Journal of the Air & Waste Management Association

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Industrial Pollution Prevention

David T. Alien , Terry Foecke , Howard Klee Jr. , W. B. Beck , Lawrence L. Ross ,
Arthur H. Purcell , Joel S. Hirschhorn & Harry Freeman

To cite this article: David T. Alien , Terry Foecke , Howard Klee Jr. , W. B. Beck , Lawrence
L. Ross , Arthur H. Purcell , Joel S. Hirschhorn & Harry Freeman (1992) Industrial Pollution
Prevention, Journal of the Air & Waste Management Association, 42:9, 1159-1167, DOI:
10.1080/10473289.1992.10467061

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 Industrial Pollution Prevention

Critical Review Discussion Papers

The 1992 A&WMA Critical Review was authored by Harry Freeman and members of
his staff at the Pollution Prevention Research Branch, Risk Reduction Engineering
Laboratory, U.S. Environmental Protection Agency in Cincinnati, Ohio. Mr. Free-
man presented the paper "Industrial Pollution Prevention," at the Critical Review
session held during the 85th Air & Waste Management Association Annual Meeting
in Kansas City, Missouri. Prepared discussions and invited comments presented
during the session are published here, as well as closing remarks by Mr. Freeman.

Prepared Discussion next generation of improvements will require significant

David T. Alien
Department of Chemical Engineering
University of California
Los Angeles, California
I appreciate the privilege and opportunity to comment on
the excellent review of "Industrial Pollution Prevention"
by Harry Freeman and his colleagues. Their review is a
comprehensive examination of a rapidly moving and loosely
defined field. In my comments, I will expand on just a few of
the many topics covered in the review. Specifically, I will
address the issues of the technological roadblocks to pollu-
tion prevention in manufacturing processes and educa-
tional needs at the university level.
Technological Roadblocks to Pollution Prevention in
Manufacturing Processes
In order to understand the nature of the technical
roadblocks to process pollution prevention, one must under-
stand how pollution prevention is currently practiced.
Initial efforts at pollution prevention have been aimed at
the most easily achieved targets. Good housekeeping prac-
tices, inventory control, and minor changes in operating
practices have resulted in an impressive amount of waste
reduction. This type of activity is rapidly approaching its
limit, however, and a second generation of waste reduction
is beginning to be implemented. In this second generation
of waste reduction, industry uses current technology, most
often separation technologies and material substitutions, to
reduce emissions and wastes. Many examples of this second
generation of activity are cited in the Critical Review.
Among them are ion exchange for the recovery of metals,
ultrasonic cleaning and distillation for solvent recycling.
These activities have had substantial impact, but, as was
the case for good housekeeping practices, there will be
limits to the effectiveness of current technology and a third
generation of pollution prevention will be required. This
Copyright 1992—Air & Waste Management Association
technological advances in reaction engineering, separation
science, and process synthesis. It will also require the
development of pollution prevention measurement tools so
that critical emissions and waste streams can be targeted
for prevention. Each of these elements of a third generation
of process pollution prevention is discussed in more detail
below, beginning with the complex issues of pollution
prevention measurement.
Pollution Prevention Measurement
In their conclusions, Freeman et al., note that "Measur-
(ing) pollution prevention is the biggest P2 (Pollution
Prevention) issue currently facing the industrial
community." This contentious measurement issue has
come to focus on two points. One of the points of contention
is the definition of pollution. Almost by default, the releases
and off-site transfers reported through the Toxic Release
Inventory has become the dominant measure of industry's
pollutants. The TRI has assumed this role because multime-
dia releases are reported, individual chemicals are identified
and the data are readily available to the public and to
environmental advocacy groups. The TRI has serious flaws,
however. It accounts for only a small fraction (much less
than 1 percent) of the estimated 12 billion tons (wet basis)1
of industrial pollutants generated annually. In addition, the
TRI has, for its first four years, focussed on reporting
releases and off-site transfers, rather than reporting gener-
ation. Thus, it has been difficult to separate pollution
prevention activities from increased waste treatment. These
deficiencies make the TRI a far from ideal measurement
tool for pollution prevention, but, other data sources such
as the RCRA biennial survey are also flawed (for a critical
analysis, see Reference 2). Recent additions to the TRI
reporting requirements, mandated by the Pollution Preven-
tion Act of 1990, may improve the situation, but clearly
much work needs to be done.
A second point of contention in measuring pollution
prevention is the issue of indexing. Most proposed mea-
sures of pollution prevention recognize the need to relate
the generation of wastes and emissions to the level of
industrial activity. For example, in the new TRI form R,
facilities are to provide a production ratio or activity index.

September 1992 Volume 42, No. 9 1159

CRITICAL REVIEW DISCUSSION
This index could be the production level (pounds of prod-
uct), number of employees, sales volume, or some other
measure of activity. The relative merits of some of these
measures has been qualitatively reviewed by Research
Triangle Institute, 3 and it seems clear that no single
activity index will be applicable for all industrial sectors. It
would be irrational, for example, to index the releases of
aircraft manufacturing operations to the mass of the
vehicles they produced and compare that to the releases of
the chemical manufacturing industries, indexed to the
same variable. But, if no single index can be universally
applied, then significant research will be required to estab-
lish norms by industry sector.
In summary, I agree with the statements in the Critical
Review that call for work on measuring pollution preven-
tion. These statements need to be strengthened and ex-
panded, however, noting that the use of a single, universally
applied measurement index is unlikely to be successful and
that significant work needs to be done to identify a set of
appropriate indices.
Process Design for Pollution Prevention
The development of quantitative flowsheet analysis tools
for pollution prevention is currently in its infancy, but
powerful new tools are on the horizon that will permit the
systematic analysis of process flowsheets for pollution
prevention. To understand the fundamental principles
underlying these methods, it is helpful to consider the
somewhat analogous problem of the design of energy
efficient processes. During the late 1970's and early 1980's,
design methods were developed for Heat Exchange Net-
works (HENs) that would minimize the energy lost by
processes. Simply stated, heat exchange network synthesis
systematically examines all of the heating and cooling
requirements called for in a flowsheet and then determines
the extent to which streams that must have their tempera-
ture raised can be heated by streams that need to be cooled.
Although incorporating thermodynamic and equipment
constraints into the problem can be mathematically com-
plex, the concept of heat exchange networks is beautifully
simple: if a stream must be heated, why not use the energy
from streams that must be cooled?
Heat Exchange Network synthesis has seen widespread
application by industry and has resulted in considerable
energy savings. Analogous concepts in Mass Exchange
Network (MEN) synthesis have been developed by Manou-
siouthakis and coworkers4'5 and have significant potential
for pollution prevention. Simply stated, mass exchange
network theory determines the extent to which molecules
that are potential pollutants can be transferred to streams
in which they have a positive value. As an example of the
implementation of a MEN, consider refinery wastewaters.
One of the waste components of interest in refinery waste-
waters is phenol. Phenol can be found in the water effluent
of catalytic cracking units, desalter wash water and spent
sweetening waters. In these streams, phenol is a pollutant,
but in other refinery systems phenol can be a valuable
additive. The goal of the MEN synthesis is to identify the
optimal process configuration for transferring phenol be-
tween the streams in which it is a pollutant into streams in
which it is a product. The Mass Exchange Network (MEN)
synthesis identifies the process configuration that mini-
mizes the amount of phenol that appears as a pollutant.
The synthesis incorporates thermodynamic and equipment
constraints and helps to determine the maximum extent to
which pollution prevention can be achieved for a specified
process and a specified pollutant. The details of the method-
1160
William Beck and David Allen
ology and a number of examples are available in the
literature, and I will not discuss them here. The reason I
present MEN synthesis here is that it defines a realistic
alternative to zero-discharge as a goal for pollution preven-
tion. In many cases, zero discharge from a process is
thermodynamically infeasible. Techniques such as MEN
synthesis help to define what goals are feasible.
To summarize, the Critical Review promoted zero dis-
charge as an achievable goal for many industrial processes.
My reaction, typical of many trained in thermodynamics, is
that it is often impossible to achieve zero discharge and it
can be misleading to target zero as a goal. Instead, process
analysis tools that identify thermodynamically feasible
targets should be employed.
Reaction Engineering and Separation Processes for
Pollution Prevention
Process design and analysis methods can be identify
targets of opportunity for pollution prevention. Some of
these opportunities can be exploited using conventional
technologies; exploiting other opportunities may require
novel new unit operations. Several forums have been
convened to review these needs, including the meeting cited
in the Critical Review, held by the American Institute of
Chemical Engineers' Center for Waste Reduction Technolo-
gies and the Department of Energy's Industrial Technolo-
gies Program.6 Others include a workshop jointly spon-
sored by the National Science Foundation, the U.S. EPA
and the American Institute of Chemical Engineers,7 and
the EPA's own pollution prevention research plan.8
Taken together, pollution prevention measurement, pro-
cess design for pollution prevention and unit operation
design for pollution prevention represent a hierarchical
method for performing P2. If measures of pollution preven-
tion are available, then critical waste and process streams
requiring prevention can be identified. The targeted streams
and processes can be examined for their pollution preven-
tion potential using flowsheet analysis tools and, where
necessary, new technologies can be developed. The imple-
mentation of this type of systematic approach to pollution
prevention has been reported only occasionally, but these
few examples, such as the Amoco/EPA Pollution Preven-
tion project,9 present a picture of how process pollution
prevention will be carried out in the decade ahead.
