=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #112
—January 17, 1989—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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WHAT WE MUST DO–PART 12: INDUSTRIAL POLLUTION PREVENTION.
Everyone agrees that pollution prevention makes more sense than
pollution cleanup or control. If you never make pollution to
begin with, you don’t need an army of scientists and engineers
figuring out what to do about it, you don’t need state and
federal government “protecting” you with their feeble and
bumbling environmental police, you don’t need to spend $80
billion per year (which is what industry and government together
are spending each year now in the U.S.) on “pollution control.”
Industry would have fewer black eyes, the health of the American
people would be improved, the earth would be relieved, and
thousands of Americans now locked in mortal combat with their
neighborhood poisoners could go back to leading normal lives or
could focus on other public problems.
What will it take to make it happen?
There are two different kinds of polluting wastes:
industrial/commercial (the stuff industry throws away or lets
leak out), and trash/garbage (the stuff consumers throw away).
They two types of waste must be considered differently. This week
we’ll focus on industrial wastes.
When speaking about industrial pollution, the term “pollution
prevention” means the same thing as waste reduction, waste
avoidance, or elimination of the generation of pollutants or
wastes. Waste management and pollution control mean recycling,
treating, or neutralizing wastes, or destroying the hazardous
properties of wastes, after they have been generated.
The fundamental basis of every industrial pollution prevention
program will have three parts:
(a) defining exactly what “pollution prevention” means.
Unfortunately, the EPA [U.S. Environmental Protection Agency]
likes to cloud the picture by speaking of “waste minimization.”
Congress’s Office of Technology Assessment, in two reports, has
described the paralyzing confusion caused by EPA’s definition,
and has clarified nicely how “pollution prevention” should be
defined. See RHWN #33.
(b) establishing general, industry-specific and plant-specific
pollution reduction goals;
(c) requiring detailed industrial reporting on pollution
production and releases. Such reporting should include total
pounds, types, and environmental impacts of pollution generated
per unit of finished product. It should report all releases to
air, water and soil. It should also include a discussion of past
performance and future plans. Accurate data reporting could be
assured by holding company executives personally responsible for
the reports, and providing automatic jail sentences for false
reporting. (We use automatic jail sentences for crimes with a
gun, and for selling drugs near schools, in New Jersey right now,
so don’t let anyone tell you such things are untried or are
unconstitutional. They’re in use and they work.)
Those are the fundamental requirements of any industrial
pollution prevention program. There are other policies that could
be used as well:
(1) Waste reduction (pollution prevention) performance standards.
This would say, for example, you’ve got to produce 5% less waste
per unit of production each year, compared to the previous year.
Such a performance standard says what you’ve got to achieve, but
doesn’t say anything about what you must do to achieve it.
(2) There could be fines (and, for repeat offenders, jail terms)
for not meeting the pollution reduction goals established in part
(b) above.
(3) There could be tax concessions offered to industries for
capital equipment, increased labor or material costs, etc. that
might be needed to prevent pollution. Currently, many laws offer
tax concessions and loans for pollution control equipment; such
tax concessions work against pollution prevention but this
situation could be turned around.
(4) Liability insurance could be denied to firms that don’t have
pollution prevention plans that they are adhering to. States
regulate the insurance industry differently, so this idea would
not work in all states today it would in some.
(5) Pollution production could be required as part of normal
financial reporting. Any reasonable investor trying to make an
informed investment decision has a right to pollution production
data because pollution production materially affects a company’s
(a) waste cleanup liability, criminal liability, and involvement
in third-party lawsuits under Superfund; (b) liability associated
with worker exposures and transportation accidents; (c)
regulatory compliance costs.
(6) In a few cases, companies might be offered “regulatory
relief”–delays in enforcement of effluent standards could be
used occasionally to encourage industries to pursue pollution
prevention. Such regulatory relief would be based on
demonstration that the environmental and health benefits of
pollution prevention exceed the benefits foregone by regulatory
delay.
(7) Stricter waste disposal regulations, to increase the cost and
liabilities of pollution, to make the alternative (pollution
prevention) more attractive. To make this work, it would have to
be combined with strong incentives for, and assistance in,
achieving pollution prevention. Simply making waste disposal more
expensive, without offering alternatives, might simply increase
illegal dumping.
(8) Technology transfer programs. State governments can help
industries learn how to prevent pollution. Among other things,
such programs could train and certify “pollution auditors” to
help industry plan and carry out pollution prevention programs.
Such auditors could also (along with the company’s top
executives) certify a company’s compliance with mandatory
pollution prevention regulations.
(9) A combined pollution tax/pollution prevention subsidy could
be established. The idea would be to establish an “acceptable”
level of pollution for companies in a given industry. Companies
producing pollution at that level would not be taxed and would
not be subsidized. Somewhere above the “acceptable” level would
be a “control level.” Companies producing pollution in amounts
between the “acceptable” level and the “control” level would be
taxed at progressively higher rates per unit of pollution as they
got up toward the control level. Pollution above the control
level would be entirely unacceptable and would be subject to
strict enforcement.
Companies producing less pollution than the “acceptable” level
would receive a progressively larger subsidy as their pollution
approached zero. These subsidies would be paid for by taxes
collected from companies polluting above the “acceptable” level.
Smaller firms might be given larger subsidies for a given amount
of pollution prevention because technical information and capital
financing are harder for them to acquire.
These ideas are almost all taken from the excellent report by
Elliott Zimmerman, SOLID WASTE MANAGEMENT ALTERNATIVES: REVIEW OF
POLICY OPTIONS TO ENCOURAGE WASTE REDUCTION. Springfield, IL:
Illinois Department of Energy and Natural Resources [325 West
Adams, Room 300; zip: 62704-1892], Feb., 1988. Available from:
National Technical Information Service, Springfield, VA 22161;
order PB 88-188-560; $15.95. Phone (703) 487-4650.
–Peter Montague, Ph.D.
Descriptor terms: waste reduction; waste avoidance; pollution
prevention; public policy; sensible public policies; regulation;
taxation;