reduced as expeditiously as possible. mt for the past two decades the state's major environmental regulatory effods have been focused on controlling or managing discharges of toxic chemicals, hazardous and other types of wastes f Arough permit systems and the installa tion of pollution control technologies; that while the traditional system of pollution control has produced substantial improvements irz the state's environmental quality, the upper limit of improvement that can be reasonably expected under the traditional system is within sight; that the inherent limits of the traditional system of pollution control should be addressed by a new emphasis on pollution prevention through reductions in the relerzse of toxic chemicals and through the reduction in the generation of solid, hmrrdous and ofher types of waste; that an accounting for the release of toxic chemicals and the generation of solid and hazardous waste at each step of an indwtrial process will identify the points at which, and the procedures by which, pollution can be prevented; that pollution prevention can be achieved through a more efficient and rational use of toxic chemicals, or through the use of less toxic substitute chemicals or processes less prone to produce pollution; that: pollution prevention conserves and protects natural resources and conserves energy; and that a sound planned pollution prevention program cay1 be implemented without adversely affecting the sfate's economy or the livelihood of the many people employed by industries that discharge toxic chemicals and generate solid, hazardous a d other fypes of waste; fhe Stat1$ of Ohio therefore finds that it is in the interest of fhe environment, and public and occupational health, and in the general public inferest of all state residents to transform the current system of pollution control to a system of pollution prevention.
Pollution Prevention Strategy for the State of Ohio - DRAFT F I V E / F i d Draft (March 28, 1994) Page 10 - Waste Management Hierarchy
Source reduction of solid, hazardous and other types of waste, and reduction in the releme of toxic chemicals shall be the first pollution prevention priority and shall be practiced wherever technically and economically feasible. If such methods are not fea;ible, on-site recycling of solid, hazardous and other types of waste and toxic chemicals shall be practiced as a second priority; and of-site recycling shall be practiced as a third priority. If none of these methods are technically and ecoxomically practicable, treatment of solid, hazardous and other types of waste and toxic chemicals shall be conducted as a fourth priority. As a last priority, solid, hazardous and other types of waste and toxic chemicals shall be disposed in an environmentally sound manner.
Reduction Goals
I t ii the goal of this state to reduce the quantity of solid and hazardous waste generated and the quantity of toxic chemicals released by 25% by the year 1997, and by SO% by the year 2000 wherever technically and economically feasible from 1988 levds.
STATE GOVERNMENT - _.
Stiite government can play an active role in promoting, encouraging and fadtating pollution prevention activities Although state government can take a lead in these pollution prevention activities, business and consumers need to take their fair share of the responsibility for institutionalizing pollution prevention throughout all sectors of the State of Ohio.
&j.ministrah 've Support
Administrative support and commitment should be obtained to promote and im;dement pollution prevention initiatives throughout state government. Thh should be completed by obtaining written upper management cornmitments in each department or agency to reduce waste whenever technically or economically feasible.
micational Outreach and Promo tion
State government should develop an educational campaign to promote and encourage pollution prevention activities. The Ohio EPA should coordinate this effort with other interested parties to achieve the following objectives:
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2.
3.
4.
Ohio EPA should work with the Department of Education to integrate pollution prevention concepts into environmental, curric:ula for grades K - 12.
Ohio EPA should work with the Ohio Board of Regents and state colleges and universities to instill pollution prevention concepts into college curricula, specifically in the areas of business, engineering, environmental and related sciences, and economics.
Ohio EPA should develop guidance and educational materials to distribute to Ohio business and industry which demonstrate the economic and environmental benefits of pollution prevention and encourage the implementation of pollution prevention practices.
#Ohio EPA should work with the Department of Natural Resources to Idevelop educational materials that promote and encourage pollution prevention practices in the consumer sector.
- Pollution Preuention Strategy for the State of Ohia - DRAFT €"E/Final Draft {March 28, 1994) Page 12
State employees should be trained to recognize pollution prevention opportunities and to implement cost-effective pollution prevention measures where appropriate. The Ohio EPA should work with the Department of Athhistrative Services to develop a state employee tr-g program for pclUution prevention and require appropriate state employees to obtain this trsining. This training should not only focus on preventing pollution in state government, but should provide state employees with the ability to convey pollution prevention concepts in the services they provide.,
Existing efforts to develop a state procurement strategy that allows the purchase of products not based solely on the least cost alternative should be continued. This strategy should recognize long-term cost benefits of durable products, product life cycle analysis and environmental factors such as the ability to recycle a product, waste generation due to excess packaging, product reusability, product toxicity, worker exposure and other relevant factors.
1.
2.
3.
The State of Ohio should expand current "group buying" strategies beyond the current efforts with recycled paper and re-refined oil.
The Department of Administrative Services should work with other state agencies to develop cooperative purchasing programs between state government, business and the public to encourage the procurement of products that preventkeduce pollution and develop statewide and regional markets for these products.
The Department of Administrative Services should work with other state agencies to develop bulk purchasing arrangements between state agencies to encourage the procurement of products that preventlreduce pollution and develop statewide and regional markets for these lxoducts. Bulk purchasing can often offset the higher cost of purchasiig some pollution reducinglpreventing products on an agency-by-agency basis.
- Pol,!ution Prevention Sfrafegy for the Sfafe of Ohio - DRAFT FIVE/Final Drtzfi (Mmh 28, 2994) Page 23
&;3Xgy Eff iciencv. Water Conservat.1 ‘on and ~ Process Efficiency
, Th.e State of Ohio should encourage energy effiaency, water conservation and industrial process efficiency whenever possible to minimize the amount of pollution generated during production and consumption.
1.
2.
3.
4,
5.
6,
The Department of Administrative Services should continue to work with the Ohio EPA to ensure that state government frulfills its obligations undertaken through U.S. EPA‘s “Green Lights” program for energy efficient lighting. State government should then promote this program to the business and consumer sectors.
The Department of Administrative Services should ensure that state government should procure energy efficient equipment, practice water conservation and implement process efficiency measures whenever cost- effective.
The Department of Administrative Services should ensure that all state government buildings are assessed to identify areas where cost-effective energy efficiency’ water conservation and process efficiency improvements can be made.
Pollution prevention initiatives in the State of Ohio Energy Strategy should be implemented as expeditiously and tholroughIy as possible. Pollution prevention altematives should be utilized whenever possible to meet the recommendations of the Energy Strategy. Implementation of many of the Energy Strategy recommendations will result in decreased generation of pollution.