University Education in Pollution Prevention
In the previous section, I outlined some of the technologi-
cal barriers to pollution prevention in three sections:
pollution prevention measurement, process design methods
and unit operation design. Do these technological areas
form a new discipline of pollution prevention? This ques-
J. Air Waste Manage. Assoc.
tion is central to the evolution of the field. Although Mr.
Freeman and his colleagues do not directly address this
question in their review, a consensus on this issue is
critically important for the further development of pollu-
tion prevention.
Is there a field of Pollution Prevention? Many of the
topics discussed in the Critical Review indicate that pollu-
tion prevention might become an area of specialization
within some existing disciplines. Life cycle analyses, design
for environment and the design of clean chemical technolo-
gies are becoming areas of specialization that require a
definitive set of skills and knowledge. To illustrate this
point, consider the design of clean chemical processes.
Chemical process design for pollution prevention is a
variation of traditional chemical process design, as prac-
ticed for decades by chemical engineers. It requires all of
the traditional skills required of chemical engineers, and
some additional degree of specialization. The specialist in
chemical process design for pollution prevention must have
skills in emission estimation methods, in designing unit
operations for minimum production of waste, in evaluating
flowsheets for pollution prevention, in determining the true
costs of wastes and in measuring success in pollution
prevention. Certainly some of these skills should be taught
to all chemical process designers, but real mastery of the
issues will require pollution prevention specialists. Fur-
ther, these experts must be exposed to disciplines not
normally studied by engineers, including public health and
public policy. This type of interdisciplinary education is
beginning to emerge at some universities, such as UCLA,
but it is in its infancy. It is also important to note that while
pollution prevention experts will be required, it is likely
that several different types of experts will be necessary. An
expert in Chemical Process Design for Pollution Prevention
might be a chemical engineer who has specialized in
pollution prevention while Product Design for Pollution
Prevention/Design for Environment might be a specializa-
tion within the field of Industrial Design.
This emphasis on experts does not mean that environmen-
tal literacy, including literacy in pollution prevention, will
not be important. Some measure of environmental literacy
will be an essential part of the body of knowledge that a well
educated person must have in the 21st century. Progress in
pollution prevention education must proceed on several
fronts, which are described in Reference 10. An understand-
Prepared Discussion
Terry Foecke
WRITAR
Minneapolis, Minnesota
My overall impression of this paper is that it considers the
right content areas, in the right order, and offers some solid
insights in its concept summaries, especially in the sections
on Total Cost Assessment, Management and Business, and
Life Cycle Analysis. In addition, this critical review showed
particular intelligence in selecting and analyzing articles on
Toxics Use Reduction, Research Needs, and Development
of New Unit Operations. These content areas are breaking
new ground rapidly, are very important and/or influential
and deserve the thought given them. My overall grade is a
B+. The only reason this paper does not earn a better grade
September 1992 Volume 42, No. 9
ing of pollution prevention must become a part of a broader
environmental literacy provided to all citizens and, in
addition, curricula for pollution prevention experts must be
developed.
Having reached this conclusion, I must disagree with the
assessment made in the Critical Review that there may be
more benefit in focussing on pollution prevention education
in public policy programs, business schools and design
programs than on the continued development of engineer-
ing education in pollution prevention. Both are necessary.
Summary
Harry Freeman and his colleagues have provided a
comprehensive review of a challenging subject. Their Criti-
cal Review has given structure to a seemingly amorphous
field. My comments are intended only to add emphasis in
certain areas, specifically education, the technological barri-
ers to pollution prevention, and measurement of pollution
prevention.
References
1. Allen, D. T.; Jain, R., Eds., "National Hazardous Waste
Databases: generation and fate of hazardous materials in the
USA," Hazard. Waste Hazard. Mater. 9:1 (1992).
2. U.S. General Accounting Office, "Hazardous waste: data man-
agement problems delay EPA's assessment of minimization
efforts," GAO/RCED-91-131 (1991).
3. Research Triangle Institute, "Alternatives for Measuring Haz-
ardous Waste Reduction," Final Report to Illinois Hazardous
Waste Research and Information Center, Champaign, IL
(1989).
4. El-Halwagi, M. M.; Manousiouthakis, V. "Synthesis of mass
exchange networks," AIChEJ. 35:1233 (1989).
5. El-Halwagi, M. M.; Manousiouthakis, V. "Automatic Synthe-
sis of Mass Exchange Networks," Chem. Engineer. Sci. 45:
2813 (1990).
6. U.S. Department of Energy, "Report of the CWRT Workshop
on: Waste Reduction R&D Opportunities in Industry," DOE/
CE/40762T-H4 (1991).
7. Jefcoat, I. A.; Overcash, M. "AIChE/EPA/NSF Workshop on
Waste Minimization Research Needs," Gulf Coast Hazardous
Substance Research Center Report (1989).
8. U.S. Environmental Protection Agency, "Pollution Preven-
tion Research Plan: Report to Congress," (1989).
9. Klee, H. "Final Report: Amoco/EPA Pollution Prevention
Project," to be available through NTIS (1992).
10. Report of the Academic Focus Group, Pollution Prevention
Education Committee National Advisory Council on Environ-
mental Policy and Technology, in preparation (1992).
is my high expectations for such excellent and experienced
authors.
Before going on to the specifics of my discussion, I would
like to posit two organizing statements. One, I believe that a
critical review should not only select, analyze and explicate,
but that it should also cast aspersions where needed and
give praise where deserved, in an attempt to set the agenda
for future efforts in the field of endeavor under examina-
tion. Two, I believe that a critical review should not only
review the literature that exists, but also assess the quality
of that body of information in the aggregate, and then point
out where more work is needed. Held up against these
guiding principles of judgment and guidance, this critical
review earns a B—. Therefore, it being easier and more
interesting to criticize than to praise, I will focus my
comments on those conclusions where I found judgment
and/or guidance to be particularly lacking.
Especially in a field in search of definition and organiza-
tion, such as pollution prevention is, one of the most
1161
CRITICAL RB/IEWDISCUSSION
important functions of a critical review is to clarify who is
doing what. This paper reviews 51 papers, nearly 25 percent
of the total cited, in an attempt to reach this clarity. The
paper then builds six of its 21 conclusions around that body
of information. (I found Conclusion #2, which states that
the literature shows that pollution prevention yields "bot-
tom line" savings, to be misplaced, intermingled as it is
with commentary on different sectors and their program-
matic efforts). Of those six conclusions, I have significant
differences of opinion with two. (As in all these comments
on the Review itself, my intent is to show whether or not
the Conclusions are supported by the literature, or whether
or not the literature itself is reflective of experience).
Conclusion # 3 states: "While there are those who persua-
sively point out deficiencies in current federal P2 efforts, it
is concluded that the federal government is promoting
pollution prevention."
In my opinion, this conclusion suffers in its quality of
judgment, perhaps because of the closeness of the authors
to the subject matter at hand. While an impressive amount
of activity can be cited and analyzed, little concomitant
structural organizational change can be used to support the
conclusion. That desire for structural change within organi-
zations is not merely my own. To hoist the authors upon
their own petard, I will paraphrase from their discussion of
education and its effects on the implementation of pollution
prevention:
"There is a lack of literature detailing any refinement of
environmental values with traditional management values . . .
[The values of] future managers would not be sustainable
against institutional disinterest."
There is a similar lack of literature chronicling refinement
of pollution prevention values with traditional environmen-
tal management values within federal agencies. Program-
matically, federal agencies are more or less healthy as
regards pollution prevention, showing considerable activ-
ity. However, there is a grave risk of mistaking activity for
progress. Organizationally, the federal government falls
short of the mark. I offer as support examples that I find
damning of the efforts of each of the agencies cited in the
Conclusion: EPA, DOD and DOE.
In the EPA Regions, resources are provided to secure and
maintain a Pollution Prevention Coordinator in each Re-
gional office, and sometimes a Pollution Prevention team.
Yet examination shows that these Coordinators are placed
variously in Policy offices, RCRA, Water and several who
are simply on "special assignment." This variety of place-
ment, often seen (and condemned as wanting) in industrial
programs, does not bespeak management commitment or
excellent teamwork. But those are two of the basic priciples
of excellent programs cited by the authors themselves in
their section on "Industrial P2 Programs."
