From: NIKKI ROY (ROY.NIKKI@epamail.epa.gov)
Date: Mon Aug 19 1996 - 10:19:34 CDT
Printreg Listserver Subscribers:
I apologize that the draft ?Study of Industry Motivation for Pollution Prevention? did not come through to you on August
16, as promised. Apparently the size of the 50 page document has created some technical difficulties in
transmission somewhere along the line. In the meanwhile, I am sending you here the draft executive summary. If
you would like us to email or fax you the complete draft document, please DO NOT HIT YOUR REPLY BUTTON, but
instead email us at ?firstname.lastname@example.org? Tell us then also if you would like a copy of the survey
instrument used for this study or a detailed discussion of the methodology.
Also, please note we would need comments by noon September 9 in order to meet our tight production timetable.
If you are having trouble e-mailing us, please call Ohad Jehassi at 202-260-8617
We thank you in advance for your comments, and hope you will find the exercise informative and the effort well
STUDY OF INDUSTRY MOTIVATION FOR POLLUTION PREVENTION
by the Pollution Prevention Policy Staff, U.S. Environmental Protection Agency
This document, ?A Study of Industry Motivation for Pollution Prevention,? reports on a study undertaken by the
Pollution Prevention Policy Staff (PPPS) of the U.S. Environmental Protection Agency (EPA), and co-sponsored by the
U.S. Department of Commerce (DOC), Department of Defense (DOD), and Department of Energy (DOE). There were
three objectives to the study:
(1) To improve the understanding by federal agencies of whether and how environmental issues influence core
business decisions -- particularly involving production process operation -- in order to better understand how
various factors, including public policy, motivate pollution prevention in industry.
(2) To improve the understanding of these factors by others with a professional interest in U.S. environmental
policy -- e.g. those in state and local government, industry, environmental and community groups, labor, and
academia -- as well as by members of the general public with an interest in environmental policy.
(3) To engage in a debate that relies on the best factual information available, while seeking to improve the quality
of that information and its interpretation.
PPPS started its work on this study by spending one year on a prototype study through which it developed a
questionnaire and a basic methodology. PPPS then hired a professional survey company to refine the methodology,
and to anonymously interview over 1000 business people -- 520 randomly-selected lithographic printing companies
(most of which were very small businesses), and 516 production managers randomly-selected to represent the
larger manufacturing companies that report to the federal Toxics Release Inventory (TRI). The research company
also gathered information from EPA data sources about the extent to which each of the surveyed businesses was
affected by the environmental regulatory system. The following findings are based on statistical analyses of those
THE PREVALENCE OF POLLUTION PREVENTION
The survey found that pollution prevention activities are being practiced widely by printers and large
manufacturers; however, we are unsure whether they have become the first resort of these businesses in meeting
their environmental responsibilities. In particular:
68% of printers report implementing pollution prevention activities. Of these:
- 91% modified or substituted chemicals;
- 72% modified image-making or prepress operations;
- 69% implemented good operating practices; and
- 58% modified press operations.
87% of large manufacturers reported implementing pollution prevention activities. Of these: - 95%
implemented good operating practices;
- 93% modified production related processes;
- 91% improved materials handling practices;
- 76% substituted chemicals or raw materials or
modified their product; and
- 64% modified cleaning or degreasing operations.
However, for the large manufacturers reporting to TRI, no association was found between the reporting of
pollution prevention activities and the actual percent of TRI chemical waste reduced (normalized for production), one
quantitative indicator of pollution prevention. The same number of large manufacturers reduced waste (normalized
for production) as increased it.
Most printers and production managers recently having contact with technical assistance programs reported
implementing pollution prevention activities as a result of those contacts. Additionally, for printers, contact with
technical assistance programs was related to increased importance of environmental issues in overall job
responsibilities, as well as increased importance of the cost of input materials and the availability of environmental
technology information. Also, a greater number of production managers contacted by technical assistance
organizations reported that pollution control or compliance costs were a strong influence in their final choice of
equipment and operations.
POLLUTION PREVENTION PLANNING
Almost half the printers and two-thirds of the production managers reported conducting their evaluations of
environmental alternatives as part of government-required pollution prevention plans.
