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Focusing on Impact Chemicals
The majority of the companies (1,066) set measurable goals or pledges to reduce
their releases and transfers of the 17 targeted chemicals, with the companies choosing which of the 17 chemicals they would reduce. Other participants developed goals
tied to changes in their production levels, chose alternative baseline years (when the
1988 baseline year was not a representative year for their facility), or set a reduction
target for all their TRI reporting without specifying goals for the 33/50 chemicals.
The EPA did not monitor the companies to ensure that their reported figures were
accurate. The simple letters sent to the EPA stating their reduction pledges or plans
were required to be signed by the chief financial officers (CFOs) of the companies.
It was in the interest of the CFOs to reduce costs for their company; therefore,
they were interested in the amount of waste reduced or chemicals released from a
cost-savings opportunity perspective.
ROLE OF STAKEHOLDERS
The EPA, major corporations, industry trade associations, and environmental groups
all played a part in developing the 33/50 Program. The stakeholders, not the sponsoring agency (the EPA), were directly involved in the implementation and program
design to meet self-determined reduction targets for one or more of the targeted
chemicals. The 33/50 Program was free from government regulations, paperwork,
penalties, punishments, and lawsuits. Companies participating in the program
voluntarily developed their own goals and plans and provided their reduction commitments to the EPA in a simple letter.
FINANCIAL IMPACTS
The EPA funded the administrative costs of the 33/50 Program through Pollution
Prevention Incentives for States (PPIS) grants (now referred to as the P2 Grants
Program) to the states. The 33/50 Program administrative and technical assistance activities were added to the list of other state P2 programs already funded
by the grants.
The voluntary approach of the 33/50 Program avoided the costly process of
legislation and the substantial costs of monitoring and enforcement by the regulatory
agency. It was also cost-effective for those making pollution reductions because it
allowed firms to make the most cost-effective emission reductions.
In addition to costs savings, program participation included possible public recognition by the EPA and special awards for innovators and firms with outstanding
P2 achievements. The incentives for a company to participate were the benefits a
company derived from a clean environmental record and were one way for a company
to indicate that it was environmentally conscientious.
EFFECTIVENESS OF PROGRAM
The 33/50 Program achieved its goals in 1994, a year ahead of schedule. The program
proved to be a successful way for the EPA to partner with industries to effectively
reduce the releases and transfers of toxic chemicals through voluntary regulation