How to make pollution-prevention systems work for your company

During P2 Week 2013, the National Pollution Prevention Roundtable promoted a Pollution Prevention (P2) Pioneer Webinar targeting state technical assistance programs (TAPs) and industry EHS staff. The webinar featured P2 pioneers Cindy McComas, Gary Hunt and Cam Metcalf, who shared their years of experience and thoughts on the evolution of P2.

They discussed the evolution perspectives from an end-of-pipe reactive mode to a production process approach and finally, to a proactive systems model. P2 has grown over the years, and it’s now in the “environmental sustainability” phase. Good plans are in place, but upper management commitment is essential for the approaches to succeed.

Using a systems approach

The evolution of successful P2 plans and programs has been a process of finding new ways for organizations to move from creating P2 awareness to promoting action plans through a systems approach process. Systems approaches already are used for creating processes relating to economics, energy, environment, innovation and quality. The EPA’s current Lean, Energy, Environmental Management Systems (EMSs) and Green Chemistry programs are examples of using a systems model to create innovative and effective approaches to reduce pollutants and encourage P2. 

The driving force for a P2 systems approach originally focused on hazardous wastes from small and large quantity generators (SQGs/LQGs). Waste minimization (WM) was defined as the reduction, to the extent feasible, in the amount of hazardous waste generated before any treatment, storage or disposal of that waste. The certification requirement for shipping hazardous waste specified that companies must have a program in place to reduce the volume and toxicity of waste generated to the degree the organization had determined to be economically practicable. 

In 1989, EPA provided guidance on the six program elements that organizations seeking to prepare waste minimization programs as required by the Resource Conservation and Recovery Act (RCRA) should consider. The elements were providing top management support, charactering waste generation and management costs, performing periodic waste minimization assessments, maintaining a cost allocation system to determine the true cost of waste management, encouraging technology transfer, and implementing the program and conducting evaluations to determine effectiveness. Initially, this hazardous waste focus appeared to impede the application of a systems approach to improving performance in other environmental media. 

Smart standards and systems lead the way

The next progression for environmental improvement, the ISO 14001 Environmental Management System (EMS) standard, has been promoted as an effective systems approach for organizations to use for planning and achieving regulatory compliance, as well as meeting pollution prevention (P2) and energy efficiency (E2) goals. The ISO 14001 standard provides an EMS framework that requires companies to consider, review and implement P2 opportunities, as well as report results, on a continuous basis. The ISO 14001 EMS template includes five major program elements: policy development and dissemination, planning, implementation, checking/corrective actions and management review of the system. 

An EMS promotes integration of environmental management with operations and overall organizational management, a critical need in today’s changing business climate. The basic premise of the system boils down to this: “Say what you do, do what you say. If it moves, train it. If it doesn’t move, calibrate it. No matter what you do, document it.” 

Energy use became a large cost center for organizations and, as energy rates continued to increase, systems approaches for energy efficiency (E2) were developed. These include EPA’s Energy Star 7-step Energy Management Process and the Department of Energy’s Superior Energy Performance with the ISO 50001 Energy Management System (EnMS). Additionally, the new smarter system (Innovation System) for Innovation Engineering emerged. This system uses a “define, discover, develop and deliver” model to improve the chances of success of new ideas, which an organization moves into development to save them energy, money and time.  

As the 21st century dawned, organizations that used applied systems approaches recognized the need for sustainability as a core value to drive strategic planning and resource management. They began using management systems as the operational tool to achieve annual economic, energy and environmental (E3) goals, objectives and targets. Sustainability became an integral part of strategic planning. Companies began to use their P2 programs to increase productivity, quality and economic viability, while also considering the environment and the community’s well-being. 

The importance of a strong commitment

There are system approaches galore to choose from to pursue P2 accomplishments. When you select a system to use for change, the real work begins. There is only one way to success: a top-down approach of commitment to continual improvement by leadership and management. We often hear the familiar refrain “If it ain’t broke, don’t fix it.” My response to that is, “If you don’t fix it, you may go broke!” 

Senior management commitment to continuous improvement is the most critical step to overcoming the gap between P2 planning and implementation. Senior level commitment also needs to percolate throughout the entire organization so that P2 principles become part of the organization’s culture and P2 practices continue when managers leave and new people take their places.

Achieving successful implementation through any systems approach requires top level support communicated by management policies; establishment of a cross-functional team that represents the administrative and process knowledge of the organization; and appointment of a leader to ensure continuity of focus, communications and effort. In order for an organization to be able to identify and implement P2 practices and continuously innovate and improve them, they must have an engaged team supported by managers that recognize pollution prevention as a critical business strategy.

Smokestack photo by Captain Kimo via Flickr