The Department of Administrative Services in conjunction with the Department of Transportation, Ohio Department of Development’s Office of Energy Efficiency, Ohio EPA and Department (of Natural Resources should inventory all state vehicles and develop and implement a strategy to determine how reformulated fuels, alternative fuel systems, recycled oil’ recycled and recyclable automotive parts’ and others items that prevent pollution can be incorporated into the staie’s vehicles.
‘fie Department of Administrative Services should work other state i3genCies and business and industry to integrate energy effiaency’ water conservation and process effiaency measures into bd&g codes throughout the state. These measures should also address the use of
- Pollution Prevention Strafegy for the State of Ohio - DRAFT F I V E / F i d Dr@ (March 28, 1994) Page 14
recycled and recyclable building products, the prevention of indoor air pollution and the utilization of appliances and building products that prevent andlor reduce pollution.
- Rwycling: Initiatives
The State of Ohio should continue to promote and encourage recycling initiatives throughout state government and to the business and consumer sectors.
1. The Department of Natural Resources should continue to work with the Department of Administrative Services to develop a list of products currently used in state government that can be reasonably recycled. The recycling of these products should be made mandatory, where feasible, throughout state government.
2. The Department of Development should developlexpand programs that provide financial assistance to companies who wish to either establish new recycling facilities or upgrade existing recycling facilities in the State of Ohio.
3. The Department of Development should work with the Department of Natural Resources and Ohio €PA to identify areas where market development for recycled products is needed in the State of Ohio.
,
&I p nomic Incentives
Economic incentives include grants and loans provided by state and federal government, tax credits and revolving loan pools. These incentives can be used to support and subsidize pollution prevention efforts,
1. Ohio EPA should work with the Department of Development to establish a matching grant, revolving loan, low-interest loant andlor no-interest loan program for Ohio industry to implement polllution prevention practices and procedures, andlor purchase pollution prevention related equipment. Funding for this program should be derived from either the General Revenue Fund, development of a Bond Issue, or a reallocation of existing Department of Development business development grants or loan
- PolIution Prevention Strategy for the State of Ohio - DRAFT F I V E / F i d Draft (March 28, 1994) Page 15
programs. This program should be developed concurrently with Item 1. under Sma 11 Bus iness Assistance in the "Business and Industry" section.
2.
3.
4.
5.
Ohio Department of Natural Resources should determine the feasibility of expanding their existing litter prevention and recycling grant programs to promote pollution prevention practices in the consumer sector.
Ohio EPA should work with the Department of Taxation to determine the feasibility of establishing a tax credit program for companies who " k e a significant portion of their wastes.
Ohio EPA should establish a formal network with business and trade organizations to ensure that federal pollution prevention grant program information is distributed to Ohio business and industry in a timely fashion.
Ohio EPA and the Department of Development should work with business and industry to establish a co-investment program for various pollution prevention projects. This program would utilize private and public funding to develop and implement various pollution prevention projects to decrease pollution generation and increase the economic viability of Ohio business and industry. State funding for this program should be derived from either the General Revenue Fund, development of a Bond Issue, or a reallocation of existing Department of Development technology development grants or loan programs.
Technical Assistancg
Pollution prevention technical assistance includes on.-site visits with suggestions for pollution prevention; telephone consultations; information dhemination; presentations, seminars or grants to develop or improve upon pollution prevention technologies or procedures.
1. Ohio EPA should continue to coordinate its pollution prevention technical assistance program with State of Ohio Edison Centers' technology transfer and environmental assistance efforts.
2. Ohio EPA should work with business and trade organizations and the State of Ohio Edison Centers to determine what type of pollution
Pollution Prevention Stratem for the State of Ohio - DRAFT FiVE/Final Draft (March 28, 1994) Page 16
prevention technical assistance efforts are most needed by Ohio business and industry and develop a plan to provide this assistance.
3. Ohio EPA should coordinate its regulatory technical assistance programs with its pollution prevention technical assistance programs in a formal manner to ensure that comprehensive technical assistance services are provided to Ohio business and industry.
4. Ohio EPA should work with the Department of Natural Resources and the Department of Development, including the Office of Energy Effiaency, to determine what types of pollution prevention technical assistance is needed in the consumer sector of Ohio and then develop a strategy to provide this technical assistance.
&liq Mo dif ications
Many environmental compliance decisions are based on Ohio EPA poliaes and guidance procedures. Ohio EPA should review these policies to ensure that pollution prevention is clearly prioritized in meeting policy guidelines.
Ohio EPA should work with other parts of state government to support research activities related to pollution prevention. A formal working relationship with the U.S. EPA Pollution Prevention Research Branch in Cjncinnati needs to be established to link Ohio business and industry with pollution prevention research and development activities. Ohio EPA should more fully utilize the technology transfer capabilities of Ohio’s Edison Centers to facilitate this linkage.
Qvercoming Institutional Barriers to Pollution Pr evention
hstitutional barriers to pollution prevention include regulatory, statutory and policy impediments to completing pollution prevention activities. These barriers also include changing the mind set of controlling pollution after its generated to preventing pollution before it is generated.
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1.
2.
3.
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Ohio EPA should continue its efforts to identify regulatory, statutory and policy barriers to completing pollution prevention activities in Ohio business and industry and detennine what steps can be taken to remove these barriers.
Ohio EPA should work with the Department of Natural Resources to identify barriers to pollution prevention in the public consumer sector and to identify what actions can be taken to overcome these barriers.
Ohio EPA should detennine the feasibility of developing methodologies for expediting the review and issuance of environmental permits for those companies that need new permits, or changes to existing permits, to complete pollution prevention activities. These activities should be developed as part of a prioritized permitting system to ensure that permits which focus on source reduction and closed-loop recycling processes are reviewed before permits dealing with treatment or disposal activities . Ohio EPA and the Attomey Generals Office should expand current efforts for incorporating pollution prevention into enforcement settlements. These settlements should require business and industry to develop and implement pollution prevention projects in exchange for mitigating a portion of a financid penalty for noncompliance with environmental laws.
wit State Efforts
Valuable information regarding pollution prevention initiatives can be obtained through cooperative efforts with other state programs. Information exdmge and sharing is a valuable tool for state programs which are in their developing stages.
1. \Ohio EPA should continue to coordinate its pollution prevention efforts with National Roundtable of State Pollution Prevention Programs and the Great Lakes Regional Pollution Prevention Roundtable.
2.. Ohio EPA should establish a formalized network to obtain information regarding other states pollution prevention programs. Ohio EPA should then provide this information to the business and consumer sectors of Ohio where appropriate.