At DOD, we have had occasion to work with both the
Marine Corps Logistics Base in Barstow, CA and the
Aberdeen Proving Ground in Aberdeen, MD, and found
piles of documentation in the form of assessments and
reports, but little buy-in at the management level or even
simple understanding at the operations level. To illustrate
the first, we were told of requests going back six years (to
the beginning of the DOD HAZMIN program) for reforma-
tion of the purchasing and inventory systems for laboratory
chemicals because of the extremely high volumes of waste
being generated. Those requests have been reviewed by
managers, and never funded, because management saw its
job to be facilitating research, not managing (or reducing)
waste. To illustrate the second, even though a facility was
in possession of a detailed pollution prevention opportunity
1162
Terry Foecke and Harry Freeman
assessment document, and, for example, workers in vehicle
maintenance knew that substitutes to solvent cleaning
needed to be made, the information in the assessment
report, which would have given chapter and verse the
implementation steps to be taken, had never been transmit-
ted beyond the environmental officer's office.
At DOE, we have worked with the Idaho National
Engineering Laboratory in Idaho Falls and found reactions
ranging from confusion to anger on the part of DOE
contractors who are attempting to interpret DOE waste
reduction guidances they considered to be at the very best
vague (as well as unfunded). An especially egregious exam-
ple of this is the requirement that each contractor complete
Process Waste Assessments (which characterize waste
streams as well as identify pollution prevention opportuni-
ties) on a mandated percentage of their waste streams by
the end of 1992. This arbitrary goal ignores the difficulties
of waste source identification, the lack of a "chargeback"
system for waste management and disposal costs (effective-
ly thwarting options analysis and comparison), and the
reality that many DOE programs are in a transition period
and find it difficult to confront the long horizons of pollu-
tion prevention implementation.
Perhaps the safest thing to say about these examples and
this Conclusion is that the Conclusion is at best premature,
and at worst misleading. I also would like to make it clear
that I understand that major organizational change re-
quires much more time than the five to nine years already
expended, making counterexamples to progress fairly easy
to locate. However, I mean to qualify the Conclusion, not
attack the organizations cited.
Continuing with the theme of who is doing what, the
review also examines the literature on state and local
pollution prevention programs, and makes the following
statements:
"State pollution prevention programs continue to expand and
provide ideas for encouraging pollution prevention that the
federal government should be aware of."
"Active local pollution prevention programs seem to be the
exception rather than the rule."
This Conclusion suffers mostly from a lack of guidance on
the part of the authors, and in my opinion is not supported
by the literature. The presumption is that state and local
programs present (or lack) something of material value. Yet
the authors themselves in Conclusion #18 call for "evalua-
tions of recently implemented state programs...." It is
precisely this evaluating of information that is absent from
the literature cited, and that lack of evaluation seems to
condemn the statement in Conclusion #4:
"The incorporation of such [facility planning] requirements
into national legislation will have an enormous effect on
reducing generation rates throughout the country."
This Conclusion at least potentially repeats the error of
mistaking activity for progress. Even if we set aside the
J. Air Waste Manage. Assoc.
hesitations, pointed out by the authors, in such areas as
measurement, cost effectiveness, education, incentives and
barriers, we are still left with the problem of saying exactly
what effect or even influence state and local programs have.
All we can say with certainty from the literature, in my
opinion, is that state and local programs exist, that they
have ideas, and that they are attempting to implement
those ideas.
On the matter of local programs, the literature clearly
lags reality. Although the authors mention an effort to base
pollution prevention efforts in publicly owned treatment
works as evidence of some progress, the facts are that a
number of realizations are urging and facilitating the
creation of ever more and more integrated, local pollution
prevention efforts. One of those realizations is that pollu-
tion prevention at the local level has much to do with jobs,
economic vitality, and the survival of neighborhoods. An-
other is that the original focus of industrial hazardous
waste has expanded to include air, energy, transportation,
agriculture and municipal solid waste, all of which may
have their own programs or any of which may band
together to attack the broader issue of resource steward-
ship. Local efforts may very well be the next powerful wave
of innovation and implementation.
The final conclusion with which I will take issue in the
"who is doing what" vein is #7, which states in part:
"There is no shortage of successful impressive industrial
pollution prevention programs. The literature is full of reports
from primarily large companies on their impressive results."
[emphasis added]
Guidance and judgment both seem lacking in this Conclu-
sion, but my concern is more with the adjectives "successful"
and "impressive." If we cannot measure, if we do not have
standards, (both of which are difficulties pointed out by the
authors), how can we say that a program is either success-
ful or impressive? Just as in federal agencies, industrial
programs have as of yet only rarely achieved structural
organizational change, if the literature (or lack of same) is
our source of information. We look in vain for even
anecdotal evidence that shows not only that the compo-
nents are in place, but that the ethic has been integrated
throughout all functions of a company. For example, if the
authors are correct in linking Total Quality Management
and pollution prevention as sharing principles and ap-
proaches, then the conclusion of that linkage should also be
shared: integration of principles accomplished so thor-
oughly that what began as projects and then became a
program has now become simply a part of standard opera-
tional practice. The authors may tacitly acknowledge this
lack of organizational change by omitting praise of indus-
Prepared Discussion
Howard Klee, Jr.
Amoco Corporation,
Chicago, Illinois
These comments were developed as part of an invited
review of "Industrial Pollution Prevention: A Critical
Review," prepared by Harry Freeman of the EPA's Risk
Reduction Engineering Laboratory, presented at the An-
nual A&WMA meeting in Kansas City and appearing in the
May issue of the A&WMA Journal. The comments serve
September 1992 Volume 42, No. 9
trial programs. Good guidance on their part, however,
would bring that lack of change to the fore.
Another 23 papers (approximately 12 percent of the total)
are cited in an effort to describe assessments, an activity
whose objective is to compile information about processes
and wastes in an effort to identify and implement appropri-
ate pollution prevention opportunities. Conclusion #16
states in part:
"It is an apparent general truism that a company's taking the
time to carry out assessments usually identifies opportunities
for reducing wastes and saving money.''
The literature does indeed support this truism. I would,
however, look to the authors for some judgment of whether
this truism is reflective of the actual value of assessments,
as well as some guidance on what the literature lacks.
Several specific examples of unanswered questions come to
mind. Are "outsiders" or "insiders" the better assessors?
How do you choose? How often does assessment lead to
implementation? If assessment is an inventory and analysis
of processes and options, how does assessment examine and
plan for barriers to implementation such as resistance to
change, lack of capital, lack of time, lack of direction?
Pointing out that current assessment procedures and re-
sults are at least unevaluated, if not automatically wanting,
would be more useful than documenting a truism.
Finally, in my opinion, Conclusion #9 has no place in this
Critical Review. It states in part that:
"Achieving zero discharge, at least for hazardous wastes, is
possible in selected industries."
At the core of pollution prevention lies the concept of the
prevention of cross-media transfers. Therefore, a focus on
any one type of discharge or release, such as hazardous
waste, is antithetical to what is being posited in nearly
every other section of the review. Given the authors'
analysis of Life Cycle Assessment, and more than one
instance of suggesting that a more global view of environ-
mental management is desirable, it is at the least confusing
that this conclusion is included. The literature may very
well support this conclusion; however, it is poorly chosen.
To conclude, I found this Critical Review to be an
excellent piece of research. However, I found analysis to be
lacking in two particular regards, which I choose to call
judgment and guidance. I took issue with Conclusions
relating primarily to progress and evaluation, and couched
my disagreement in terms of a desire for more discretion on
the part of the authors. However, I found myself in
agreement with most of the 21 conclusions, and appreciate
the effort required to compile, digest and comment upon the
literature on pollution prevention.
both to offer different views on some literature, and provide
"real-world" examples for a rapidly growingfieldwhich has
been largely driven by hypothetical arguments and assump-
tions in place of data.
Background
Amoco Corporation recently completed a unique, two-
year program in partnership with the United States Envi-
ronmental Protection Agency identifying and analyzing
pollution prevention opportunities at Amoco's Yorktown,
Virginia Refinery.1 This effort involved over 200 people,
from 30 organizations—more than 40 from EPA and the
Commonwealth of Virginia alone. The Project considered
1163
CRITICAL REVIEW DISCUSSION
all releases from the Refinery to the air, water, and land.
The Project then identified over 50 potential options which
might reduce these releases.2
A subset of 12-14 options was developed and analyzed in
detail to define quantitative information about each, in
terms of the potential impact of the option on the quantity
of pollutants released, risk and risk reduction potential,
cost, position on the pollution prevention hierarchy, etc.
Based on this information, the options were ranked, both
from our individual organizational perspectives, and jointly,
to select the "best" ones. Finally, the Project identified why
we were not doing the things identified today: What was
getting in the way?
Needless to say everyone involved learned a great deal
about both the myths and realities of pollution prevention
at a complex industrial facility. Some of the Review's points
and my concerns with them are illustrated by a few of the
many lessons learned during the 2+ years of experience.
