Beyond Command and Control

EPA's National Environmental Performance Track aims to motivate and reward top environmental performers

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"We just started our new wastewater treatment plant," says George. "I think that will drastically reduce our BOD, although this again is an example of our environmental policy. We do not have to treat the water any more than we already do. We can send it to the local POTW and just pay a BOD surcharge, which is what we've done for years. But we're going to meet the goals."

Akzo Nobel Aerospace Coatings' Waukegan plant said it would reduce volatile organic compound (VOC) emissions from wash tanks by 84 percent by cutting the number of solvent-containing parts washers and by using "greener" cleaners. It also committed to decreasing hazardous materials use, overall VOC emissions and electrical energy use.

Balancing the reductions with production increases poses the greatest hurdle, says Akzo Nobel's Flack. "The idea is to continue to increase production, increase efficiencies and try to minimize any additions of emissions, waste ," those key areas that we've worked so hard to try to reduce."

The DuPont Spruance plant pledged to increase the use of recycled Kevlar materials from 0 pounds (lb) per year to 180,000 lb per year by recycling prepolymers generated during process startups and shutdowns. In addition, the facility said it would cut air toxics, hazardous waste and solid waste.

"We're well on our way to meeting our commitments," maintains DuPont's Dunn. "Our annual [carbon disulfide] emissions were 50,000 pounds ," we said we'd take that to zero, and we've done that. We said we'd reduce nonhazardous waste in Kevlar, and we've cut that by over 90 percent already."

Johnson & Johnson's future commitments are based on the joint efforts of all 51 participating facilities. The company said it would reduce carbon dioxide (CO2) emissions by 2 percent by improving management practices and using alternative energy sources. It also committed to further reductions in raw material use, water use and solid waste generation.

"It is a big challenge," emphasizes Johnson & Johnson's Pai. "Because we've achieved so much already under our old goals, now it becomes harder and harder to achieve additional improvements."

And some reductions are more difficult to achieve than others, adds Pai. "For example, CO2 emissions ," that is the biggest challenge we have at the moment because our company is growing rapidly," she stresses. "This is a goal that measures absolute reductions. What we have done is tried to implement the use of more renewable energy ," for example, using solar energy, wind, hydroelectric power."

Reaping benefits

These super-achievers and other Performance Track participants have worked long and hard to achieve environmental excellence. They are quick to point out, however, the program's benefits.

"Performance Track has gotten us a lot of attention from government," says Madison Chemical's George. "One of our senators, Sen. Evan Bayh, dropped by the other day for photo opportunities and to announce some programs he's supporting. The commissioner of the Indiana Department of Environmental Management dropped by because they're very pleased with the way we conduct things. When you take these kinds of persons through the plant, it really makes an impression on the employees."

DuPont's Dunn said his facility also was values the recognition for its achievements. "I put myself in the shoes of the community, and I realized that if we are doing the things we're being recognized for and say we're doing, it's natural that we would be expected to be part of Performance Track," he says.

Johnson & Johnson's Pai sees the program as "that additional push, that incentive" the company needs to meet its next-generation goals. And, again, the formal recognition aspect of the program is a boon.

Program members also benefit from EPA-enabled information sharing, notes Julie K. Spyres, Performance Track's director for program development and member services. EPA holds an event each spring to allow members to share best practices and network. The event can be a golden opportunity for those seeking innovative solutions to persistent problems. In addition, EPA's regions host events in which program participants have "opportunities for a lot more dialogue in lieu of a presentation style," she adds.

What's next?

Performance Track is still a work in progress, and EPA is evaluating additional incentives that might one day benefit program participants. For example, the agency recently proposed one rulemaking that would allow hazardous waste generators within Performance Track to extend hazardous waste storage, and another that would reduce regulatory paperwork for Performance Track facilities.

And soon to be unveiled is a database of leadership practices, or best practices, says Spyres. "All of our members will be highlighted in that database," she says. "It's going to cover a lot of environmental best practices from all over the country that we learn about from different awards programs."

Also in the works is a mentoring program, notes Spyres. "Not only will it be for our existing members to mentor potential members," she explains, "but we're also going to use it as a way to try to link up our membership pool ," so they have a way of asking very specific questions for which they would like us to help find answers."

Moreover, the agency teamed up with the U.S. Occupational Safety and Health Administration (OSHA) to explore opportunities for joint workshops and other activities for facilities that are members of both Performance Track and OSHA's Voluntary Protection Program (VPP). The agencies also are looking into ways to recognize facilities that participate in both programs.

"We really want to use [Performance Track] to improve our ability at a facility and company level to measure environmental performance and to demonstrate that we can go from a very compliance-based approach to a performance-based approach," emphasizes EPA's Fiorino. "At some point, my hope is that we'll really start to build, with legal authority perhaps, some sort of a sharing approach to regulations ," where there are high performers who meet not a different set of performance expectations, but that EPA would sort of oversee and monitor differently, given their track record."

OK, so maybe Performance Track doesn't represent a complete turnaround in EPA's regulatory approach. But at least it's a start.

The next open application period for EPA's National Environmental Performance Track program begins on Feb. 1, 2003. For more information, visit CP


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