Pollution Prevention Strategy for the State of Ohio - DRAFT FlVE/Final Draft (March 28, 1994) Page 18 - heal and County Go vernment Initiatives
Ohio EPA should work with other parts of state government and local government officials to determine what types of pollution prevention as5iistance are needed.
1. Ohio EPA should encourage local and county governments to become involved in U.S. EPA’s Green Lights Program.
2. Ohio EPA should survey local and county governments to determine how pollution prevention can be promoted on the local and county level by organizations such as Solid Waste Management Districts, local Chambers of Commerce, and others.
&@atom Develobment
A pollution prevention emphasis can be incorporated into many facets of regulatory development. Regulations should be developed which clearly prioritize pollution prevention as the option of first Choice when complying wiih environmental regulations and statutes.
1. Ohio EPA should establish a review process which ensures that pollution prevention is incorporated into all new state environmental regulations where appropriate.
2. Ohio EPA should establish a regulatory review process to modify existing environmental regulations which either promote waste generation, increase cross-media transfers or discourage pollution prevention.
3. Ohio EPA should work with other parts of state government to institute pollution prevention principles into applicable regulations.
&nDoint Sour ce Pollution Prevention
The Ohio Nonpoint Source Management Program, written in 1989, was revised in 1993 to reflect new pollution control objectives and implementation strategies. This document represents the coordinated efforts and input from nirie Ohio Department of Natural Resources (ODNR) Divisions, Ohio EPA and various state and federal agencies, several universities and numerous
Pol,'ution Prevention Strategy for the State of Ohio - DRAFT FNEIFinal Dmfi (March 28, 1994) Page 19 - private interest groups. Two major goals have been established for Ohio's Nonpoint Source Management Program:
1. Protect and preserve our state's water resources from the adverse impacts of nonpoint source (NPS) pollution; and
2. Improve and restore water resource quality and biotic habitats in order to make Ohio's waters truly fishable, swimmable and drinkable.
Achievement of these goals will depend on Ohio's ability to meet six the following programmatic objectives:
1.
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4.
5,
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The State of Ohio should develop a NPS education program for management agencies' staff, affected organizations, landowners, and the general public.
The State of Ohio should encourage management agencies and research institutions to provide technical assistance for planning and implementing remedial and preventative NPS projects.
The State of Ohio should establish a statewide monitoring program to track effects of NPS pollution and determine effectiveness of implemented projects.
The State of Qhio should provide funding for WS research, education, planning, technical assistance, monitoring, iind enforcement in targeted priority areas.
The State of Ohio should coordinate administrative efforts to insure efficient management of NPS issues.
'The State of Ohio should establish financial and regulatory incentives to promote nonpoint source pollution prevention activities.
BUSINESS AND INDUSTRY
Ohjo business and industry have long demonstrated how pollution prevention can provide both economic and environmental benefits in msulufacturing and other business settings. The State of Ohio should recognize past achievements and promote future development of pollution prevention practices throughout business and industry in Ohio. State government, business and industry, and the consumer sector should establish a long term cooperative working partnership to ensure that pollution prevention activities are implemented whenever economically and technically feasible.
mrhnical Assistance
Pol'Lution prevention technical assistance must be provided to help Ohio businesses implement pollution prevention practices and to identify cost- effective pollution prevention options. Information on pollution prevention altematives must be disseminated throughout business arid industry in Ohio to assist them in implementing pollution prevention programs.
1.
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Ohio business and industry, in conjunction with the State of Ohio, should determine what types of on-site pollution prevention technical assistance is needed and work with the state to develop programs to provide this assistance wherever possible. Existing on-site technical assistance providers, such as the Cleveland Advanced Manufacturing Program, Institute for Advanced Manufacturing Sciences and Ohio EPA, should continue to coordinate their efforts to target areas where the need for this type of assistance is greatest.
Ohio business and industry, the Ohio EPA, the Ohio Department of Development, the Institute of Advanced Manufacturing Sciences and the Cleveland Advanced Manufacturing Program, should coordinate the establishment of a pollution prevention training program where businesses can be instructed on developing pollution prevention plans and conducting facility wide pollution prevention assessments. This program should be provided through trade organizations, state government, colleges, universities, technical centers or other organizations.
The Ohio EPA should effectively serve as a responsive referral point for pollution prevention information.
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4.
5.
Business and industry trade associations should coordinate efforts among Ohio businesses to create industrial "open housesn to solicit assistance from other businesses and industries, and to facilitate "business-to- business" information exchange.
Ohio business and industry should work with Ohio EPA to establish a Retired Engineers Pollution Prevention Program to place retired engineers in business and industry to assist in the development of pollution prevention programs and provide technical assistance.
mpcation and Outreach
Motst businesses will implement pollution prevention initiatives when made aware of the environmental and economic benefits inherent in most pollution prevention approaches. Education and outreach programs should be established that disseminate information and increase the awareness of the benefits realized through pollution prevention.
I
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Ohio EPA should provide pollution prevention informational materials to Ohio business and industry free-of-charge.
Ohio business and industry with successful pollution prevention programs should continue efforts with Ohio E??A to develop Pollution Prevention Case Studies to inform other businesses and the public of the benefits of pollution prevention.
Ohio business and industry should assist Ohio EPA in establishing a Pollution Prevention Intern Program to place college interns in business and industry to assist in the development of pollution prevention programs.
Ohio EPA should develop pollution prevention education and outreach materials specificalIy directed towards pollution prevention opportunities for small business.
Ohio business and trade associations, Ohio EPA, the Department of Development's Office of Energy Effiaency and the Department of Natural Resources should develop a comprehensive public relations strategy to promote pollution prevention throughout Ohio, This strategy should include the development of a weekly or monthly environmental news
- Polfution Prevention Strategy for the State of Ohio - DRAFT F I V E / F i d Draft (March 28, 2994) Page 22
column focusing on pollution prevention to be provided to state newspapers; development of additional public service announcements focusing on pollution prevention; and development of a monthly pollution prevention success story to be provided to state media.
Bade Assoc iation Involvement
Business and industry trade associations provide an ideal forum for promoting pollution prevention. State government should establish cooperative working relationships with these organizations to provide training and education on cost effective pollution prevention alternatives.
1. Business and trade assouations should continue to sponsor state and local forums in which manufacturers, suppliers and researchers can exchange information on specific pollution prevention issues and concerns.
2. The State of Ohio should continue efforts with business, professional and trade organizations to offer workshops dealing with pollution prevention techniques and technologies.
3. Business and trade associations should focus portions of existing environmental conferences on promoting cost effective pollution prevention practices.
