xii
Foreword
trainees to set up Russian companies in a way that would be sustainable. In addition
to technical training, we provided training in business practices, something that was
scarce in Russia at the time. In Uzbekistan, we assisted the state and federal governments and regulated industries in setting up regional pollution prevention programs.
The Soviet system had one aspect that was significantly different from past and
current U.S. environmental regulation. In essence, they regulated the use of toxic
chemicals based on a fee structure; that is, a company measured its annual releases
of harmful constituents and paid a fee based on the quantity released. The cost per
pound was based on the toxicity of chemicals released. The fee started at zero release
to create an incentive to reduce chemical discharges to zero. The fee increased in
steps as they approached what in the United States would be the permit level and
increased again for even higher releases beyond the permit level. This approach
has the potential to achieve greater environmental benefit at a lower expenditure
of resources versus the “command-and-control” approach of allocating levels of
pollution (permit levels) equally between all of the regulated community regardless of individual capability to achieve the permitted standard. It is ironic that the
Communist bloc set up environmental regulation based on a market-based approach,
while capitalist countries have based environmental protection on a system of command and control. The principal problem with the Soviet system was that enforcement was arbitrary.
While giving a pollution prevention talk in Brazil, I also gave a talk to the
Companhia de Tecnologia de Saneamento Ambiental (CETESB), the environmental
regulatory agency for the state of São Paulo. I left a copy of my Pollution Prevention
Handbook, which they added to their growing library of materials for their Pollution
Prevention Department, established in 1992. A few years later, they asked me to provide them with a few days of training on how to run a successful pollution prevention
program. Three years ago, they decided that they wanted to expand on their program
and wanted assistance in developing a program to reduce the impacts of toxic chemicals on public health and the environment. To develop this program, we first evaluated the effectiveness of similar programs in the United States and other countries.
The USEPA Toxics Release Inventory (TRI) was developed in response to the
tragedy of Bhopal, where 3,787 people died and hundreds of thousands were sickened
by the release of methyl isocyanate from a Union Carbide storage tank. The program
required that U.S. companies report on their annual release of approximately 200
plus toxic chemicals. As a result of this program, companies were required to find out
about the composition of products they used, calculate usage of the toxic chemicals,
and report on releases of these chemicals to the environment. An unintended consequence of TRI reporting was that releases of these chemicals reduced over time
as companies sought to reduce adverse publicity and reduce the cost of regulatory
reporting. A subsequent U.S. voluntary program (33/50) resulted in over 50 percent
reduction in releases of 17 highly toxic TRI chemicals over 4 years. Various state
programs have expanded on the TRI requirements to include requirements that companies prepare pollution prevention plans and set toxic chemical reduction targets.
Although the TRI program has been successful as a first step in reducing some
chemical releases to the environment, one enhancement to the program would involve
measuring or reporting the release of toxic chemicals in products themselves. While
Foreword
trainees to set up Russian companies in a way that would be sustainable. In addition
to technical training, we provided training in business practices, something that was
scarce in Russia at the time. In Uzbekistan, we assisted the state and federal governments and regulated industries in setting up regional pollution prevention programs.
The Soviet system had one aspect that was significantly different from past and
current U.S. environmental regulation. In essence, they regulated the use of toxic
chemicals based on a fee structure; that is, a company measured its annual releases
of harmful constituents and paid a fee based on the quantity released. The cost per
pound was based on the toxicity of chemicals released. The fee started at zero release
to create an incentive to reduce chemical discharges to zero. The fee increased in
steps as they approached what in the United States would be the permit level and
increased again for even higher releases beyond the permit level. This approach
has the potential to achieve greater environmental benefit at a lower expenditure
of resources versus the “command-and-control” approach of allocating levels of
pollution (permit levels) equally between all of the regulated community regardless of individual capability to achieve the permitted standard. It is ironic that the
Communist bloc set up environmental regulation based on a market-based approach,
while capitalist countries have based environmental protection on a system of command and control. The principal problem with the Soviet system was that enforcement was arbitrary.
While giving a pollution prevention talk in Brazil, I also gave a talk to the
Companhia de Tecnologia de Saneamento Ambiental (CETESB), the environmental
regulatory agency for the state of São Paulo. I left a copy of my Pollution Prevention
Handbook, which they added to their growing library of materials for their Pollution
Prevention Department, established in 1992. A few years later, they asked me to provide them with a few days of training on how to run a successful pollution prevention
program. Three years ago, they decided that they wanted to expand on their program
and wanted assistance in developing a program to reduce the impacts of toxic chemicals on public health and the environment. To develop this program, we first evaluated the effectiveness of similar programs in the United States and other countries.
The USEPA Toxics Release Inventory (TRI) was developed in response to the
tragedy of Bhopal, where 3,787 people died and hundreds of thousands were sickened
by the release of methyl isocyanate from a Union Carbide storage tank. The program
required that U.S. companies report on their annual release of approximately 200
plus toxic chemicals. As a result of this program, companies were required to find out
about the composition of products they used, calculate usage of the toxic chemicals,
and report on releases of these chemicals to the environment. An unintended consequence of TRI reporting was that releases of these chemicals reduced over time
as companies sought to reduce adverse publicity and reduce the cost of regulatory
reporting. A subsequent U.S. voluntary program (33/50) resulted in over 50 percent
reduction in releases of 17 highly toxic TRI chemicals over 4 years. Various state
programs have expanded on the TRI requirements to include requirements that companies prepare pollution prevention plans and set toxic chemical reduction targets.
Although the TRI program has been successful as a first step in reducing some
chemical releases to the environment, one enhancement to the program would involve
measuring or reporting the release of toxic chemicals in products themselves. While