Sustainability Policy and Events, Purpose and Context
The Green Screen for Safer Chemicals, a product of Clean Production Action, is a method of comparative Chemical Hazard Assessment that can be used for identifying chemicals of high concern and safer alternatives. Logo used with permission. See: https://www.greenscreenchemicals.org/
In 1987 while working as an environmental analyst in the Massachusetts budgeting office, I learned about a little program that was focusing on “Source Reduction”,[1] and I went right over to ask if I could work there, because after 17 years of trying to figure out how environmental problems could be most effectively addressed, I felt they had the answer: you address the problem at the source, instead of waiting for problems to arise and then trying to clean them up.
The next year I started working on what grew into one of the world’s first and biggest programs of technical assistance for toxics use reduction (at its height, our office was a little more than thirty employees. If I ran environmental policy, such agencies would have hundreds of staff). I stayed with what became more generally known as pollution prevention for the next twenty-seven years, becoming a true believer in its value, because I saw hundreds of companies find ways to reduce their toxics use and become not only safer, but more economically viable. Nearly all of the companies I worked with had good experiences and came to appreciate how worthwhile it can be to focus on environmental issues as clues to how to improve process and product. They also learned how helpful government can be when it is not just out to punish you: a much needed change in the relationship between government and the regulated community. My experience convinced me that our society can transition to cleaner production without the economic penalty so many expect from environmental initiatives, and without having to use harsh enforcement, except when dealing with the most entrenched laggards. (I also spent a few years as an enforcement attorney, and know that some companies do need punishment, or its threat). Many businesses will utilize a helping hand, and that made me convinced we should have a “two-handed” approach, offering assistance first, and using enforcement as a powerful backup when it doesn’t work. It is not one or the other, but both, appropriately targeted, that can accelerate progress.
Although many millions of pounds of toxics were reduced and companies saved millions of dollars,[2] and the rest of us received reduced toxic pollution and waste, skeptics constantly told me that my story could not be true, because, as one expert put it, company managers are “expert money hunters”, and if there really was a lot of savings in toxics use reduction, they would have found it by now. It is like the joke about an economist not bending down to pick up a twenty dollar bill, because “it couldn’t be there”. I came up with my reply too late after being humiliated by this expert in front of prestigious thinkers at MIT, but perhaps it can still do some good: “They don’t usually hunt in this part of the forest”.
The next year I started working on what grew into one of the world’s first and biggest programs of technical assistance for toxics use reduction (at its height, our office was a little more than thirty employees. If I ran environmental policy, such agencies would have hundreds of staff). I stayed with what became more generally known as pollution prevention for the next twenty-seven years, becoming a true believer in its value, because I saw hundreds of companies find ways to reduce their toxics use and become not only safer, but more economically viable. Nearly all of the companies I worked with had good experiences and came to appreciate how worthwhile it can be to focus on environmental issues as clues to how to improve process and product. They also learned how helpful government can be when it is not just out to punish you: a much needed change in the relationship between government and the regulated community. My experience convinced me that our society can transition to cleaner production without the economic penalty so many expect from environmental initiatives, and without having to use harsh enforcement, except when dealing with the most entrenched laggards. (I also spent a few years as an enforcement attorney, and know that some companies do need punishment, or its threat). Many businesses will utilize a helping hand, and that made me convinced we should have a “two-handed” approach, offering assistance first, and using enforcement as a powerful backup when it doesn’t work. It is not one or the other, but both, appropriately targeted, that can accelerate progress.
Although many millions of pounds of toxics were reduced and companies saved millions of dollars,[2] and the rest of us received reduced toxic pollution and waste, skeptics constantly told me that my story could not be true, because, as one expert put it, company managers are “expert money hunters”, and if there really was a lot of savings in toxics use reduction, they would have found it by now. It is like the joke about an economist not bending down to pick up a twenty dollar bill, because “it couldn’t be there”. I came up with my reply too late after being humiliated by this expert in front of prestigious thinkers at MIT, but perhaps it can still do some good: “They don’t usually hunt in this part of the forest”.