4. Business and trade associations and Ohio EPA should utilize local organizations and associations with an environmental interest to promote pollution prevention concepts and provide pollution prevention technical assistance (e.g., county health departments, local industry or trade groups, Solid Waste Management Districts, local environmental groups and local Chambers of Commerce).
5. Ohio business and industry trade associations should work with the State of Ohio to develop a listing of upcoming conferences where presentations promoting pollution prevention could be provided. This listing should include all conferences where the audience may have a potential interest in pollution prevention and not limited to groups focused on environmental issues.
Pollution Prevention Strategy for the State of Ohio - DRAFT FNEIFinal Draft (March 28, 1994) Page 23 - 6. Local Chambers of Commerce should work with Solid Waste
Management Districts and Ohio EPA to achieve solid waste reduction goals established in H.B. 592 using pollution prevention approaches.
7. 'Business and trade associations and Ohio EPA should develop video presentations promoting pollution prevention concepts that can be provided to business and industry, and local organizations.
&iall Business Assistance
Mimy small businesses do not have the resources required to invest in poilution prevention. State government and larger businesses should work together to provide pollution prevention assistance targeted to small business.
1. The Ohio EPA and the Department of Development should determine the feasibility of establishing a small business low-interest loan or grant program for pollution prevention. Develop an implementation strategy and seek the required administrative andlor legislative changes necessary to implement this program. This program should be deveIoped concurrently wifh Item I . under Economic Incentives in the "State Goverlzmenf" secfion.
2. The Ohio Edison Centers, Ohio EPA and organizations such as the Small Business Council of the Ohio Chamber of Commerce should determine the pollution prevention technical assistance needs of s m d business and establish programs to provide this service.
3. Business and industry trade organizations should coordinate efforts with the Ohio EPA and Ohio Department of Development to provide education and training to assist s m a l l business in establishing cost effective pollution prevention programs, This effort should develop a mechanism to show businesses how to obtain information and pursue pollution prevention technical assistance, and show small businesses how to obtain tax credits, grants and low-interest loans for pollution prevention.
4. Funding available from the Ohio Air Quality Development Authority and the Ohio Water Quality Development Authority for air and water
Pollution Preoention Sfrategy fir the State of Ohio - DRAFT €TVElHd Draft (March 28, 1994) Page 24 - pollution abatement activities should be directed to pollution prevention projects which "abate" air and water pollution.
5. Business and industry trade organizations should work with the Ohio EPA and Ohio Department of Development to identify grant and low- interest loans that may be available through the private sector to hance pollution prevention projects for s m d businesses. These organizations should also provide education and training to assist small businesses in obtaining this financing.
Ncm-point source pollution prevention measures can provide substantial environmental improvements in agriculture. Low input sustainable agriculture, mini" till and no till farming methods should be promoted whenever possible.
1.
, 2.
3.
4.
The Department of Agriculture and Ohio EPA should work with County Extension Agents to encourage farmers to draft and implement conservation resource plans with help of the Soil Conservation Service. These plans would include: nutrient management (animal waste, biosolids (sludge) application and fertilizer application), pesticide management, soil erosion control, air pollution control provisions, windbreaks, and containment for above ground storage tanks.
The Department of Agriculture, Ohio P A , the Ohio Department of Natural Resources and other appropriate state agencies should work with County Extension Agents to encourage the use of reusable and recyclable pesticide containers to reduce the number of containers requiring disposal. The production of new generation pesticides which come in smaller containers or containers that dissolve in the mix tank should also be encouraged.
The Department of Agriculture, Department of Administrative Services and Ohio EPA should work with County Extension Agents to encourage the Green Lights and Energy Star Programs in the farm setting. This program could apply to poultry houses and other farm buildings.
The Department of Agriculture, Ohio EPA, the Ohio Department of Natural Resources and other appropriate state agencies should work with
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County Extension Agents to encourage the development and implementation of Resource Conservation Plans to help increase education on the economics of conservation tillage. Conservation tillage reduces fuel use, reduces obsolescence of farm machinery, and reduces the amount of f m machinery needed and manufactured.
5. The Department of Agriculture, Ohio EPA, the Ohio Department of Natural Resources and other appropriate state agencies should work with County Extension Agents to develop a strategy to encourage the development and implementation of innovative fanning methods that prevent pollution. These methods should include, but not be limited to: low input sustainable agriculture, 'organic farming," integrated pest management, habitat enhancement for beneficial flora and fauna, conservation tillage, agri-chemical budgeting, integrated cropping systems and integrated nutrient management.
- En" Ef ficiencv, Water Conservab *on and Process Ef ficiencv IN 'tiatives
T h e State of Ohio should encourage energy effiaency, water conservation and increased process efficiency practices throughout business and industry as a way to reduce operating costs and " h e the pollution created during production and consumption
1.
2.
3.
4.
Ohio EPA will continue efforts to encourage business and industry participation in US. EPA's Green Lights and Energy Star Programs.
The State of Ohio should encourage business and industry to incorporate energy efficiency, water conservation and process efficiency practices into any plant upgrades or modifications.
The Ohio EPA should fully integrate energy effiaency, water conservation and process efficiency options into any voluntary pollution prevention planning program,
Ohio EPA, the Ohio Department of Development Office of Energy Efficiency, the Public Utilities Commission of Ohio and Ohio utility companies should develop programs that promote the linkage between energy efficiency, water conservation and pollution prevention.
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5. The Public Utilities Commission should recognize customer's process efficiency improvements which result in lower energy usage in demand side management programs.
Q,mpliance Ass istance
Pclllution prevention encourages business to go beyond compliance to achieve environmental goals. However, many bushesses can attain compliance through pollution prevention practices. The State of Ohio needs to encourage business to use pollution prevention as viable alternative for achieving compliance mandates.
1.
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Ohio EPA should coordinate existing and planned regulatory and pollution prevention technical assistance efforts so businesses can obtain information on how to reduce a facility's overall generation of pollution to achieve compliance in various regulatory programs.
Ohio EPA should emphasize pollution prevention alternatives as the option of first choice for meeting environmental standards.
Ohio EPA should determine if regulated facilities would like to receive information on pollution prevention, pollution prevention technical assistance and/or a list of contractors that can provide pollution prevention services during the course of environmental inspections. 'Inspector's checklists" used to evaluate regulatory compliance should be amended to include these items.
Ohio EPA should allow sufficient regulatory flexibility to allow the implementation of pollution prevention practices to meet environmental standards. Examples include: a) allowing extensions of regulatory deadlines in order for facilities to implement source reduction or recycling operations or equipment; and b) allowing temporary "short-term' excedences of environmental standards to implement source reduction or recycling operations or equipment.
