207
Pollution Prevention Planning
normally need more assistance developing P2 programs. It was noted that if
the larger companies do not help the smaller-to-midsize firms with P2, the
New Jersey DEP may create more stringent regulations for the entire industry. Air Products has provided assistance to smaller companies in an effort
to decrease the amount of regulations required for the chemical industry.
• Managers at Air Products suggested that reporting be for 2 yrs rather than
yearly. It was also felt that the TRI program by itself was the most effective
at promoting toxics reductions due to the shame factor.
• Those at Air Products also suggested that less emphasis be placed on
material accounting as it can require a lot of resources that could be used
to fund actual projects.
• Those at Air Products advised against creating regulations that are too
prescriptive for manufacturing facilities. Regulations that are too prescriptive can stifle the manufacturing and economic growth of a facility.
CALIFORNIA: HAZARDOUS WASTE SOURCE REDUCTION AND
MANAGEMENT REVIEW ACT OF 1989 (SENATE BILL 14)
In California, Senate Bill (SB) 14 requires that generators that routinely generate
more than 12,000 kg of hazardous waste or 12 kg of extremely hazardous waste
in a reporting year comply with SB 14. These regulated industries are required to
evaluate source reduction opportunities and report on accomplishments every 4 yrs
(California EPA 2006).
The regulated facilities are required to stay in compliance with the legislation
by preparing a Source Reduction Evaluation Review and Plan, a Hazardous Waste
Management Performance Report, and a Summary Progress Report. TUR is not a
separate program and is integrated within the P2 planning in California.
A P2 Plan and Summary are required to be prepared every 4 yrs in addition to
Hazardous Waste Management Performance Reports. The generator is required to
certify that the plan is being implemented unless the selected measures for source
reduction are not technically feasible or economically practicable or if attempts to
implement the measure result in an adverse impact to hazardous waste reduction
goals, product quality, or human health or the environment (State of California 2005).
TEXAS
The Waste Reduction Policy Act of 1991 was adopted by the Texas legislature
to prevent pollution in Texas. The Texas Commission on Environmental Quality
(TCEQ 2003) adopted the corresponding rule under 30 TAC 335 Subchapter Q.
This act requires that large- and small-quantity generators of hazardous waste and
TRI Form R reporters
1. Prepare a 5-yr P2 plan
2. Submit an executive summary of the P2 plan
3. Report annually on their activities to prevent pollution
Pollution Prevention Planning
normally need more assistance developing P2 programs. It was noted that if
the larger companies do not help the smaller-to-midsize firms with P2, the
New Jersey DEP may create more stringent regulations for the entire industry. Air Products has provided assistance to smaller companies in an effort
to decrease the amount of regulations required for the chemical industry.
• Managers at Air Products suggested that reporting be for 2 yrs rather than
yearly. It was also felt that the TRI program by itself was the most effective
at promoting toxics reductions due to the shame factor.
• Those at Air Products also suggested that less emphasis be placed on
material accounting as it can require a lot of resources that could be used
to fund actual projects.
• Those at Air Products advised against creating regulations that are too
prescriptive for manufacturing facilities. Regulations that are too prescriptive can stifle the manufacturing and economic growth of a facility.
CALIFORNIA: HAZARDOUS WASTE SOURCE REDUCTION AND
MANAGEMENT REVIEW ACT OF 1989 (SENATE BILL 14)
In California, Senate Bill (SB) 14 requires that generators that routinely generate
more than 12,000 kg of hazardous waste or 12 kg of extremely hazardous waste
in a reporting year comply with SB 14. These regulated industries are required to
evaluate source reduction opportunities and report on accomplishments every 4 yrs
(California EPA 2006).
The regulated facilities are required to stay in compliance with the legislation
by preparing a Source Reduction Evaluation Review and Plan, a Hazardous Waste
Management Performance Report, and a Summary Progress Report. TUR is not a
separate program and is integrated within the P2 planning in California.
A P2 Plan and Summary are required to be prepared every 4 yrs in addition to
Hazardous Waste Management Performance Reports. The generator is required to
certify that the plan is being implemented unless the selected measures for source
reduction are not technically feasible or economically practicable or if attempts to
implement the measure result in an adverse impact to hazardous waste reduction
goals, product quality, or human health or the environment (State of California 2005).
TEXAS
The Waste Reduction Policy Act of 1991 was adopted by the Texas legislature
to prevent pollution in Texas. The Texas Commission on Environmental Quality
(TCEQ 2003) adopted the corresponding rule under 30 TAC 335 Subchapter Q.
This act requires that large- and small-quantity generators of hazardous waste and
TRI Form R reporters
1. Prepare a 5-yr P2 plan
2. Submit an executive summary of the P2 plan
3. Report annually on their activities to prevent pollution