Overview
As Harry Freeman and his coauthors so aptly noted, the
literature on pollution prevention has exploded in the last
several years. The written Review provides an excellent
literature survey on the topic. The authors are to be
commended for categorizing such a broad range of refer-
ences, particularly given the unusually short time they had
to complete this effort. The Review itself, however, appears
to be missing the "critical" element noted in the title on
two fronts. First, several important citations are missing,
particularly those with more industrial input. A Review
specifically entitled by its authors "Industrial Pollution
Prevention" might be better co-authored with industrial
representatives. Some missing literature citations include:
1. Material published by the American Institute of Chem-
ical Engineers' second topical review on Pollution
Prevention held in Pittsburgh last fall.3
2. The Amoco/EPA Pollution Prevention Project, which
involved so many EPA offices and produced 50 pounds
(literally) of documentation on a variety of subjects.4
3. Material or reference to recent work by the American
Petroleum Institute, and PERF, the Petroleum Envi-
ronmental Research Foundation.5
Second, there is a lack of criticality in the Review itself. No
attempt was made to distinguish accurate and objective
material from unsubstantiated opinion. Political decisions,
personal opinions, and technical matters are given equal
treatment. This approach may again reflect the relatively
short time given the reviewers to complete such a large
assignment.
Comments
Other comments and observations are provided below,
organized by the conclusion numbers used by the Review
authors.
Definitions. The Review quotes (and I echo) Dr. Larry
Ross' sentiments about discussions of definitions: these are
not very productive discussions. The joint project with EPA
was fortunate enough to have started before the legal
profession turned to this topic. The Project Workgroup,
composed of EPA, Virginia and Amoco representatives,
chose what all of us at the time considered a more results-
oriented definition: preventing releases into the environ-
ment. Unfortunately, these definitional discussions con-
tinue. They appear to be driven by a need to define legally
1164
Howard Klee and Maureen Sullivan
enforceable pollution prevention activities, including not-yet-
defined in-process recycling. Even more unfortunate, these
kinds of definition debates divert substantial limited re-
sources away from more constructive activities.
During the course of the Yorktown study, our EPA/
Amoco Workgroup analyzed and debated how to classify a
number of options. What really was source reduction? What
was recycling? For example, improved seals on gasoline
storage tanks were viewed by some members of the Work-
group as source reduction. The source was the tank, better
seals reduced emissions, QED: source reduction. Others
viewed the contents of the tank as the source; seals are a
control technology. Therefore this was treatment, and
perhaps recycling, since the products remained in the tank.
Counting all the people around the table during these
discussions, literally hundreds of person-hours were spent
in these debates. The discussions neither improved the
efficiency of the tank seals, nor hastened their installation.
Limited Definition = Limited Results
For the Yorktown Project, had we focussed on the narrow
definition of Pollution Prevention as source reduction, we
would have missed more than 60 percent of the opportuni-
ties for environmental improvements. The Project con-
cluded that Pollution Prevention, as narrowly defined, was
simply not good enough to get the environmental results
that responsible corporations, governments and the public
want. On other occasions, the Agency has acknowledged
what we all know: almost any cost-effective environmental
management plan will make use of all parts of the waste
management hierarchy.
Where is Risk?
A difficulty with the present definition, which emphasizes
source reduction as the "highest" form of activity, is that it
can set priorities on the wrong things. When the Work-
group ranked options identified at Yorktown solely on the
basis of their standing in the waste management hierarchy,
they identified the five options in column A below as the
"best" things to do. However, when multiple ranking
criteria were used, which considered the concept of risk and
risk reduction, release reduction, cost, impact on liability,
etc., as factors in prioritizing what we do, a different set of
"best" choices emerged. These are shown in column B,
below.
A: "Best" Source Reduction Options
1. Secondary seals on gasoline storage tanks
2. Leak detection and repair program
3. Eliminate coker pond
4. Reduce soil intrusion into sewer system
5. Improve sampling systems to reduce oil in sewers
J. Air Waste Manage. Assoc.
B: "Best" Options (all criteria)
1. Reduce barge loading emissions
2. Secondary seals on gasoline storage tanks
3. Reduce emissions from process emergency relief
(blowdown) stacks.
4. Leak detection and repair program
It was interesting that in ranking alternatives identified in
the Yorktown study, the Workgroup came to agreement on
what were the four best things to do at this facility. This
held true regardless of prior institutional biases and past
experience. The driving factors that dominated the rank-
ings were risk6 reduction potential, cost, and technical
features of the options. Outside the traditional regulatory
framework, given reasonable people and sufficient factual
information, the ranking process gave clear-cut results.
Perhaps we would be better served in these discussions
by simply remembering that pollution prevention is a
means, not an end. The end or goal is improved environmen-
tal quality.
Effectiveness. The Review's second conclusion highlights
the economic effectiveness of pollution prevention. I would
state this somewhat differently. Pollution prevention op-
tions can be more cost-effective than other pollution man-
agement choices. However, this does not necessarily make
them cost competitive with other corporate activities. At
Yorktown, the source reduction opportunities were gener-
ally more cost-effective than treatment and disposal.
However, most of the projects had rates-of-return well
below zero. Instituting a leak detection and repair program
to reduce fugitive leaks of volatile hydrocarbons from small
flanges, fittings, and pumps was the best option. It had an
estimated 19 percent rate of return. Adding secondary seals
to gasoline storage tanks had a 10 percent rate of return.
Everything else was less, usually much less.
Viewed another way, several projects captured hydrocar-
bons which might otherwise be lost to the atmosphere. If
the hydrocarbons captured were valued as gasoline, the
"cost" of this gasoline (including capital, operating and
maintenance) ranged from about $0.65/gallon to over
$415.00/gallon. Given a current refinery "gate" price for
gasoline of about $0.75/gallon, there was no incentive to
install most of these projects on the basis of product
recovery.
It is certainly a popular myth that pollution prevention
will always pay for itself. While recovering products may
provide more economic value than incinerating them, this
does not necessarily make recovery an economically attrac-
tive activity.
Funding priorities. I agree strongly with Mr. Freeman's
assessment that most EPA funds are still being devoted to
control, rather than prevention. EPA budgeting is sending
mixed signals to industry, Congress and the environmental
community. While there is philosophical interest in preven-
tion, there is apparently little interest in financing research
and activities to encourage it.
Many current and pending regulations send similar
messages. The Clean Air Act Amendments require the
installation of Maximum Available Control Technology for
designated sources. RCRA typically relies on Best Available
Control Technology for managing a hazardous waste. The
Benzene NESHAP regulation7 discourages prevention by
mandating controls even if prevention could eliminate a
source's potential to emit benzene. While recognizing that
some of these programs are required by statute, giving EPA
little flexibility, the command-and-control mindset is diffi-
cult to give up. There are many in industry who find
command-and-control equally appealing. But pollution pre-
vention does not fit a command-and-control framework.
Cost. Conclusion 11 provided a disappointingly brief
discussion about costs. To say there are hidden costs in
environmental accounting was not illuminating. There are
indeed costs that are not yet included in financial decision
September 1992 Volume 42, No. 9
making. One is the impact of facilities (or changes in
facilities) on .future corporate liability. Liabilities in this
context include (a) potential future remediation costs as a
result of spills, (b) potential catastrophic failures, and (c)
potential liability for changes in product quality. These
liabilities are real, as are the ultimate costs for cleanup,
lawsuits, etc. However, at this time industry simply doesn't
have the factual information and analysis techniques to
develop a priori reliable and realistic values for these items,
One point which this Review overlooked was that many
industrial cost accounting systems fail to assign pollution
management costs to the parts of a facility that are
responsible for generating pollution. In many large indus-
trial facilities, pollution management costs are assigned to a
central environmental or waste management division, whose
sole responsibility is to operate waste water treatment
works, incinerators, and landfills. By separating the cost for
management from the source of generation, facilities re-
move a major reward system and tracking mechanism.
When the area responsible for generating a waste has no
accountability for the cost of its management, there is little
incentive to reduce generation.
Barriers and Incentives. Conclusion 14 discussed regula-
tory barriers and incentives. The authors bemoaned the
continued discussion of barriers. It seems fair to say that
until the barriers are removed, people will still insist on
identifying them and possible solutions. The Review discus-
sion, however, missed several key areas that became appar-
ent from the Yorktown Project.
Contrary to the view expressed in this Review, barriers to
implementing pollution prevention are real, not simply
industrial intransigence. These include:
Industrial Barriers
a. Technical Difficulties in developing new processes.
This topic is discussed in much more detail by Profes-
sor David Allen, another participant on the Critical
Review Panel. Dr. Allen is a leader in efforts to provide
improved understanding by, and training for, the
engineering and academic communities who must
teach and develop new viewpoints and processes.
b. Technical difficulties in identifying specific sources of
specific pollutants at complex facilities. At Yorktown,
the Project team spent nearly a year and about
$1,000,000 identifying sources. While similar costs
are not required for every facility, this is a crucial first
step in formulating source reduction plans.
c. Limited time, limited technically trained people and
limited capital. All of us in government and industry
have limited resources available to solve environmen-
tal and other problems. Early environmental legisla-
tion and regulation were successful because the prob-
lems were simple and obvious. Almost any activities
would produce visible, positive results. As our under-
standing improves and we tackle more difficult prob-
lems, the solutions are far less obvious. From permit
writers to process developers, we need to find better
ways to prioritize where these resources are spent.
d. Sunk costs. Once treatment facilities are built, they
generally have long useful lives—20 to 40 years, for
example. Provided these facilities are performing as
needed and have adequate capacity, there is no incen-
tive to abandon them in favor of spending additional
resources on prevention!