Businesses should be provided economic incentives to prevent pollution. Pollution prevention options are more readily implemented when short term
Potjution Prevention Strategy for the State of Ohio - DRA€? FIVE/Final Draft (March 28, 1994) Page 27 -
economic gains can be achieved. The State of Ohio should create new programs and m o w existing programs to provide business with economic inc:entives to prevent pollution.
1. The Ohio Department of Development should detennine whether existing business development loan programs can be provided to companies for pollution prevention projects.
2. The Ohio Department of Taxation and the Ohio EPA should work together to detennine if existing tax credit programs for water and air pollution control equipment should be modified to include pollution prevention equipment.
&l,lution Prevention Plannin-a ma
Many other states have demonstrated the benefits of pollution prevention planning. These benefits include reduced long-term liabilities through total waste accounting; reduced waste management costs; upper management support for pollution prevention activities at the facility level; increased competitiveness through more efficient operations; and justification of funding expenditures for pollution prevention activities through identification of pollution prevention opportunities identified during the planning process. Ohio EPA should work with business and industry to develop voluntary pollution prevention planning programs that acknowledge achievements in pollution prevention and seek to reduce the amount of pollution generated and released in Ohio.
On September 1, 1993, Governor George V. Vohovich requested the top 100 toxic chemical releasers to prepare comprehensive pollution prevention plans. These plans will identify cost-effective options to help Ohio business become more competitive through reduced waste management costs.
The goals of the program are to achieve a 50% reduction in the amount of toxic releases and hazardous waste generation by the year 2000, using 1988 as the baseline year. The primary purposes of this program are to encourage facilities to initiate or expand existing pollution prevention practices through development of comprehensive pollution prevention plans; demonstrate the economic and environmental benefits of pollution prevention by having the facilities included in this initiative serve as role models for other businesses
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throughout the state; and to publicize the exemplary pollution prevention efforts being made by these companies.
Most, if not all, of the facilities included in this initiative already have some type of pollution prevention program in place. However, no mechanism exists to coordinate efforts or publicize achievements. The Ohio EPA is required to provide the Toxic Release Inventory to the public. Many of the companies with the largest amount of releases have made great strides in release reduction and pollution prevention.
Cctmpanies were selected for this initiative using the most recently available Toxic Release Inventory data (1991). Only data pertaining to toxic chemical releases was used to derive the 'top 100' list. Release numbers were taken directly from the information provided to Ohio EPA by companies required to report.
The Pollution Prevention Development Workgroup recommends that this program be open to all businesses, industry and other organizations involved in preventing pollution. This expanded program should encompass all types of waste and pollution generated andlor released to the environment, while maintaining a focus on seeking a 50% reduction in the amount of hazardous waste generated and toxic chemicals released by. the year 2000.
The program should have two tiers of partiapation. h e first tier will adnowledge all organizations who have made a commitment to pollution prevention. To participate at this level, an orgka t ion should:
1. Provide a written commitment to participate in the program;
2. Summarize previous, current and planned pollution prevention efforts; and
3. Commit to promote pollution prevention to others.
The second tier of partiapation should recognize those organizations who have made, or plan to make, outstanding achievements in pollution prevention. To participate at this level, an organization should:
1. Provide a written commitment from the highest ranking corporate or organizational official to participate in the program;
- Pollution Prevention Strategy for the State of Ohio - DRAFT FWEfFinal Draft (March 28, 1994) Page 29
2.
3.
4.
5.
Provide a written commitment from the highest ranking corporate or organizational official to establish a goal of reducing the amounts of hazardous waste, toxic releases or other type of waste by 50% by 2000.
Provide a written, non-confidential business information s u m m a r y of previous, current and planned pollution prevention efforts, including activities to be completed to meet the 50% reduction goal;
Have an on-going program for promoting and supporting pollution prevention to others; and
Provide a written commitment and establish a program for continually reducing the amount of pollution generated.
Or,ganizations participating at this level should provide information pei?*g to the amounts and types of pollution to be prevented; the baseline year from which reductions will be measured; and any relevant information pertaining to economic, technological and regulatory barriers which may impede pollution prevention programs.
If voluntary pollution prevention planning efforts fail to achieve a significant reduction in the amount of pollution generated, it is recommended that the State of Ohio seek and implement a legislative mandate requiring reductions in fhe amount of toxics produced from all Toxic Release Inventory reporters and large quantity hazardous waste generators.
CONSUMER SECTOR - _I
Many opportunities exist to prevent pollution in the consumer sector. Pollution prevention options range from preventing the generation of waste in the home, to purchasing environmentally friendly or "green" products. M'any of the current pollution prevention activities in the consumer sector hive concentrated on recycling and raising consumer awareness about the results of household waste generation. This foundation needs to be built upon to focus more on source reduction, or "not generating waste in the first place.
Eiucation a nd Outr each
Existing education and awareness activities should be continued and focused on promoting source reduction concepts along with recycling.
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The Ohio EPA and Ohio Department of Natural Resources should focus existing consumer education and awareness campaigns on source reduction strategies along with recycling.
Informational materials developed by the State of Ohio describing consumer source reduction strategies should be distributed to the public.
The State of Ohio should utilize focal and county governments to distribute informational materials and promote source reduction and recycling strategies.
The State of Ohio should also provide infomation to the public free-of- charge detailing proper disposal techniques and recycling opportunities for household wastes to complement pollution prevention information (e.g., used oil recycling, antifreeze disposal, household hazardous disposal, etc.).
&onom ic Incentives
Consumers should be made aware of the overall economic and environmental costs of the products they purchase. Products purchased in bulk tend to cost lerss and have less overall packaging requiring disposal. The State of Ohio should identify and detennine the feasibility of implementing programs that
Pollution Prevention Strategy fir the State of Ohio - DRAFT FfVEIFinal Drafr (March 28, 1994) Page 31 - provide economic incentives for consumers who recycle or purchase products that reducelprevent pollution.
0 . 0 Energv Efficiencv and Water Conservation Initrattves
Ccnsurner energy efficiency and water conservation programs should be expanded. Consumers should be made aware of the long term savings versus higher upfront costs of some energy effiaent products and water co:nservation measures.
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The Ohio Department of Development’s Office of Energy Efficiency in conjunction with the Ohio EPA, Department of Administrative Services, the Public Utilities Commission and Department of Natural Resources shodd prepare and distribute information on energy efficient products and water conservation measures.