When I would visit companies and ask them questions about whether they had investigated cleaner alternatives, I found they usually had not. I came to understand that many companies operate under tremendous pressure. I, a lifelong environmentalist who started out thinking businesses were simply amoral, developed a deep sympathy for many of them. They come into work and have to get that product out the door. They have to meet payroll. They cannot make any change to process without fearing that what is working will be disrupted. They do not generally have the time or resources to investigate alternatives. Some are indeed amoral and don’t care enough about the impacts they cause. But I found so many that did, but did not have the capacity to act effectively. And when they were caught out by the environmental enforcement agencies, they were often required to install costly treatments that reduced pollution releases but did nothing to change the initial process. Our assistance service helped them look at upfront changes. Instead of continuing to use toxics and then having to do a better job of managing toxic releases and wastes, we helped them evaluate better ways to perform the function that toxics were performing. We helped them think about ways to make their product without having to use them, or if they had to use them, how to use them more efficiently.
My first lesson in how this could really work was with Reliable Electroplating, a small company in Southeastern Massachusetts. I learned they had eliminated use of the solvent TCE (neurotoxic, carcinogenic, a hazardous waste). I asked owner Dale Broadbent if he would explain how he did it, and he was happy to. He told me that he had been buying parts from Asia, because they were so much cheaper, but they came coated in oil to prevent tarnishing, and he had to use the solvent to degrease them. But when Boston University students interning with the source reduction office visited his factory they asked what it cost him to manage and dispose of the TCE waste. He realized from this simple exercise that it was costing him more than he was saving. He started buying his parts from a local supplier, because they would arrive fresh and did not need to be coated in oil. No more TCE use, no more TCE/oil hazardous waste to manage. He was better off and he was helping the local economy. I asked him why he was willing to tell me his story, because the experts had told me that if I did find opportunities (that twenty-dollar bill on the sidewalk that doesn’t exist), companies would not want to share their stories, because they would be competitive advantages. He told me that when a company down the street had had a spill of TCE he got a call from a reporter asking him about his own use of the chemical. He said we are all in the same boat.
During this coronavirus shutdown, when so many production supervisors and designers are at home, we have an opportunity. Although there are many things to attend to, some may now have a little time, and maybe they can use it to rethink how things are done. Environmental issues are signs of inherent inefficiency. Learning about greener alternatives expands your understanding of how to accomplish your mission. Companies that have an environmental impact, if they now have some time, can strategize options for avoiding it at the source. If you use toxic chemical x, take a moment and recognize all the problems that causes for you. It might mean you have to get a permit, and spend time or hire people to do the calculations and submissions, and you have to pay fees and risk fines. It might mean you are spending a lot to properly manage and ship your wastes that are hazardous because toxic chemical x is in it. It might mean you have to have a whole wastewater treatment system, and that you have to have warnings on your product, and train your workers about how to work with the chemical safely, not to mention accidents, cleanups, liabilities, insurance. Most companies I visited had never counted all this up. When I recommended a green substance that did the same as toxic chemical x, they said, yes, but that costs twice as much. But that’s just the upfront purchase cost. All the rest would be gone. If you don’t count all those hidden costs up, you don’t see that the green chemical actually costs less in the end. And the advantages of now having a greener product include opening up opportunities to partner with other companies that are looking to “green” their supply chain, and sell to customers who want safer products. Capturing these opportunities can be far larger than simply reducing costs.
The rethinking shouldn’t just be about looking for a replacement chemical. It’s important to do “functional analysis”. What is the purpose of the toxic chemical? If it’s an acid bath that provides a particular surface, maybe polishing can work. If it’s to etch, maybe you can use a laser to cut. If it’s a toxic glue for fusing, maybe hot melt can make the bond. If you look at that function in the context of the whole production scheme, maybe you don’t need it. One company gave up on a surface treatment after our visit because they realized they were putting on a coating that obviated the need for it. Production changes to specific steps had occurred over the years without anyone taking a holistic view. It took a fresh look by an outsider to see it.
Our ideas didn’t always work, but often they stimulated a self-examination that led to improvements. At one company that made hard plastics, we asked why all the rejected products couldn’t be reground and used as raw materials instead of disposing of them. The company said their grinder couldn’t get them small enough. One of the engineers at our program came up with the idea that cryogenic freezing could work. The company said, oh, but buying a cryogenic system is way too expensive. But they tried cold water, and that worked.