At Yorktown, the waste water treatment plant was
working well. Under normal operating conditions, the
discharge to the York River was about one-tenth of
values allowed under it's NPDES permit. Most spe-
cific chemical tests of the effluent were negative: the
materials, if present, were below the detection limits.
The treatment system was not fully loaded, providing
more than enough capacity for the refinery. Thus, the
1165
CRITICAL RB/IEW DISCUSSION
Workgroup had a great deal of trouble devoting re-
sources to preventing material from reaching the
treatment plant, since it was clear adequate treatment
would be provided.
Regulatory Barriers
a. Short compliance time frames favor "quick-fixes"
which meet legal deadlines at the expense of more
comprehensive, long-term solutions. Typical statu-
tory and regulatory compliance deadlines range from
90 days to three years. Yet, a well defined large-scale
industrial project typical of those in the petroleum
industry takes 2-3 years to complete, assuming there
is agreement on what to build, no equipment delivery
problems, no permitting delays, no unusual safety
considerations, and no startup problems. Many projects
take longer, particularly when regulatory and/or de-
sign requirements are unclear, or new (undeveloped)
technology is involved.
b. Overly prescriptive statutory and regulatory language.
The Yorktown study found that this Refinery could
achieve equivalent levels of environmental protection
for 15-25 percent of the cost of current regulatory
requirements. Most current programs mandate (or
imply through Control Technology Guidelines) the
use of specific technology, rather than establishing a
performance standard for an industrial facility. Since
all facilities are not equivalent, this "one-size-fits-all"
approach does not allow a facility to develop a solution
tailored to the unique process and geophysical charac-
teristics of their site.
At the present time EPA does not have a policy goal,
and may not have statutory authority to simply set a
release reduction "target" or performance standard,
without prescribing how that standard should be
achieved.
c. Inadequate accounting for both the benefits and costs
of environmental regulations is an obstacle to develop-
ing more efficient environmental management prac-
tices. Few EPA accounting systems measure direct
benefits of the Agency's activities, such as improved
ecological health, biodiversity, reduced risk to human
populations, etc. Rather, accomplishments are usually
measured in terms of activities, such as number of
permits written, amount of fines collected, or number
of enforcement action pursued.8 The lack of direct
connection between Agency activities and environmen-
tal results reduces accountability for program costs
and benefits. Without adequate measurement sys-
tems, it is difficult to tell when environmental manage-
ment practices actually improve the environment.
d. No release banking system is available to encourage
early reductions. Many regulatory programs mandate
specific emission reductions compared to a "base"
1166
year. For example, the voluntary 33/50 program
instituted by EPA Administrator Reilly uses 1988 as a
base year for evaluating emission reductions of 17
chemicals. The Clean Air Act Amendments Early
Reduction Program uses 1987 as a base year. Preven-
tion of Significant Deterioration (PSD) review for air
permits starts with emissions present in 1977. Still
other programs use different base years.
Reducing emissions before required reduces a com-
pany's baseline emissions and makes achieving future
regulatory requirements more difficult and costly,
because the most cost-effective reductions would have
already been made. Those companies that have made
minimal emission reductions are indirectly rewarded
because when required to reduce, they can do so more
economically than a "more progressive" company
that has already made substantial reductions. While
emissions banking has been discussed for years,9 and
used with success in some programs such as the
phaseout of lead from gasoline, no acceptable solution
has been developed for airborne hydrocarbons, and
many other pollutants.
References/Endnotes
1. "Project Workplan," prepared by H. Klee, Jr. (Amoco) and M.
Podar (USEPA), for the Amoco/USEPA Pollution Prevention
Project, Chicago, October 1990.
2. "Pollution Prevention Workshop," prepared by H. Klee, Jr. and
SAIC for the Amoco/USEPA Pollution Prevention Project,
Chicago, 1991.
3. "2nd Topical Conference on Pollution Prevention," sponsored
by the American Institute of Chemical Engineers and the
Center for Waste Reduction Technology, Pittsburgh, PA, Sep-
tember 1991. Papers were published by the Center and are
available through the AIChE national office in New York.
4. "Executive Summary," prepared by H. Klee, Jr. and M. Podar,
for the Amoco/USEPA Pollution Prevention Project, Chicago,
1992. All documentation for the Amoco/USEPA Pollution
Prevention Project is currently available at copying cost from
Ms. B. Bush at the Health and Environmental Division, Ameri-
can Petroleum Institute in Washington, D.C. EPA will be
distributing this material through the National Technical Infor-
mation Service (NTIS). As of this writing, NTIS numbers have
not been assigned.
5. Some PERF projects are paid for and undertaken by a specific
set of industrial clients. Results may not be publicly available
without charge.
6. For other discussions of risk in environmental decision making
see "Reducing Risk: Setting Priorities and Strategies for Envi-
ronmental Protection," Science Advisory Board, United States
Environmental Protection Agency, Washington, D.C, 1990.
Also, "The Report of the Strategic Subcommittee, Relative Risk
Reduction Project, Reducing Risk, Appendix C," (EPA-SAB-EC-
90-021C) United States Environmental Protection Agency,
Washington, D.C, 1990.
7. "Benzene Waste Operations NESHAP," Federal Register 55:
8292, March 7,1990.
8. "Environmental Protection: Meeting Public Expectations with
Limited Resources," General Accounting Office, (GAO/RCED-
91-97), Washington, D.C, June 1991, Chapter 3.
9. Liroff, L. A. Reforming Air Pollution Regulation: the Toil and
Trouble ofEPA's Bubble, The Conservation Foundation, Wash-
ington, D.C, 1986.
J. Air Waste Manage. Assoc.
Prepared Discussion
W. B. Beck
Pilko & Associates
Houston, Texas
As a discussant, I would like to comment on several specific
aspects of this review and offer some alternative perspec-
tives. This is an effort to present some points in a new light
and by no means intended to negate what has been
presented.
Industrial pollution prevention is probably as old as the
industrial revolution itself, if not older. I know from
personal experience that it is at least fifty years old.
However, industry has not always called it pollution preven-
tion. To industry, making their processes and operations
more efficient, increasing yields and cost reduction pro-
grams were a necessary part of staying competitive. Indus-
try has not practiced it for the primary purpose of protect-
ing human health and the environment. Nevertheless,
industry worked to make its processes and factories more
efficient and this has indirectly reduced waste.
What society is asking industry to do now is pay more
attention to the last few percent of waste, particularly to
toxic waste. Certainly that is not too much to request.
Industry should and must.
But it must also juggle pollution prevention with a
number of other societal demands. Added to this are the
ever-increasing economic burdens and what you have is a
floundering industry. Certainly industry should meet its'
responsibilities but it needs help to do so. Help must come
from the society it serves, if it has any hope of getting the
job done and surviving in the global economy.
Although industry has been working on reducing wastes,
they unfortunately have no reliable measure or chart of
progress over the past two or three decades with respect to
pollution reduction. Nor do we have an idea of whether this
was accomplished through process change or mere end-of-
the-pipe treatment.
This critical review entitled, Industrial Pollution Preven-
tion, interestingly is broken down roughly into one third
concerning EPA program descriptions. Ordinarily this would
be considered as selfserving, but because pollution preven-
tion is so inexorably tied into other EPA programs, the
agency and its policies dominate this activity, and therefore
where its going and what it will allow in its regulations is
critially important. That being said, this review fails to
really critique the EPA regulatory efforts to encourage
industry to practice pollution prevention.
The second-third describes industrial programs, largely
big industry, plants and factories. Leaving one third of the
article to cover miscellaneous topics such as product stew-
ardship, Life Cycle Analysis, and Education.
In reviewing this document there are several areas I
would like to focus on for expansion and to offer a fresh
perspective:
• The roles of EPA and the federal government in pollu-
tion prevention.
• Measurements
• Toxic Use Reduction Program
• Education
Role of EPA
The EPA's classic role is to protect the environment—
and its classic approach has been to control the discharge
and release of pollutants.
It has been an end-of-the-pipe, command and control
approach, and the agency and has done so by focusing on
media-specific strategies. This double problem, the wrong
September 1992 Volume 42, No. 9
focus, and failure to overhaul the media-specific approach
will severely inhibit industry's pollution prevention efforts
for years to come.
While it has made serious strides to change this through
its pollution prevention office, and with the pollution
prevention legislation, and its research and development
activities, I think it is still very far from reaching its
potential. The Clean Air Act amendments, and beyond
these, the upcoming RCRA revisions, will be the acid test of
EPA's real commitment to pollution prevention.