The Public Utilities Commission in conjunction with the Ohio Department of Development’s Office of Energy Efficiency, Ohio P A , Department of Administrative Services and Department of Natural Resources should encourage utilities to supply information on the estimated cost savings to be obtained through use of energy effiaent products and the implementation of water conservation measures.
Existing newsletters prepared by the State of Ohio should highlight . specific energy efficient products and water conservation measures. These newsletters should detail the long term cost saving and environmental benefits associated with these products and practices.
Training and information seminars should be developed by the Public Utilities Commission, Ohio Department of Development’s Office of Energy Efficiency, Ohio EPA, Department of Administrative Services and Department of Natural Resources in conjunction with business and industry to promote energy effiaency and water conservation practices.
citizen and Community G rout) Involvem enf
Business and state government should expand existing efforts to work with citizen groups to promote pollution prevention concepts. This can be aclhieved by using these groups to distribute information related to household
- Pollution Prevention Strategy fir the State of Ohio - DRAFT FWEfFiml Draft (March 28, 1994) Page 32
pollution prevention practices, and coordinating workshops and training sessions to demonstrate the benefits of pollution prevention.
1. Citizen and community groups should be encouraged to assist in promoting pollution prevention through conferences, newsletters, awards, etc'.
2. Citizen and community groups should serve as outlets for disseminating pollution prevention information,
3. Citizen and commhty groups should assist in the creation of local pollution prevention committees.
4. Citizen and community groups should use Toxic Release Inventory information to discuss pollution prevention strategies with local business and industry.
&rehas incr Initiatives
Coinsumers should be encouraged to purchase products that reducelprevent pollution. The Ohio Department of Natural Resources, Ohio EPA and other appropriate state agencies should work with business and industry to educate consumers about the environmental impacts of the products they buy. This program should promote the following concepts:
1. Purchasing products in bulk;
2. Not purchasing products with excess or unneeded packing;
3. Purchasing durable products as opposed to disposable goods;
4. Reusing or redistributing products to others instead of disposing them when they are no longer needed;
5. Purchasing products with recycled content;
6 . .Eliminating junkmail;
7. IPurchasing products that contain non-toxic chemicals;
Polr'ution Prmention Strategy fir the State of Ohio - DRAFT FWE/Fid Dmft (March 28, 1994) Page 33 - 8. Purchasing energy efficient products; and
9. Purchasing products that promote water conservation.
- Technical Ass istance
The State of Ohio should expand programs to provide technical assistance to consumers on household source reduction and recycling techniques. This assistance should be provided through either a statewide toll free hotline; through state, local or regional forums; and through local andlor cornmunity or,ganizations.
1. The Ohio EPA, Department of Natural Resources and other appropriate state agencies should determine the feasibility of developing a computerized bulletin board andlor n1-800" toll free hotline where consumers can obtained information and assistance related to pollution prevention and other environmental issues.
2. The State of Ohio, business and industry trade associations, and consumer groups should develop a pollution prevention "speakers bureaun to provide presentations on pollution prevention opportunities for consumers and other interested parties.
QY ercominp Barriers to P I o lubon Prevention
The Department of Natural Resources should continue its efforts to determine wlbt barriers exist to household recycling and source reduction. The results of this survey should be used to improve existing and planned household recycling and source reduction efforts.
Blucational Orsan izations
Educational organizations outside of the public school system can serve as eflective vehicles for promoting pollution prevention. Many of these functions can be used enhance pollution prevention activities in the Consumer Sector.
Pollution Prevention Strategy for fhe Slate of Ohio - DRAFT ENE/Final Draft (March 28, 1994) Page 34 - 1.
2.
3.
4.
Educational organizations should incorporate pollution prevention concepts in curricula.
Educational organizations should offer continuing education courses in pollution prevention.
Educational organizations should increase efforts to Erik businesses with pohtion prevention research opportunities.
Educational organizations should place greater emphasis on pollution prevention research.
Retailers have a tremendous opportunity to raise consumer awareness about pollution prevention opportunities. Informed consumers can purchase products which generate less waste and have less of a negative effect on the environment.
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Retailers should provide customers the opportunity to prevent pollution through reduced packaging and Serve as outlets for disseminating information on how purchasing choices affect the environment.
Retailers should provide customers the opportunity to prevent pollution by offering discounts for reuse practices, such as reusing grocery bags.
Retailers should participate in the Green Lights and Energy Star Programs.
bibor Organizations
Labor organizations have a unique opportunity to promote pollution prevention through the total quality management process. Quality action teams can provide useful information on improving process efficiencies and preventing pollution generated during production processes.
1. Labor organizations should assist in promoting pollution prevention through conferences, newsletters, awards, etc.
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3.
4.
5.
Labor organizations should serve as outlets for disseminating pollution prevention information.
Labor organizations should select pollution prevention for quality circle projects.
Labor organizations should promote the formation of pollution prevention teams.
Labor organizations should organize training in pollution prevention.
SUGGESTED GUIDELINES FOR IMPLEMENTATION
This portion of the strategy suggests how the recommendations provided by th.e Pollution Prevention Development Workgroup should be "put into practice" to promote pollution prevention throughout Ohio. The following discussion provides recommendations on prioritizing initiatives, potential funding mechanisms and implementation. This discussion also identifies which recommendations may need legislative support in order to be fully implemented.
Recommendations in the previous sections were prepared in order to provide the maxi" degree of flexibility in implementation. Many of the recommendations can be implemented as 'stand alone" programs. Recommendations do not need to be implemented in a specific order to be efYective.
It is recognized that some recommendations will be easier to implement than others. Recommendations that require some type of legislative support will necessarily take longer to implement than those that can be completed through procedural or policy changes w i t h existing state, business or consumer organizations. The recommendations contained in this strategy were prepared to allow the flexibility to decide which recommendations will prIDvide the greatest benefit to the State of Ohio and to implement those recommendations or groups of recommendations that will provide the greatest degree of pollution prevention in a cost-effective manner.
Bioritization of Initiatives and Imdementatioq
The Pollution Prevention Development Workgroup is providing the following suggestions for prioritizing recommendations based upon the perceived needs for pollution prevention throughout the state and input received from Pollution Prevention Development Workgroup participants. The following factors were considered when developing rankings for strategy recommendations.
Recommendations regarding technical assistance receive priority ranking in order to reduce the amount of pollution generated by government, business and consumer sectors. Establishing cooperative working relationships to transfer infonnation, expertise and technological innovations among these three sectors should greatly increase the amount of pollution prevention activify throughout Ohio.