Over time, and encouraged by many successes we had,[3] we applied the lessons to water and energy use. We found opportunities there as well, in nearly all places we looked. The practice of examining options for reducing impacts does not always lead to success. A rough estimate from my quarter century in this field would be that it leads to something a little more than half the time. But that’s a lot, and it could be more if the questioning process became ingrained. For example, the National Pollution Prevention Roundtable awards annual recognition to companies that demonstrate substantial or innovative reductions.[4] One of last year’s winners was Global Foundries of Vermont. This high-tech electronics company has kept the flame of pollution prevention alive. It is a three-time winner of the award, because they have adopted toxics use reduction as an ongoing effort. They have teams working on “continuous improvement”, which is a mantra in many companies applied to production efficiency. When applied to improving environmental performance, it tends to accomplish both production efficiency and safer production.
Many commentators have noticed that the international shutdown has reduced pollution, but have worried about how it will come back when production is resumed. It need not come back as it has been. We can seize the opportunity to rethink and redesign production.
[1] The Office of Safe Waste Management of the Department of Environmental Management, run by Michael Brown and supported by DEM Commissioner James Gutensohn. In 1989 the Massachusetts legislature, informed by the successful demonstration programs of OSWM, established the Office of Technical Assistance as part of the Toxics Use Reduction Act (passed unanimously). OTA has continued to provide onsite assistance to users of toxics since then, though its staffing is much reduced. Onsite or other direct assistance is key to success, as assistance from a distance may not accurately assess the particulars of each situation, and is less likely to create an effective relationship with assistance recipients. (For example, the alternatives assessment assistance that the Toxics Use Reduction Institute can perform, using tools such as the Green Screen, does not require onsite visits, though they can be helpful). By 1990 nearly all states were creating such programs, and the remnants of this effort still find national representation in the National Pollution Prevention Roundtable (https://p2.org/).
[2] Examples: https://www.mass.gov/files/ota_effectiveness_study_final_2006.pdf, https://www.turi.org/Our_Work/Policy/Toxics_Use_Reduction_Act/Program_Assessments
https://www.csu.edu/cerc/researchreports/documents/AnOunceOfPollutionPreventionIsWorth2003.pdf
[3] https://www.mass.gov/business-environmental-achievement-case-studies
[4]https://p2.org/MVP2-Awards
My first lesson in how this could really work was with Reliable Electroplating, a small company in Southeastern Massachusetts. I learned they had eliminated use of the solvent TCE (neurotoxic, carcinogenic, a hazardous waste). I asked owner Dale Broadbent if he would explain how he did it, and he was happy to. He told me that he had been buying parts from Asia, because they were so much cheaper, but they came coated in oil to prevent tarnishing, and he had to use the solvent to degrease them. But when Boston University students interning with the source reduction office visited his factory they asked what it cost him to manage and dispose of the TCE waste. He realized from this simple exercise that it was costing him more than he was saving. He started buying his parts from a local supplier, because they would arrive fresh and did not need to be coated in oil. No more TCE use, no more TCE/oil hazardous waste to manage. He was better off and he was helping the local economy. I asked him why he was willing to tell me his story, because the experts had told me that if I did find opportunities (that twenty-dollar bill on the sidewalk that doesn’t exist), companies would not want to share their stories, because they would be competitive advantages. He told me that when a company down the street had had a spill of TCE he got a call from a reporter asking him about his own use of the chemical. He said we are all in the same boat.