In addition, production managers in Massachusetts and New Jersey -- the states with the most detailed planning
requirements -- answered several questions differently than production managers in similarly-sized firms in the rest
of the country. In particular, MA and NJ respondents from smaller firms were more likely to report that state pollution
prevention planning requirements were very important in first getting them to consider environmental issues in their
TRADITIONAL ENVIRONMENTAL REGULATORY PROGRAMS
While the survey showed that traditional environmental regulatory programs were almost unrivaled in bringing the
attention of business decision makers to their environmental obligations, there may be room to improve the programs?
effectiveness in facilitating business efforts to meet those obligations.
For large manufacturers, contact with enforcement personnel was associated with reduction in TRI waste
normalized for production. Also, the use of certain types of pollution prevention activity by large manufacturers was
associated with the amount of interaction the large manufacturers had with the regulatory system or with technical
Environmental regulatory requirements ranked near the top of issues considered very important by the production
managers in their overall job responsibilities. Environmental regulatory requirements were ranked nearly last on the
list of issues printers considered very important, though very few printers reported considering environmental issues
not at all important.
Environmental enforcement actions were reportedly among the most important factors in getting respondents to
first consider environmental issues in their jobs.
Interaction with the regulatory system was also related to an increase in the reported importance of company
environmental policies and management directives, of pollution control and waste disposal costs, and, for large
manufacturers, of the environmental impacts of their products during use or disposal. Also, government
requirements ranked among the top for production managers and in the middle for printers of strong influences on the
final choice of equipment and operations.
Government publications and assistance providers did not rank high among reported sources of environmental
information about alternative practices or technologies. However, having contact with assistance and enforcement
organizations increased the reported importance of government publications and assistance providers as sources of
Advice from government employees ranked at the bottom of the list of strong influences in the final choice of
equipment and operations. However, interaction with both the regulatory system and technical assistance
organizations increased the reported influence of this advice.
Also, contact with regulatory and assistance personnel increased the reported influence of the compliance costs
on the final selection of equipment or operations.
MOTIVATORS NOT DIRECTLY RELATED TO PUBLIC POLICY
Employee morale and level of productivity, and the sources, quality and cost of raw materials topped the list of
issues that printers and production managers reported as being very important to their job responsibilities. Trends in
customer preferences for the respondent's product was near the top of the rank, though for production managers, it
ranked below environmental regulatory requirements.
The environmental interest of the respondent, family, and friends was ranked with environmental enforcement
actions at the top of the list of factors printers reported as very important for first getting them to consider
environmental issues in their jobs.
Vendors and suppliers were ranked at the top for printers as sources of environmental information about
alternative practices or technologies. Company employees ranked at the top for production managers, well ahead of
vendors and suppliers.
Total Quality Management (TQM) plans and materials or chemical accounting reports were frequently mentioned in
connection with evaluations of alternative practices and technologies, ranking behind only government-required
pollution prevention plans.
Production efficiency and other non-environmental benefits topped the rank of issues reported by printers and
production managers as very important in influencing the final choice of equipment and operations. For printers, the
top rank was shared by availability of information on the particular practices and technologies. Availability of
information was ranked near the top for production managers.
THE RESPONDENTS AND THEIR FIRMS
Of the 520 printers surveyed, 38% were company owners, 19% were presidents, 13% were general managers,
and 13% were operations or production managers. Of the remaining 17%, all seemed to be in core business
functions such as production or sales, and none reported themselves to be environmental specialists of any sort.
28% of the printers reported having 1-2 production employees, 25% had 3-4 production employees, 24% had 5-7
production employees, 12% had 8-19 production employees, and 10% had 20 more production employees on an
average shift. Because an increase in printing company size was associated with an increase in pollution
prevention activities as well as interaction with regulatory and technical assistance programs, some of the observed
associations between printers? responses and interaction with regulatory and assistance programs may be partly a
result of company size.
Of the 516 large manufacturers contacted, 61% of the respondents reported themselves to be productions or
operations managers, 17% had some other position in operations, manufacturing, or engineering, 10% were owners
or top managers, 5% were directors of environmental affairs, and most of the rest were in core business functions
such as quality management or product planning.
23% of the large manufacturers had 1-19 production employees, 28% had 20-40 production employees, 24% had
41-100 production employees, and 25% had 100 or more production employees on an average shift. Most of the
Fortune 100-owned facilities had more than 100 production employees on an average shift.
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