- Pollution Prevention Strategy for the State of Ohio - DRAFT FWE/Fid Draft ( M m h 28, 1994) Page 37
Eclucation and outreach recommendations, particularly in the consumer sector, receive priority ranking in order to communicate the substantial economic and environmental benefits of pollution prevention approaches. Government, businesses and consumers should be trained and educated on pcdlution prevention opportunities.
Voluntary and incentive based approaches, particularly in the business sector, receive priority ranking because the business sector should be provided with t h opportunity to demonstrate that voluntary and incentive based approaches to pollution prevention can yield substantial environmental benefits.
Overcoming barriers to pollution prevention, while not receiving priority ranking, is considered to be an inherent part of most of the recommendations thint received priority ranking. Implementation of these recommendations will need to occur concurrently with implementation of many of the recommendations in other sections. Implementation of these recommendations will also make it easier to implement recommendations in other sections.
Energy efficiency, water conservation and increased process efficiency initiatives receive priority ranking because many of the recommendations for these initiatives overlap into other areas covered in this strategy or may receive a higher priority through the state’s Energy Strategy. Recommendations for initiatives in these sections should be implemented in ways that will complement pollution prevention programs throughout the Stiite of Ohio.
- Implementation of Initiatives
The Pollution Prevention Development Workgroup has identified the five hig;hest priority recommendations for each of the three sectors addressed in the strategy (State Government, Business and Industry, and Consumer Sectors). Initially, the five highest priority recommendations for each sector should be implemented. A discussion is also provided on groups of recommendations that Pollution Prevention Development Workgroup partiapants believe should receive priority attention during the implementation process. Recommendations contained in these ngroupsn should be implemented after the five highest priority recommendations for each sector are implemented.
Poilution Preuenfion Strategy for the Stafe of Ohio - DRAFT FWE/Fid Druft (March 28, 1994) Page 38 - A cooperative working relationship between government, business and ccII1sumers sectors is needed to ensure that recommendations are implemented in a cost effective and timely manner. The strategy identifies potential "lead" organizations for each recommendation. These organizations should involve all interested parties when directed to implement these recommendations.
State Government
"lie five highest priority recommendations for the State Government Sector is provided below followed by a discussion of which groups of recommendations should be given priority consideration after the initial recommendations are implemented.
1. Adm inistrative S U D D O ~ section, only recommendation for this section, on p . 11 Adminis frative support and commitment should be obtained io promote and implemen t pollution preveniion initiatives throughout state govemmen t. This should be completed by obtaining written upper management commitments in each department or agency to reduce waste whenever technically or economically feasible.
2. Economic Incentives section, recommendation no. 1 on p. 14 Ohio EPA should work with the Department of Development to establish a matching grant, revolving loan, low-interes t loan, andlor no-interest loan program for Ohio industry to implement pollution prevention practices and procedures, andlor purchase pollution prevention rela fed equipment. Funding for this program should be derived from either fhe General Revenue Fund, development of a Bond Issue, or a reallocation of existing Department of Development business development grants or loan programs. (This program should be developed concurrently with Item 1. under Small Business Assistance in the "Business and Industry" section).
3. Techn ical Assistance section, recommendation no. 2 on p. 15 & 16 Ohio EPA should work with business and trade organizations and the State of Ohio Edison Centers to determine what type of pollufion preveniion technical assistance efforts are most needed by Ohio business and industry and develop a plan to provide this assistance.
- Polltrtion Prevention Strategy fir the State of Ohio - DRAFT FIVE/Final Draft (March 28, 1994) Page 39
4. Overco mine Institutional Barriers to Pollution Prevent ion section, recommendation no. 3 on p . 17 Ohio EPA should review its permitting programs and develop methodologies for expediting the review and issuance of environmental permits for those companies that need new permits, or changes to existing permits, to complete poZlution prevention activities. These activities should be developed as part of a prioritized permitting system to ensure that permits which focus on source reduction and closed-loop recycling processes are reviewed before permits dealing with treatment or disposal activities,
5. ReFlatory Developme nt section, recommendation no. 1 on p . 18 Ohio EPA should establish a review process which ensures that pollution prevention is incorporated into all new state environmental regulations where appropriate.
State Government - Groups of Recommendations
The Pollution Prevention Development Workgroup believes the following wy~s of recommendations should be given priority consideration in regards to implementation after the initial five recommendations listed above are implemented. These groups include: Economic Incentives; Technical As2;istance; Regulatory Development; Energy Efficiency, Water Conservation and Process Efficiency; and Procurement.
Bu!3iness and Industry
Tht? five highest priority recommendations for the Business and Industry Sec:tor is provided below followed by a discussion of which groups of reomunendations should be given priority consideration after the initial reo ammend at ions are implement e d . 1. Po llution Prevention Plannine Proerama section, only recommendation
for this section, p. 27 The volun f a y pollution prevention planning programs described in this section should be implemented as recommended.
2. Small Business Ass istance section, recommendation no. 1 on p. 23 Have fhe Ohio EPA and the Department of Development determine the feasibility of establishing a small business low-interest loan or grant program for pollution
Pollution Preuenfion Sfrafegy for the State uf Ohio - DRAFT FZVE/Final Draft (March 28, 1994) Page 40 - prevention. Develop an implementation strategy and seek the required administrative andlor legislative changes necessary to implement this program. (This program should be developed concurrently with Item 1. under Economic Incentiveg in the "State Government" section.)
3. Comp liance Ass istancq section, recommendation no. 4 on p. 26 Ohio EPA should allow sufiient regulatory flexibility to allow the implementation of pollution prevention practices to meet environmental standards. Examples include: a) allowing extensions of regulato y deadlines in order for ,facilities to implement source reduction or recycling operations or equipment; and (b) allowing tempora y "short-term a excedences of environmental standards to implement source reduction or recycling opera fions or equipment.
4. :Economic Ince ntives section, recommendation no. 2 on p. 27 The Ohio Department of Taxation and the Ohio EPA should work together to determine if existing tax credit programs for water and air pollution control equipment should be modifid to include pollution prevention equipment.
5. .co mpliance Assistance section, recommendation no. 1 on p. 27 Ohio €PA should coordinate existing and planned regulato y and pollution prevention technical assistance efforts so businesses can obtain information on how to reduce a facility's overall generafion of porlufian to achieve compliance in various regulato y programs.
Business and Industry - Groups of Recommendations
The Pollution Prevention Development Workgroup believes the following poi - of recommendations should be given priority consideration in regards to implementation after the initial five recommendations listed above are implemented. These groups include: Economic Incentives; Small Business Assistance; Technical Assistance; Compliance Assistance; and Energy Efficiency, Water Conservation and Process Efficiency.
