Assumptions Underlying the Shift to Pollution Prevention and Green Design

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Much of the environment legislation enacted in the 1970s and 1980s was media-specific; that is, each statute focused on either emissions to air, discharges to water, or disposal on land. This approach arose from a general consensus that industry should be in charge of deciding how to manufacture its products. The government's role was/is to protect human health and the environment and therefore should be limited to regulating emissions, discharges, and wastes after they leave the manufacturing facility.

There were several assumptions built into this approach, however. It was assumed that if the adverse impacts of waste disposal on the public increased, the public marketplace would resist by making it more difficult for industries to site disposal facilities, which would in turn drive up the costs of waste management. As the cost of waste management rose, industry would find an equilibrium point at which it was no longer profitable to generate and manage waste. Consequently, business managers would be forced to find more efficient ways of producing goods and services in order to stay in business.

In general, these were probably good assumptions, but several unanticipated factors slipped into the equation. First, the study of the impacts of contaminants on human health and the environment was not as advanced as manufacturing science and technology. Therefore, neither the government, the public, nor industry could fully evaluate the costs of the impacts of waste management on the environment and assign a true cost to that activity.

Second, no one anticipated some of the outcomes of media-specific statutes. In general, each of these statutes sets standards without considering relationships to other media. In some cases, media-specific statutes have inadvertently promoted the shifting of pollutant releases from one medium to another without reducing the overall generation of pollutants. For example, some of EPA's air quality emissions standards are based on end-of-pipe pollution control technologies such as stack gas scrubbing. In the past, in order to achieve compliance quickly and with certainty, manufacturers often chose to add a stack gas scrubber to the smokestack rather than redesign their products and/or the production process to eliminate the source of the toxic emission. Using a scrubber achieved compliance with air regulations by removing pollutants from stack gases and transferring these pollutants to scrubber wastewaters. What were once air emissions, therefore, become water pollutants.

Similarly, to comply with Clean Water Act regulations, most manufacturers chose to add wastewater treatment plants at the end of the pipe rather than redesign products or processes to reduce pollutants at the source. Thus, while wastewater treatment removed pollutants from wastewater, it transferred these pollutants, in the form of sludge, to a waste that was usually incincerated (thereby creating an air emissions problem) and/or was disposed of in landfills.

There is no doubt that the United States has made significant headway in cleaning up the environment using a media-specific approach. However, two significant problems arose as a result:

1. End-of-pipe pollution control doesn't really solve the problem—it just moves it from medium to medium.

2. Managing waste costs money and adds to the cost of production—often at the expense of other opportunities.

As noted earlier, the cost of the end-of-pipe approach has risen to an estimated $115 billion annually.

Figure 1 illustrates the amount of solid waste generated annually in the United States— estimated at 13.2 billion tons per year.

In addition to generating solid waste, industry releases billions of pounds of toxic chemicals to the air and to deep underground injection wells each year. Some of these releases are legally permitted releases, and some are not. The extent to which the unpermitted releases cause a risk, if any, is not known. However, in all cases managing releases costs money.

Hazardous (0.7)

Non-hazardous (11)

Manufacturing (6.5)

Non-hazardous (11)

Hazardous (0.7)

Manufacturing (6.5)

Figure 1 "Solid" wastes as defined under the Resource Conservation and Recovery Act (RCRA).

(a) All RCRA wastes (billions of tons); (b) nonhazardous RCRA wastes (billions of tons). Much of the solid waste produced in the United States is not directly generated by consumers. Municipal solid waste, the focus of much public concern, represents less than 2% of all solid waste regulated under RCRA. In contrast, industrial activities produce about 700 million tons of hazardous waste (a) and about 11 billion tons of nonhazardous wastes (b). Note: All numbers are estimates. The nonhazardous waste total has been rounded to reflect uncertainty. Much of the "solid" waste defined under RCRA, perhaps as much as 70%, consists of wastewater. The terms hazardous and nonhazardous refer to statutory definitions of Subtitles C and D of RCRA, respectively. The mining wastes shown in (b) exclude mineral processing wastes; the oil/gas wastes in (b) exclude produced waters used for enhanced oil recovery; the "other" category in (b) includes wastes from utility coal combustion. (Adapted from U.S. Congress, Office of Technology Assessment, Managing Industrial Solid Wastes From Manufacturing, Mining, Oil and Gas Production, and Utility Coal Combustion, OTA-BP-O-82, U.S. Govt. Printing Office, Washington, D.C., February 1992.)

A recent Chemical Manufacturers Association survey indicates that about 20% of new capital expenditures are now for pollution abatement and control [1]. Furthermore, as a result of the escalating costs associated with federal environmental regulations, a number of petroleum refineries in the United States have closed. Increasingly, companies are sacrificing less profitable refineries in favor of those capable of absorbing the costs of complying with environmental requirements. No new refineries have been built in the United States in the past 15 years [2].

By the mid-1980s, it had become clear to government and industry that the key to increasing economic competitiveness and environmental improvement was pollution prevention. There was compelling evidence that companies who were pioneers in pollution prevention were saving money on waste management, generating less pollution, and improving their competitive position as a result.

In 1984, Congress began a serious search for a preventive approach that would lessen the costs of end-of-pipe management and reduce the amount of waste generated. In 1986, both EPA [3] and the Congressional Office of Technology Assessment [4] published reports that explored this issue. Both reports pointed to the need for government and industry to find new incentives to reduce the amount of pollution generated and suggested specific approaches that should be explored and implemented.

At the same time, Congress began work on Community Right-To-Know Legislation (EPCRA), which helped to spur citizen concern about chemical use in factories and chemical releases to the environment. Citizens and public interest groups have become wiser in their purchasing choices and have greater access to information on the effects of toxic chemicals on human health and the environment. Citizen groups are placing increased pressure on industry to reduce the use of toxic chemicals in consumer products and to recycle used products to prevent them from causing harm and also from taking up precious landfill space. Consumer sure has caused major companies to change product lines, use alternative packaging, and design products composed of less toxic materials to meet public demand.

The combined effect of the government's shift in priorities (from end-of-pipe pollution control to up-front pollution prevention) and enhanced citizen awareness and involvement is influencing the way the United States will conduct business in the future. The next sections provide the reader with an overview of the types of programs that are under way.

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