However, there are already some disturbing signs:
Clean Air Act. EPA, in the Clean Air Act, is between a
rock and a hard place. The pressure to get out certain parts
of the regulations has not allowed the Agency to really build
in accommodations and encouragement for pollution preven-
tion, or the support for source reduction via new technol-
ogy. In retrospect, the agency should have tried to convince
congress and the many lobby groups that influence con-
gress that any new environmental legislation must be
couched to include an all-media approach to whatever
problem the legislation is trying to address. This wasn't
done and now we have a very narrow media-specific CAA
amendment package that pays lip service to pollution
prevention but really does nothing to aggressively support
it. In fact, the amendment and the evolving regulations and
guidance to the states actually create effective barriers to
pollution prevention.
For example, the initial draft HON for hazardous air
pollutants for the Synthetic Organic Chemical Manufac-
tures Industry sector in its 821 pages is basically a prescrip-
tion for a 98 percent end-of-the-pipe "control by flare"
approach. Yet, innovative approaches involving the use of
end-of-the-pipe scrubbers and condensers to return or
recover VOC's, or the Biofiltration technology to destroy
VOCs if not 98 percent effective—and with excellent up
time reliability, probably will not be allowed.
More critically, process change that attempts to increase
product yield, and that might in turn reduce both air
emissions as well as solids, tars, or other residual hazardous
waste and waste waters will probably not be allowed
because they cannot match end-of-the-pipe abatement.
From reading this draft I cannot expect industry will be
given any time on credit for attempting other process
modifications.
Technology changes are by this nature highly individual
and very situation specific. They must be evaluated on such
a basis. This requires considerable experience, judgment
and latitude on the part of the permitting agency. More-
over, if cross media benefits are involved, there is no
guidance on how to judge or value such bandits from a total
environmental pollution prevention stand point. This is far
beyond the scope of the CAAA of 1990. Also no allowance
has been made to encourage this kind of thinking. EPA is
missing a golden opportunity to really aid pollution preven-
tion. The recently issued Part 70, or Title 5, basically a
guidance to the EPA and state permit writers, doesn't even
mention pollution prevention as an element to look for in
the new operating permit program.
EPA's 33/50 Program
This voluntary industrial initiative has been held up as a
model of what can be done, given the proper encourage-
ment. There is no question that the 33/50 program will
result in reduced pollution—significant reductions. How-
ever, given the tight timetable for these reductions, indus-
try has relied on end-of-the-pipe abatement or ingredient
switching rather than technology development to accom-
plish the major part of these. Here again the rush to do
something to be counted as a good company and the lack of
really understanding industry's situation has resulted in a
missed opportunity or at best a reduced success.
1167
 Turning Now to RCRA
EPA's next big test will be RCRA reauthorization or
whatever form it takes. Again—it is largely a congressional
issue, with a lot of conflicting lobbies that will influence
congress. EPA could take a strong stance on the side of
pollution prevention by encouraging recycling/recovery,
process changes, etc., but it will take working closer with
industry to understand all of the processes and the various
options that will provide a win-win situation for all parties.
Measurements
It has been said that if source reduction is the heart of
pollution prevention, then measurement is the key to
source reduction. It's very important, and so measurement
of pollution prevention progress deserves more discussion
in this review. It is pivotal to the congressional perception
and to societal concerns. Of course both of these are major
influences on legislation.
Instead of focusing on the problems and doubts cast on
the existing data, the review should have cited more
positive programs and successes. For example, the TRI, for
all its problems is probably directionally correct in showing
a strong downward trend. A number of individual compa-
nies, trade associations, media and others have accumu-
lated data to support this. Perhaps the earliest and longest
effort in this regard is the CMA's annual waste survey. This
data base has ten years of consistent data from the chemical
industry.
As the GAO pointed out in its recent review of EPA's data
management activities, the agency has yet to develop the
definitions, systems and methodology to cope with the
dynamics of industry, products and other activities. Per-
haps the EPA needs to pay closer attention to efforts such
as were described by McCartney and Holland in their paper
on Dupont's waste reduction program, covered in the
Journal's series on this subject. It's a good system that has
demonstrated it can work. Polaroid, Northrup, General
Dynamics and others have comparable systems. There
needs to be more national consensus around a single system
or at least fewer competing systems that are designed to
track waste first-—and serve as a tool for enforcement
second. The AIChE, Air & Waste Management Association,
and ASME with EPA might form a task force to come up
with such a system.
Invited Comments
Lawrence L Ross
AIChE, Center for Waste Reduction Technologies
New York, New York
Let me begin by commending the authors for this most
timely undertaking. For one who has had to keep abreast of
the fast changing landscape of pollution prevention, this
review represents a much needed distillation and interpre-
tation of the growing literature of the field. It should
provide an excellent base for future debates and targeted
studies.
1168
Education
How do we change our attitudes about pollution, about
waste, about resources and throw-a-ways? While the review
covers many of the programs now in existence, and that are
being started up, it does not stress enough how critically
important the general education of the public is to pollution
prevention. Better still, respect for the environment needs
to become an integral part of our curriculum, from pre-
school through college and integrated into all the core
courses.
Summary
Pollution prevention has been practiced by industry for
many decades, and for many reasons. While it's generally
been able to remain competitive, these efforts have not been
optimized to protect the environment or, in general, to meet
all of the demands of society, which are themselves chang-
ing. Overall, industry is probably 95 percent efficient. What
is needed now is for industry to push this few remaining
percent toward zero. This can be accomplished by a number
of options. Each of these have pluses and minuses:
1. By Law; no more wastes, and there are some who
believe this is the only way.
2. By Taxes; pricing wastes so high as to force their
reduction. This could only be doiie under some sort of
international agreement such as the Montreal accords.
3. By creating a combination of incentives and circum-
stances to encourage a higher level of innovation and
discovery around process efficiency than exists today.
And by being patient to accept the reality that such
deep cultural changes will take a generation or two.
I subscribe to this last option. Government, society, and
industry need to work together to make this concept of
pollution prevention really work. Adversarial approaches
have not worked; they delay progress and only favor the
lawyers. We must accept one another as partners, each with
some good ideas and a genuine interest in succeeding.
Government needs to rethink its role and relationship
with industry in the area of new technology development, in
energy development and options and in general resources
uses. The European and Japanese approach might serve as
a model. Closer to home, the recent cooperative spirit of the
government and the auto industry to develop electric car
technology could certainly provide some useful ideas. Pollu-
tion prevention needs to be given its rightful role at the top
of the hierarchy in regulation development just as it now is
in the waste management field. >
Any review—and this one is no exception even allowing
for the generous space allocated—cannot take a field as
wide and controversial as pollution prevention and satisfy
every reader's interests or biases. And so, I would like to
touch on two important issues alluded to indirectly, which I
feel are crucial to pollution prevention needs, identified in
this article. In fairness to the authors, my comments may
well be outside the purview of the article's objectives.
However, I believe that it provides a wider perspective to
the important needs more narrowly addressed.
It's one thing to zero in on such obvious "slam dunk"
targets as legislative and regulatory barriers to the imple-
mentation of innovative environmental solutions. It's quite
another to dig deeper and get at the underlying causes of
these barriers. The causes—everyone knows them, but
J. Air Waste Manage. Assoc.
rarely addresses them head on—are our nation's adversar-
ial mindset, and our difficulty in developing and implement-
ing a long-term technology strategy. Given the elusive
nature of causes, effects, and cures for many environmental
problems, it is not surprising that we created a combative
climate in which it's difficult for industry, government and
the public to talk with each other, much less lay a founda-
tion for mutually beneficial regulations and innovative
technologies. Given our failure in overcoming these barri-
ers during previous periods of intense public concern over
treatment and disposal, and cleanup and remediation, why
would we expect a different attitude now that concerns have
turned to clean production and manufacturing? And, why—
beyond our often-mentioned love of litigation—does this
dilemma seem to be a peculiarly American one?
Some answers to these questions can be gleaned from
recently published analyses of U.S. competitiveness. Of
these, I believe Lester Thurow's publication Head to Head
is singularly on the mark in confronting the hard choices
that will need to be made. Although his main thesis does not
specifically address environmental competitiveness, many
of the compelling arguments, I believe, can be directly
transferred to this setting—^which is what I propose to do.
Thurow states, "In the twenty-first century, sustainable
competitive advantage will come much more out of new
process technology and much less out of new product
technologies (i.e., inventing new products). Reverse engi-
neering has become an art form. New products can be easily
reproduced. What used to be primary (inventing new
products) becomes secondary, and what used to be second-
ary (inventing and perfecting new processes) becomes
primary." Given increasingly demanding standards of
environmental improvement, there is a recognition that
Invited Comments
Arthur H. Purcell
Preventive Environmental Management Services
Resource Policy Institute
Los Angeles, California
Freeman and colleagues have put together a useful snap-
shot of a rapidly changing picture. I am reminded of the
characterization made by a colonel I met many summers
ago, when serving as an intern with the old Army Environ-
mental Office. He likened keeping up with environmental
regulations and trends to "painting a moving train." The
authors have done a credible job of train painting; it is,
however, important, to bear in mind that the field of
pollution prevention (P2)—or waste minimization or clean
technology or whatever it may be called—is evolving, and
growing, daily.