Cor isumer Sector
The five highest priority recommendations for the Consumer Sector is provided below followed by a discussion of which groups of recommendations should be given priority consideration after the initial recommendations are implemented.
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Pollution Prevention Strafegy for the Stafe of Ohio - DRAFT FWE/Fid Draft (March 28, 1994) Page PI -
1.
2.
3.
4.
5,
Technical Assistance section, recommendation no. 1 on p . 33 The State of Ohio should detemine the feasibiliiy of developing a computerized bulletin board andlor "1-800" toll free hotline where consumers can obtained information and assistance related to pollution prevention and other environmenfal issues.
E ; ch section, recommendation no. 1 on p. The Ohio EPA and Ohio Department of Natural Resources should focus existing consumer education and awareness campaigns on source reduction strategies along with recycling.
Education and Outreach section, recommendation no. 3 The State of Ohio should utilize local and county governments to distribute informational materials and promote source reduction and recycling strategies.
Technical Assistance section, recommendation no. 2 on p. 33 The State of Ohio, business and industy trade associations, and consumer groups should develop a pollution prevention "speakers bureau to provide presentations on pollution prevention opportunities for consumers and other interested parties.
E nerev Ef f iciencv and Water Conservation Initiatwes section, recomendation no. 3 on p . 31 Existing newsletters prepared by the State of Ohio should highlighf specific energy efficient products and water conservation measures. These newsletters should detail the long term cost saving and environmental benefits associated with these products and practices.
Consumer Sector - Groups of Recommendations
The Pollution Prevention Development Workgroup believes the following grclups of recommendations should be given priority consideration in regards to implementation after the initial five recommendations listed above are implemented. These groups include: Education and Outreach; Purchasing Inikatives; Technical Assistance; Energy Effiaency and Water Conservation Lni5atives; and Citizen and Public Group involvement.
Pollution Prevention Strategy for the State of Ohio - DRAFT FNEIFinal Draft (March 28, 1994) Page 42 - IdeadAfication of Resources
Three different scenarios exist for funding recommendations presented in this strategy. These scenarios are based on the type and degree of imp1,ementation that needs to occur to make these recommendations effective. The different funding possibilities for each recommendation is not listed since most recommendations could potentially be funded by a number of different mechanisms. Tying a recommendation to a specific funding mechanism may limit the ability of the implementing organization in securing adequate funds to implement a recommendation. Organizations responsible for implementing specific recommendations should also know the most appropriate way to secure funding for specific projects.
The three scenarios described below identify three categories for funding strategy recommendations and provide guidance on possible ways to secure funding for pollution prevention initiatives using traditional and non- traditional funding sources.
Scenmio One: Existing Resources - Many of the recommendations can be impl.emented using existing resources. These resources can either be reallocations of existing funds, modification of an individual's job duties to emphasize pollution prevention andlor the use of an existing funding source for pollution prevention programs. Revenue sources for some tax credit and pollution control programs use the term "abatementn which is defined as "prevention" among other things. Organizations need to review existing enabling legislation to determine if existing funding can be used for pollution prevention programs. Many existing recycling efforts should also be focusing on source reduction. Resources used to fund recycling programs could also be used for source reduction initiatives.
Scenario Two: Degree of Implemenfafion - Some recommendations can be implemented to varying degrees and stil l be effective. However, the effectiveness of the recommendation will often be tied to the funding provided. Education and outreach, technical assistance and other pollution prevention programs can be initiated with minimal funding but will require additional funding to increase their effectiveness over time. Often it easier to obtain additional funding for an effective program once a 'track recordn is established. Also, funding from non-profit or private foundations can be leveraged using a limited source of 'start-up" funding.
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Polhtion Prevention Strategy fir the State of Ohio - DRAFT FNE/Fiinal Draft (March 28, 1994) Page 43 - Scenlzrio Three: Recommendations Requiring Legislation - Recommendations requiring some degree of legislative support are described in the next section. Enakiling legislation should not be sought for implementing the reco~mendations in this strategy unless adequate funding can be provided. The state budget process can also be used to obtain additional funding for reco;mmendations not requiring enabling legislation. Funding for implementing many of the recommendations identified in this strategy should be derived from either the General Revenue Fund, development of a Bond Issue, or a reallocation of existing fees andlor fines received by the State of Ohio for environmental or development programs.
- Recommendations Reauirine LePjslative S UDDOTf
Most of the recommendations provided in this strategy can be implemented without additional legislative authorities. Recommendations that the Pollution Prevention Development Workgroup believes will require some t y p e of enabling legislation include:
State Government - Economic Incentives: The matching grant, revolving loan, lowinterest loan, andlor no-interest loan program for Ohio industry; tax credit program for companies who minimize a signiscant portion of their wastes; and co-investment programs for various pollution prevention projects may require some type of enabling legislation to provide the necessary authorities to implement these programs and to ensure that adequate funding is provided. State funding for these program should be derived from either the General Revenue Fund, development of a Bond Issue, or a reallocation of existing grant, loan or tax credit programs.
Sfafle Government - Overcoming Institutional Barriers to Pollu fion Prevention: The removal of statutory and regulatory barriers to completing pollution prevention activities in Ohio business and industry may require additional legislative authorities in certain instances and the modification of existing legislative authorities in others. Modification of current environmental permitting systems may require the modification of existing legislative authorities; however, much of the activity recommended for this section can be completed under the existing regulatory framework.
Business and Indust y - Pollution Prevention Planning Programs: If voluntary pollution prevention planning efforts fail to achieve a significant reduction in the amount of pollution generated, it is recommended that the State of Ohio seek and implement a legislative mandate r e q m g reductions in the amount
- Polfutitln Prmention Strategy for the State of Ohio - DRAFT FlVE/Final Dtafl (March 28, 1994) Puge 44
of toxics produced from a l l Toxic Release Inventory reporters and large quantity hazardous waste generators.
CONCLUSXON
The recommendations provided in this strategy were developed by the Pollution Prevention Development Workgroup in an effort to promote cost- effec.tive pollution prevention programs throughout the State of Ohio. The polic:y and program initiatives recommended in this strategy provide a framework for achieving substantial environmental improvements throughout all sectors of Ohio using pollution prevention. The members of the Pollution Prevention Development Workgroup believe that implementation of the reco:mmendations provided in this strategy represent the next logical step toward achieving the environmental goals of the State of Ohio and that this strategy provides a basis for focusing and coordinating existing and proposed pollution prevention programs.