During this coronavirus shutdown, when so many production supervisors and designers are at home, we have an opportunity. Although there are many things to attend to, some may now have a little time, and maybe they can use it to rethink how things are done. Environmental issues are signs of inherent inefficiency. Learning about greener alternatives expands your understanding of how to accomplish your mission. Companies that have an environmental impact, if they now have some time, can strategize options for avoiding it at the source. If you use toxic chemical x, take a moment and recognize all the problems that causes for you. It might mean you have to get a permit, and spend time or hire people to do the calculations and submissions, and you have to pay fees and risk fines. It might mean you are spending a lot to properly manage and ship your wastes that are hazardous because toxic chemical x is in it. It might mean you have to have a whole wastewater treatment system, and that you have to have warnings on your product, and train your workers about how to work with the chemical safely, not to mention accidents, cleanups, liabilities, insurance. Most companies I visited had never counted all this up. When I recommended a green substance that did the same as toxic chemical x, they said, yes, but that costs twice as much. But that’s just the upfront purchase cost. All the rest would be gone. If you don’t count all those hidden costs up, you don’t see that the green chemical actually costs less in the end. And the advantages of now having a greener product include opening up opportunities to partner with other companies that are looking to “green” their supply chain, and sell to customers who want safer products. Capturing these opportunities can be far larger than simply reducing costs.
The rethinking shouldn’t just be about looking for a replacement chemical. It’s important to do “functional analysis”. What is the purpose of the toxic chemical? If it’s an acid bath that provides a particular surface, maybe polishing can work. If it’s to etch, maybe you can use a laser to cut. If it’s a toxic glue for fusing, maybe hot melt can make the bond. If you look at that function in the context of the whole production scheme, maybe you don’t need it. One company gave up on a surface treatment after our visit because they realized they were putting on a coating that obviated the need for it. Production changes to specific steps had occurred over the years without anyone taking a holistic view. It took a fresh look by an outsider to see it.
Our ideas didn’t always work, but often they stimulated a self-examination that led to improvements. At one company that made hard plastics, we asked why all the rejected products couldn’t be reground and used as raw materials instead of disposing of them. The company said their grinder couldn’t get them small enough. One of the engineers at our program came up with the idea that cryogenic freezing could work. The company said, oh, but buying a cryogenic system is way too expensive. But they tried cold water, and that worked.
Over time, and encouraged by many successes we had,[3] we applied the lessons to water and energy use. We found opportunities there as well, in nearly all places we looked. The practice of examining options for reducing impacts does not always lead to success. A rough estimate from my quarter century in this field would be that it leads to something a little more than half the time. But that’s a lot, and it could be more if the questioning process became ingrained. For example, the National Pollution Prevention Roundtable awards annual recognition to companies that demonstrate substantial or innovative reductions.[4] One of last year’s winners was Global Foundries of Vermont. This high-tech electronics company has kept the flame of pollution prevention alive. It is a three-time winner of the award, because they have adopted toxics use reduction as an ongoing effort. They have teams working on “continuous improvement”, which is a mantra in many companies applied to production efficiency. When applied to improving environmental performance, it tends to accomplish both production efficiency and safer production.
Many commentators have noticed that the international shutdown has reduced pollution, but have worried about how it will come back when production is resumed. It need not come back as it has been. We can seize the opportunity to rethink and redesign production.
[1] The Office of Safe Waste Management of the Department of Environmental Management, run by Michael Brown and supported by DEM Commissioner James Gutensohn. In 1989 the Massachusetts legislature, informed by the successful demonstration programs of OSWM, established the Office of Technical Assistance as part of the Toxics Use Reduction Act (passed unanimously). OTA has continued to provide onsite assistance to users of toxics since then, though its staffing is much reduced. Onsite or other direct assistance is key to success, as assistance from a distance may not accurately assess the particulars of each situation, and is less likely to create an effective relationship with assistance recipients. (For example, the alternatives assessment assistance that the Toxics Use Reduction Institute can perform, using tools such as the Green Screen, does not require onsite visits, though they can be helpful). By 1990 nearly all states were creating such programs, and the remnants of this effort still find national representation in the National Pollution Prevention Roundtable (https://p2.org/).
[2] Examples: https://www.mass.gov/files/ota_effectiveness_study_final_2006.pdf, https://www.turi.org/Our_Work/Policy/Toxics_Use_Reduction_Act/Program_Assessments
https://www.csu.edu/cerc/researchreports/documents/AnOunceOfPollutionPreventionIsWorth2003.pdf
[3] https://www.mass.gov/business-environmental-achievement-case-studies
[4]https://p2.org/MVP2-Awards
RSS Feed
