P2 in the new millennium

Definitions of P2

The interpretation of P2 varies. The 1990 Pollution Prevention Act defined P2 as "reducing the generation of waste and pollution at the source." Environmental regulatory agencies have put P2 at the top of the hierarchy of approaches to solid and hazardous waste management strategies: prevention, recycling, treatment, and disposal. Others define P2 as "any means that would avoid, reduce or prevent pollutant discharges or emissions other than traditional methods of treatment." However pollution prevention is defined, it is viewed as voluntary and as affecting releases to air, land, and water. Because P2 is an unmandated environmental management strategy and because it involves all traditional and established environmental regulatory programs (including the SPDES program), it presents both challenges and benefits.

Challenges to progress

Unlike mandated and government-funded regulatory programs for air, water, and land releases, government P2 programs are often considered "nice but not necessary" and lack dedicated funding. Many states have been unable to maintain a P2 program in the face of budget cuts, but New York continues to support one of the largest such programs in the nation.

Another barrier experienced by P2 programs is the difficulty of documenting measures of success. It is certainly true that the continued decreases in toxic releases (more than 70% from 1988 to 1998 for core reporting industries and chemicals as shown by the Toxic Release Inventory) is due in part to P2, yet there is no way to demonstrate the specific contributions that P2 has made to those reductions. Furthermore, most government technical assistance programs concentrate on working with small businesses, and reductions occurring from them are not captured by TRI because most small businesses operate below the required reporting levels. Thus, the effectiveness of most technical assistance programs can be measured only anecdotally or by developing and conducting survey mechanisms or metrics. Many P2 assistance programs are working to understand better the effects and progress of P2 assistance programs on the implementation of P2 strategies and reductions in toxic releases.

P2 progress in New York State

P2 programs in most states operate with minimal base funding and must seek additional funds through competitive grant awards, primarily offered by USEPA. The NYSDEC Pollution Prevention Unit has applied for and obtained over $3 million to support P2 outreach and other projects aimed at reducing toxic releases. The NYSDEC P2 Unit has conducted over sixty workshops and training sessions, held eight annual P2 conferences, and published many documents including an award-winning self-audit manual for small business. (Publications include a series of self assessments and P2 guides for small quantity generators, printers, vehicle maintenance shops, health care facilities, and the electronics industry. This series will soon include manuals for metal finishers, the pulp and paper industry, and marinas.

Many documents can be downloaded from the P2 Unit's web site.

This year Pollution Prevention Week is celebrated September 17 - 23, 2000. Please check the PPU web site to take part in P2 Week events.

Look for a children's poster contest as part of Pollution Prevention Week.

The NYSDEC P2 Unit has also recognized businesses and organizations that have reduced releases of toxics from their facilities through the Governor's Awards program. Forty-five awards have been given for projects that have documented the elimination of 15 million lb of toxic and hazardous wastes releases. This year, the Awards will give particular attention to projects that show reductions in persistent, bioaccumulative, and toxic substances (PBTs).

1999 winners of the Governor's P2 Award, from left: DEC Deputy Commissioner Carl Johnson, Robert Aman—AA Dairy, Clarence Rappleya—NY Power Authority, Jim Casola—Corning Inc., Joseph Shandling—U.S. Military Academy West Point, Marvin Stillman - University of Rochester-Strong Memorial Hospital Diana Bendz—IBM Endicott

Since 1992 nearly two hundred industrial facilities have been addressed through an integrated facility management approach known as the M2P2 Program. This program brings together relevant environmental quality programs to work together to assemble and assess pertinent information, to coordinate media inspections - usually at a single time—and then to evaluate comprehensively each selected facility. The majority of these facilities have been responsible for most of the toxic and hazardous releases in the state. Again, it is difficult to measure the effects that the program has had on releases, but it is known that communication and joint problem-solving among agency staff and with facility personnel has increased.

Partnerships for P2

The NYSDEC P2 Unit works with a variety of partners to develop and deliver New York's P2 program. A Comparative Risk Project is being conducted involving over a hundred individuals from business, environmental, citizen, academic, legislative, and other groups to develop a risk-based strategy for P2. By characterizing risks associated with toxic releases and the procedures that can be applied to reduce those risks, this project will be able to recommend ways to make the P2 program more effective in improving the environmental resources, public health, and quality of life in New York.

Many of the NYSDEC's environmental assistance partners, such as the USEPA, the NYS Environmental Facilities Corp., and the NYS Energy Research and Development Authority, have contributed articles to this issue of CLEARWATERS. The P2 Unit also works closely with the Business Council of NYS, Inc., which co-sponsors the annual P2 Conference and assists with other P2 activities.

The future of P2 in New York

Throughout the next year and beyond, the P2 Program will focus on ways to rank efforts to obtain the greatest reductions in risks to human health and the environment, the development of metrics that will demonstrate program effectiveness, new efforts to integrate P2 into regulatory programs, establishment of new and enhanced partnerships, and delivering a more effective outreach program. Specific activities include:

Prioritize

    The M2P2 program will focus on specific industry sectors such as metal finishers. Opportunities to emphasize reductions in PBTs will be developed. Recommendations from the Comparative Risk Project will be used in strategic planning.

Measure

    Appropriate metrics will be developed, data collected and shared with others. Progress will be described quantitatively.

Integrate

    The M2P2 program will continue its integrated facility management approach. Opportunities will be pursued for using P2 in permitting, enforcement, and other program activities.

Collaborate

    Partnerships will be continued and enhanced with USEPA, other state agencies, and business organizations. New partnerships will be investigated, for example the New York Water Environment Association.

Educate

    Traditional outreach methods will be refined and enhanced. High priority sectors, such as health care facilities, will be addressed.

Click here to go to the web site of NYSDEC's Pollution Prevention Unit.
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Mary Werner is director of NYSDEC's Pollution Prevention Unit.