As this change occurs, it is becoming increasingly clear
that P2 programs must be developed in the larger context of
overall resource stewardship objectives. The authors cor-
rectly note in this regard the importance of improved
understanding of Lifecycle Analysis (LCA) as a means of
gaging the long-term implications of P2 activities. This is
one important component of the overall need for programs
which assess the synergies between pollution prevention
activities and other environmental and resource efforts.
Synergies between P2 and energy use are illustrative
September 1992 Volume 42, No. 9
these new processes must not only be cost-effective and
reliable, but they must also be clean.
Achieving and maintaining a sustainable competitive
advantage, therefore, will require the continuous applica-
tion of new and improved technologies to reduce environ-
mental damage fast enough to outpace production in-
creases. This is at the heart of a long-term competitive
strategy. To realize this goal will require a major transfor-
mation, with:
• Environmental factors being incorporated into design at
the earliest stage
• Environmentally compatible design becoming a perma-
nent feature of industrial practice
• The next and future generations of scientists and engi-
neers being' 'pollution prevention professionals.''
A key to achieving these long-term goals is cooperation
between industry and government. Although there are
many such partnerships in place or under development—
the AIChE's Center for Waste Reduction Technologies
being one—their ultimate success will be dictated not so
much by the quality of the individual players but by the
commitment of their stakeholders to a change in the
industrial culture of revolutionary proportions.
This commitment is not for the faint-hearted. It will be
costly, and require high investment and sacrifice. And it
will only be achieved by a radical transformation in U.S.
industrial policy away from short-term profit maximization
to one based on long-term market expansion (or what
Thurow calls "strategic conquest"). To quote Thurow,
America will "have to shift from being a high-consumption,
low-investment society in the 1980s to being a high-
investment, lower-consumption society in the 1990s. From
being present-oriented, it will have to become future-
oriented." .
examples. Conventional wisdom dictates that P2 and en-
ergy conservation go hand in hand. Yet this is not necessar-
ily the case. Cutting back energy use in buildings, e.g.,
without redesign of ventilation systems, will lead to signifi-
cant decreases in indoor environmental quality. Making a
more durable product may mean less pollution in the longer
term but more in the shorter term. P2 programs entailing
synergistic research, however, are few. And until we better
understand synergies, we will have to put qualifiers on
claims for overall success of P2 programs.
Education and training represent particularly fast mov-
ing P2 trains. Five years ago the head of what has become a
recognized higher education center for P2 research confided
that "waste minimization has no place in a university
curriculum." Just as this individual has had a change of
heart about the academic acceptability of a subject as
interdisciplinary as P2, the education establishment as a
whole—K-12, undergraduate, graduate, and post-doctoral—
has begun serious rethinking of traditional education pro-
grams related to environmental training and management.
The authors note that, at the university level, P2 "tends to
be taught as a specialized (course)," is "rare in the social
sciences and liberal arts," and "most pollution prevention
curriculum development is being done by individuals or
small groups, in isolation. . ." This situation must clearly
be improved if P2 programs of the future are to be
developed and run by adequately trained personnel.
Just as the P2 train finds itself moving rapidly through
our educational system, it is causing much activity at the
public policy level. As the authors indicate, laws on a
1169
number of government levels, in the U.S. and abroad, are
aimed at promoting P2. When the Resource Conservation
and Recovery Act was signed into law in the U.S. a decade
and a half ago, some very strong P2 language was inserted.
Section 8002 charged the mandated Resource Conservation
Committee with conducting "a full and complete investiga-
tion and study of... the appropriateness and feasibility of
restricting manufacture or use of categories of consumer
products as a resource conservation strategy." While no one
wanted to touch that provision at the time of enactment, it
is instructive to note that in the future the study, at least, of
this kind of P2 strategy, will likely be part of most P2
program formulation.
Invited Comments
Joel S. Hirschhorn
Hirschhorn & Associates, Inc.
Lanham, Maryland
The critical review on industrial pollution prevention may
seriously mislead and misinform many people. Sadly, the
EPA authors seemed intent on portraying EPA and the
Bush Administration as being leaders in pollution preven-
tion. This is simply incorrect, especially if one pays atten-
tion to the behavior of the Office of Management and
Budget and the Vice President's Council on Competitive-
ness. All of the authors, of course, are from EPA's Office of
Research and Development which is somewhat remote
from the main policy and program offices. Still, the evident
hubris of the authors is disturbing.
Here is some correct history. The first significant U.S.
government action to use a preventive strategy was in the
1984 Hazardous and Solid Waste Amendments, and this
resulted from Senate reaction to the 1983 Congressional
Office of Technology Assessment report "Technologies and
Management Strategies for Hazardous Waste Control"
which stressed industrial waste reduction over waste treat-
ment and disposal. Other efforts, including OTA's 1986
report "Serious Reduction of Hazardous Waste" and the
pioneering work of people receiving no credit in the review
(including Roger Schecter, Don Huisingh, and David Roe)
resulted in several pieces of pollution prevention legislation
in Congress which ultimately resulted in the Pollution
Prevention Act of 1990.
EPA opposed the legislation, and for several years prior
to passage Congress forced money on EPA for pollution
prevention activities. No accurate account of events in the
1980s would conclude that EPA showed leadership or
initiative in pollution prevention. Even its much publicized
33/50 program does not actually require pollution preven-
tion actions, although it is an excellent program. What is
sorely needed is a clear national environmental strategy
based on pollution prevention, such as the Dutch govern-
ment has done, and explicit ways to provide industry with
greater flexibility in spending limited resources on preven-
tion rather than traditional end-of-pipe compliance.
As to the discussion of different terms and definitions,
readers are strongly advised to read a May 1992 EPA
directive by Deputy Administrator Habicht which finally
removes much of the confusion created by various EPA
statements, and brings EPA into compliance with the
Pollution Prevention Act of 1990.
1170
The P2 train is moving rapidly toward the household
level, as is evident from the surge in efforts to control and
reduce household hazardous wastes. Management of these
wastes has, in fact, become one of the biggest environmen-
tal management growth areas. It is essential to emphasize,
in any analysis of P2 programs, that the degree of control
exercised over hazardous components of household waste—
the very visible tip of the iceberg of resource consumptio-
n—is strongly indicative of the overall success of industrial
P2 programs. Reduction and elimination at the production
level must translate directly into reduction and elimination
at the household level.
Equally disturbing is the review's lack of recognition of
the full scope of innovative industrial activities. The review
did not get to industrial programs until the fifth section,
and then only for three pages. A good example of the
review's undercoverage pertains to the enormously impor-
tant issue of measurement of waste reduction progress with
comprehensive data. The one American company that
showed incredible initiative is Polaroid; it created the first
truly comprehensive corporate measurement system and
yet the review has no citation to any of the publications by
Harry Fatkin and his colleagues.
Another example of pollution prevention related indus-
trial innovation is the Warner-Lambert Company's major
investment in agriculturally derived, biodegradable materi-
als which offer environmental lifecycle advantages com-
pared to plastics and paper. In fact, several other companies
are also leading a major materials revolution. The review
provided little attention to the application of pollution
prevention to municipal solid waste issues.
Nor did the review give adequate credit to the many
states (including Massachusetts, North Carolina, Minne-
sota, and Illinois) that forced early attention to industrial
waste reduction, while EPA did nothing. These and other
states pioneered with conferences and awards for industry,
and then passed state laws for planning and reporting. In
regard to the latter, however, the review missed a major
opportunity to address a most serious issue confronting
American industry.
State and federal reporting and planning requirements
have become so burdensome and costly that they are now
diverting resources from actually carrying out pollution
prevention projects. Planning and reporting has become a
punishment for all industry, as if no one in industry can and
will do the right thing. Nor has EPA effectively addressed
the technical difficulties that many companies encounter in
relating waste generation (or chemical usage) to production
data, which is nearly always required.
A most interesting omission by the review is the lack of
reference to papers by this author which presented a useful
framework for understanding the non-linear character of
industrial pollution prevention. The four stage framework
aids understanding of the increasingly complex and stub-
born obstacles facing industrial waste reduction. The re-
view also missed an opportunity to present an overall
framework (which this author has published) for under-
standing the full range of pollution prevention activities,
from toxics use reduction and resource conservation for
inputs, through source and waste reduction within sys-
tems, to redesigning, reformulating, and repackaging prod-
uct outputs. Oddly, discussions on clean technologies,
toxics use reduction, and product design seem to have a
J. Air Waste Manage. Assoc.
random distribution within the review. Nor did the review
adequately demonstrate the applicability of pollution preven-
tion principles to the full scope of local and global environ-
mental problems.
