Western Regional Pollution Prevention Network
Training Session, October 25, 2000
"Pollution Prevention for CUPAs and Other Regulatory Agencies"

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What do you consider to be your greatest challenge in implementing pollution prevention in a regulatory context?

• education of potential partners*
• regulatory mind set
• education of public; general awareness
• winning over new businesses
• regulatory grey areas
• getting public and management buy-in*
• education of CUPA inspectors*
• existing paperwork is overwhelming*
• finding appealing workshop topics
• inspectors have too much to do*
• large number and diversity of regulated entities*
• networking with a large number of CUPAs
• finding the right person for information at a regulatory agency
• capturing the interest of regulatory staff
• integrating into regulatory planning
• getting P2 recognized as a key component of regulatory programs
• resistance in community college instructors
• getting the word out, getting buy-off*
• changing public behavior
• learning about businesses, industrial processes

* indicates more than one participant cited this as a challenge

Problems, Causes, Solutions: Brainstorm Session

Problem Definition:

1) Old mind set, resistance to change

Perception of P2 as an added cost

2) Availability of technical information

3) Suspicion of regulatory agencies

4) Lack of awareness of P2 resources

5) Resistance to environmentalism

6) Lack of regulatory mandates

Causes:

1) -Early indoctrinations

-Investment of time, money, attitude with delayed payoff

2) -Lack of outreach

-Not user-friendly information

-False claims on solutions

-Too much information --- overwhelming

3) Regulatory agencies wearing 2 hats: "regulator" and "P2 assistance"

5) Resentment/misperception that environment = lost jobs

Political ideology

Solutions:

1) Education of P2 at a younger age.

Work with upper management

Relate to business perception/ work with business instead of force

2) Offer user-friendly information

Multi-media materials (video, brochures, etc.)

Make materials easier to locate

Cooperation among agencies

Agency newsletters --- share with businesses

Work with trade associations

3) Consultations

Workshops for businesses

Regulators partner with neutral organizations to offer P2 info

6) Approach from economic point of view rather than environmentalist’s point of view

Relate to public health

7) Legislation to require training employees in P2

P2 training for inspectors/cooperation between agencies

Summary of Problem:

• Communication amongst ourselves and with businesses
• Unclear message: define our objective/duties/P2 message

Summary of Causes/Solutions

1. Unclear objectives
2. Lack of motivation
3. No measurement
4. Need better monitoring/communication
5. Top-down philosophy

Problem Definition:

1) Marketing the idea to the business sector --- communication

Start with Mom and Pop businesses, then move to the bigger businesses.

2) CUPAs, regulatory agencies:

Duties, scope of regulatory areas unclear

No consistent communication within and among regulatory agencies or between regulatory agencies and businesses. Mixed messages.

3) Goal unclear.

Causes/Potential Solutions:

1. Unclear objectives
2. Lack of communication and training
3. Lake of motivation, incentives (reduced permit fees, rebates: what’s in it for me?), funding for regulators and businesses
4. Unmeasurable positive results
5. Marketing problem: advertising the idea; word of mouth
6. Customer service: outreach to businesses, pamphlets, websites, referrals, resources
7. Frequent/return inspections due to non-compliance; do no-fault inspections as a time-savings
8. Fear of regulatory agencies, changing mind set; move from reactive to proactive; results from proper communication.
9. Train environmental health directors on P2; top-down; speak at annual conference of environmental health directors
10. Understand cultural differences of inspectors and businesses
11. Raise the standard of compliance, expectation from the business; get their commitment and their feedback
12. Develop a task force of regulatory agencies, i.e., teamwork, joint inspections, partnerships.

Topic: Coordination

Problem:

One main goal for all agencies:

• communication
• effective use of resources
• priorities (solid waste vs. hazardous waste)
• common link between agencies
• selling pollution prevention

Causes:

• Funding and time issues
• No link between agencies
• No common vision
• Lack of multimedia networking
• Lack of cross-training
• Territoriality
• No incentive for regulators to promote P2
• No incentives for different agencies to cooperate or coordinate approval of new technology and promote P2

Potential Solutions:

Top Three

1. have one person from each agency coordinate with all other agencies
2. mandate cooperation; offer incentives
3. advertise existing efforts in government

Other Solutions

• more funding
• common language
• make the vision more universal
• central clearinghouse: meet regularly to discuss issues
• provide regulatory relief for new technologies
• change basic laws that created the agencies
• link P2 and other agencies via e-groups
• sell P2 to legislature

Action Plan

• new committee
• use Permit Assistance Centers as "jumping off point"
• direct business to "expert" for best info available

Difficulties:

• Important to change attitudes of managers (bring them into the field)
  • Old dog, new tricks
• Need management commitment and buy-in
• Need inspector training on industry groups -- will get a certain percentage interested
• State training has no P2 (e.g. 8-hour generator training)
• Lack of interest
• Time, inspection quotas
• No info on state-mandated P2, e.g., CUPA, SB 1082, Tanner, other
• No funding, recognition for P2; don’t lose money if you don’t do it
• New inspector orientation needs to integrate P2 into all program training

Solutions:

1. Develop a mission statement for management

Adjust inspection quota to allow time for P2

OR

Add a P2 "bean"

2. Funding

Recognition (a carrot) (for regulatory agencies)

Repercussions (if P2 not done)

3. Legislative changes: laws and regs
4. Training
5. Give money to locals to review SB 14 plans

If CUPAs are evaluated solely on the number of inspections, no incentive. If CUPAs are evaluated on business compliance, there is more room for business assistance, P2 activities.