Environmental Protection

Don't Waste Your Waste

Pointers for setting up a solid waste recycling program at your facility

Now that you know the benefits of recycling industrial solid waste after reading the cover story “Renewable Refuse” in our magazine’s May 2007 issue, where do you start? Who should be involved? How do you implement recycling? So many questions… here are a few suggestions on how to effectively implement pollution prevention (P2) in your operations. Start now, make a plan, and make a difference.

The Pollution Prevention Act of 1990 focused industry, government, and public attention on reducing the amount of pollution through cost-effective changes in production, operation, and raw materials use. As a result, many states require documentation of P2 activities by large quantity generators, small quantity generators and/or Toxic Release Inventory (TRI) reporters to develop P2 plans. If you don’t fall into those categories though, don’t be shy. Take the initiative. Take a good, hard look at your business and develop your own P2 plan, step by step. After all, it will save you money and help protect the environment.

Step One: Evaluate Facility Processes
Take a look around and be nosy. Better yet, develop a P2 team and get more people involved. You may even want to bring in a consultant or someone who can offer a “fresh pair of eyes,” but always get your own people involved because without them, your program won’t take off. Sometimes we get caught in the “that’s how it has always been done” mindset and we don’t realize that there may be a better alternative.

Using a systematic approach to evaluate your processes:
• Evaluate what goes on in and out of your facility (e.g. materials, energy, labor).

• How many different processes are there? Develop flow diagrams for each process, including details such as chemicals used, length of process, waste generated, energy consumption, etc. The more you know about your processes, the better you can determine alternatives that may work in those processes.

• Talk with the people who actually do the work. Long time employees may provide valuable insight into why things are done the way they are. Maybe the reasoning for conducting a process a certain way is no longer applicable or technology and/or equipment has changed over the years.

Step Two: Identify and Prioritize Waste Streams
Now that you have clearly demonstrated your facility’s processes with flow diagrams, identify and prioritize the waste streams generated in each of those processes. Be sure to look not only at hazardous wastes, but include air emissions, wastewater discharges, and other solid wastes such as waste streams you currently recycle (i.e. scrap metal, cardboard, plastic, pallets, etc.). There’s always room for source reduction! Prioritizing criteria to consider include volume of waste generated, cost, toxicity, ease of P2 project implementation, etc. When considering cost, be sure to include disposal costs, raw material cost, regulatory fees, and labor dollar estimates in your evaluation. You may be surprised at how much your facility is spending not only to dispose of wastes generated, but on associated permit fees, storage space requirements, containment, training, and reporting. Many of these costs are often overlooked. Also, consider the health impacts of your waste streams. Do employees need to take extra precautions, such as wearing respirators and protective clothing, when handling the materials?

Step Three: Identify and Prioritize P2 Projects
Source reduction and waste minimization are the two main types of projects you will identify in your P2 plan. Source reduction, which is the EPA “preferred” method of pollution prevention, is any practice that “reduces the amount of any hazardous substance, pollutant, or contaminant entering a waste stream or otherwise released to the environmental (including fugitive emissions) prior to recycling, treatment, or disposal.” Examples of source reduction projects include reusing shipping containers, reducing packaging and using nontoxic or less toxic cleaners, inks or paints. Include an evaluation of the technology you use at your facility as well. One facility upgraded its machinery, eliminating their need for methylene chloride to flush the system.

Waste minimization is any practice that “reduces the environmental or health hazards associated with hazardous wastes, pollutants, or contaminants. Examples include reuse, recycling, neutralization, and detoxification.” A review of your process may indicate you can make three widgets out of a piece of plywood instead of two. By being more efficient in your process, less waste plywood is generated. In addition, maybe that waste plywood can be used as a source material for another company. That company may even be willing to buy your waste plywood. You may even make money on your waste, which is now no longer considered a waste. Other common pollution prevention projects include material storage and handling, spill and leak prevention, process and equipment modifications, and inventory control.

Don’t be afraid to “reuse or recycle” ideas. There’s a wealth of information out there on the internet. EPA and many states provide pollution prevention options based on what has worked at various types of facilities and for various types of projects. They are more than willing to share their success stories if it means reducing waste at another facility. Look at what has worked at other facilities with similar processes, but don’t forget to look at other processes and types of facilities as well. You may be able to glean some valuable information from those projects that otherwise you never would have thought of. The proverbial “thinking outside the box” is definitely a benefit in this step. Don’t forget to get ideas from all levels of your company (e.g. secretaries, managers, plant workers, environmental, health and safety staff members). Again, it may be good to get an outside perspective on your operations. Some state regulatory agencies offer this service for free, but if you prefer not to invite a regulator into your facility, you may consider hiring a consultant. The consultant should be able to help you save more money than their fees cost you. However, without internal support, your plan will just collect dust on the shelf.

Once you figure out what your projects are, you need to figure out where you’re going to start. Things to consider when prioritizing projects are:
• Technical feasibility - your team need to evaluate each identified project and select those that can be most easily accomplished. When considering technical feasibility, you may need to consider whether or not the quality of the product is affected by the project, is more labor required to implement the project, and whether or not new and old equipment will work together. Another potential downfall is whether production will shut down during installation/implementation.

• Economical considerations - which project has the most economic benefit to the company? Remember, what appears to be the most economically efficient may in reality cost you more money in the long run. Compare the initial cost of the option (i.e. equipment, loss of production time, etc.) with the potential cost savings of the project. How long does it take to realize the cost savings?

In addition to the feasibility of the options, what are the environmental and human health risks associated with the project? Are you ultimately causing more harm than good? One way to evaluate these risks is to review material safety data sheets (MSDSs) for the materials involved. Will there be any extra precautions your employees will have to take if the project is implemented? Even though the volume of waste generated is less, is it more toxic than before? Last, but not least, are you merely shifting your releases from one media to the other? Are the volatile compounds in your waste now being vented to the atmosphere rather than being disposed in a landfill? All these questions play a part in prioritizing your projects and getting them approved by the decision makers.

Step Four: Set goals
Start with baby steps. Set goals that are measurable and achievable. You may want to start with “low hanging fruit” – projects that are quickly implemented so that you show immediate tangible results to garner more support for your P2 program. Don’t set the bar so high that you’ll get frustrated and quit before you get there. Allow your team members to see they are making a difference with the P2 projects they are implementing. Goals to consider include percent reduction in hazardous waste, tons of chemicals reduced, percent reduction in air emissions, and water savings. This last one is particularly crucial in certain parts of the country that have been experiencing drought conditions over the last several years.

Step Five: Evaluate projects and goals
As you implement your P2 projects, periodically evaluate your progress. Is the implementation going smoothly? Are things working out as you planned? Are the goals being achieved? Pollution prevention is meant to be a dynamic process; nothing is set in stone. If something is not working, or you discover an even better way to improve your process, revise the project as necessary. New technologies may provide the ability to make greater strides in pollution prevention at your facility.

EPA encourages and supports pollution prevention and has several programs in place to assist and recognize those that participate. These include Performance Track, National Partnership for Environmental Priorities (NPEP) and the Resource Conservation Challenge (RCC). By following these general steps, not only are you maintaining compliance with state regulations (be sure to check your state-specific regulations), you’re saving your company money and making it look good in the public eye. So, go ahead -- challenge your company to make a difference.

This article originally appeared in the 07/01/2007 issue of Environmental Protection.

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