The discussion of economic analysis missed the major
point that it is nearly impossible to find companies that
have established systems which explicitly account for a host
of more indirect economic benefits (e.g., reduced long term
liabilities, improved valuation of common stock, improved
retention and recruitment of professionals, improved cus-
tomer relations, etc). In fact, industrial pollution preven-
tion has already reached a level of stagnation (now that all
the sludge dewatering and simple housekeeping actions
have been taken), because capital intensive projects are not
being fully implemented in our present depressed economy.
Inadequate economic analysis is a major explanation.
Interestingly, the review offers no significant discussion
Closing Remarks
Harry Freeman
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, Ohio
My colleagues and I appreciated A&WMA's inviting us to
prepare the review article on industrial pollution preven-
tion, and we are continuing to enjoy hearing from those
around the country to whom we sent copies of the article.
The comments contained in this issue of the journal were
prepared by individuals invited by the Critical Review
Committee to review the article. We would like to thank
those individuals, with one notable exception, for taking the
time to review our article and for preparing their com-
ments. It is through such a process that we all advance our
understanding of the topic in question. Some responses to
the points raised by our reviewers follow.
Allen effectively highlights the fact that after all or most
of the P2 benefits of modifying operating practices and
modifying current processes have been obtained there will
be a need for a third generation of pollution prevention
technologies to be developed. We certainly agree with this
statement and would favor the providing of support for
programs that will contribute to reducing the technological
roadblocks that inhibit the development of the newer
processes. We found Allen's comments about the P2 mea-
surements question very useful in focusing the importance
of the question. His well spoken support of the concept of
developing a pollution prevention specialist similar to an
industrial safety specialist is somewhat of a minority
opinion in the discussion of how do we best incorporate P2
into the industrial scene. While we are not in complete
agreement with this position, we are sure that we could
agree with Dr. Allen on most of the points about the
importance of P2 education.
Even though Foecke and Klee were somewhat critical in
their comments, it is hard for us to take much umbrage
over their comments since we were flattered that they
would take the time to read our paper in such detail to
develop such detailed observations. Some comments about
those observations follow. Foecke questions our conclusion
that the federal government is promoting pollution preven-
tion and suggests that maybe because we are too close to the
September 1992 Volume 42, No. 9
of the relationship between pollution prevention and Total
Quality Management programs in industry. Nor does it give
credit to the U.S. Agency for International Development
which has begun to give very serious attention to bringing
pollution prevention to developing countries. Moreover,
there is a major opportunity for American industries to
export pollution prevention technologies, products, and
services. The review's description of DOE's pollution preven-
tion activities as "model" is further evidence of the au-
thors' governmental isolation.
To sum up, a critical pollution prevention review by
people actually practicing pollution prevention in industry,
both consultants and industry workers, would have been
very different and more accurate. As to scholarship, while
25 percent of the review's citations are EPA works, a large
number of significant pollution prevention publications
were not cited. Readers beware.
Ronald Berglund and Harry Freeman
issue we may be confusing activity for progress. This could
be, but we would suggest that before making such a
statement that Foecke be clearer on the baseline to which
he is referring. More could always be done regardless of the
issue, and P2 is no exception. However, from where we sit
and from the literature we reviewed, we stand by our
conclusion, especially as it compares to federal government
activities of just five years ago. Foecke's disagreement with
our statement that state P2 programs continue to expand
and provide ideas for encouraging P2 appears to be based
upon his belief that some sort of formal evaluation of the
state programs needs to be carried out before such a
statement can be made. We believe that although there may
very well be a need for such an undertaking, there is
sufficient evidence to support our rather mild conclusion.
Foecke states, "On the matter of local programs, the
literature clearly lags reality." This may very well be true,
but this was a literature review, not a reality review.
Near the end of his review Foecke states that in his
opinion our conclusion, "Achieving zero discharge, at least
for hazardous wastes, is possible in selected industries,"
has no place in the Critical Review. We would disagree.
Eliminating a waste stream is certainly within the spirit of
pollution prevention and more often than not, according to
the literature, such an accomplishment is based primarily
on the incorporation of P2 strategies rather than the cross
media transfer of pollutants. Our not commending such
accomplishments because they do not conform to a purist
definition of pollution prevention seems counterproductive.
We appreciate Foecke's final comment. If such a well
1171
recognized and credible player in the P2 game as Terry
Foecke agrees with most of our conclusions, we must have
done something right.
Klee notes that we missed some relevant pieces of
literature. His point is well taken, certainly in the case of
the AMOCO/EPA P2 Project. We agree that this is a
significant omission, and had we to do it over, we would
highlight this study. As we said in the review, there is a lot
out there and a lot of people are doing a lot of things. We
regret that a few slipped through the crack. Klee also notes
that we tended to give political decisions, personal opinions,
and technical matters equal treatment. This certainly was
not our intention. However, we would say that given the
peculiar nature of the P2 beast, there is a huge overlap
between the aforementioned items.
After reading through Klee's very thorough and percep-
tive observations and comments on the paper, our first
conclusion is that we clearly erred in not inviting him to be
a coauthor. We recommend his review to the reader for it
adds a lot to the whole question of where pollution preven-
tion is going. His discussion of barriers and incentives is
especially insightful.
Klee notes that we did not include under the "Cost"
conclusion that an effective P2 strategy is to allocate the
costs of pollution creation and management to the actual
unit that generates the pollution. We appreciate his point-
ing this out. We have found in various studies supported by
the Agency that such an allocation of costs may very well be
the most effective approach to encouraging industrial pollu-
tion prevention.
Klee's comment, "Perhaps we would be better served in
these discussions by simply remembering that pollution
prevention is a means, not an end. The end goal is improved
environmental quality," is something we all too often
forget.
Beck, as usual, offered perceptive comments reflecting his
long experience as an active participant in developing real
world pollution prevention strategies at DuPont. His high-
lighting the fact that there are some disturbing signs
related to the EPA's implementation of the Clean Air Act
Amendments is a useful reality check to those who believe
that the federal government is indeed 100 percent behind
pollution prevention as the best environmental protection
strategy. His also pointing out that the EPA's 33/50
Program is not completely a pollution prevention initiative,
and that industry will receive credit for end-of-the-pipe
control strategies is also useful to those of us who occasion-
ally tend to overlook this point.
Beck suggested that we should have focused more on the
positive P2 measurement programs and successes rather
than kicking the usefulness of TRI data around so much.
We would have liked to do this, but did not find a lot in the
literature about these successes. Something we learned
from this experience is to expand some of our current P2
measurement research projects at the laboratory to include
documentation of successful measurement projects. Any
assistance that readers of the Journal might be able to
provide by alerting us to relevant literature is appreciated.
He also pointed out that we did riot stress enough how
critically important is the education of the general public to
prevent pollution. So to be responsive to his comment and
to demonstrate our complete agreement with his position,
let us here repeat Beck's statement; "Better still, respect
for the environment needs to become an integral part of our
curriculum, from pre-school through college and integrated
into all the core courses."
Finally, Beck believes that we as a nation would be better
served by a government/industry approach based on the
European or Japanese model for encouraging the adoption
of pollution. Endorsing such a broad proposal is rather
outside the scope of our critical review project. However, we
believe that reflecting on the possibilities of such an organi-
zational model is a useful undertaking for those interested
in dissolving barriers to increased pollution prevention.
The observations of Ross about our nation's adversarial
mindset and our difficulty in developing a long term
technology strategy, and the observations of Purcell about
the difficulty of painting a moving train are useful in
focusing the discussions about how to dissolve barriers to
the implementation of P2 strategies. Both of these comment-
ers provide useful perspectives on pollution prevention in
the U.S.
And then we come to Hirschhorn, whose otherwise
possibly useful comments get lost in his continuing criti-
cism of the U.S. EPA and anyone else who might disagree
with him, or who might not pay homage to his articles as
the seminal works on pollution prevention that he obvi-
ously believes them to be. Such politically-based statements
as those penned by Hirschhorn are inappropriate.
In closing, we would say that the process of preparing the
critical review has certainly been an enjoyable and worth-
while undertaking for us. We realized a real sense of
accomplishment in completing the work within the time
allotted, and we enjoyed very much working with the
A&WMA editorial staff who did an outstanding job. We
hope the Journal readers found our work useful.

Critical Review Subcommittee to Expand

The A&WMA Publications Committee invites nominations for the Critical
Review Subcommittee. This Subcommittee selects the topic for each Annual
Meeting Critical Review, selects the critical reviewers and commenters, provides
peer review for the manuscript, and conducts the Critical Review Session. The
committee meets each year at the Annual Meeting. Please send nominee's name
with a brief resume to the Chairman of the Publications Committee:
Dr. William Pierson
Desert Research Institute
P.O. Box 60220
Reno, NV 89506

1172 J. Air Waste Manage. Assoc.