Perform internal full cost accounting (i.e. assess full costs of tangibles like raw material losses and product quality improvement, and of intangibles like customer satisfaction and employee safety, to help make informed decisions and help foster pollution prevention)
Financial community should set internal full cost accounting standards; government agencies should form partnerships with industry to help develop new accounting practices and monitor effectiveness; industry is responsible for implementation after standards are set
Voluntary acceptance by industry; fear of change and concern for confidentiality; government's concern that this approach does not conform to current command-and-control management strategies
Establish standards for internal cost accounting; augment existing pollution prevention rewards (give an image and marketing dollar value of the award with its presentation); form government-industry partnerships; establish an industry-produced newsletter
Develop and implement toxic pollutant reduction plans to reduce, if not eliminate, potential sources of persistent, bioaccumulative, toxic substances that have been identified in ongoing programs such as lakewide management plans (LAMPs) and remedial action plans (RAPS)
Facility owners (public and private); government (encourage or require plans, provide guidance or approval for plans); consultants (provide independent opinion and expertise)
Concern for level playing field; ensuring plans turn into actions; convincing small businesses to take action
Priority should be placed on linking individual facility plans to existing, basin-wide and lakewide strategies and objectives; greater emphasis should be placed on moving forward with a voluntary/partnership approach, then evaluating the need for mandatory requirements; when considering mandatory requirements, such as a phase-out of PCB containing equipment, regulatory agencies should conduct a Life Cycle Assessment (LCA) of the proposed regulation to estimate costs and identify previously unforeseen effects of the regulation prior to its promulgation
Incorporate LCA techniques (i.e. analysis of a product's life cycle, including the "cradle-to-grave" economic and environmental impact of a product, process, or service) into all regulatory and incentive-based initiatives to control point source pollution
Product manufacturers perform assessments; insurance industry, academic institutions, and government cooperate to set standards, inclusive of liability and fate
Cost; affordability for small manufacturers; information on product pathways
Amend existing statutes (Toxic Substances Control Act; Federal Food, Drug, and Cosmetic Act; and the Canadian Environmental Protection Act) to require LCA for selected products, inputs, and processes; establish an information clearing house; consult with industry on timing of implementation; inform public with descriptive labeling (proceed with demonstration projects - autos, packaging); provide an example by examining the "cradle-to-grave" costs and impact on society of these proposed regulatory modifications
Perform comprehensive assessments of bioregional pollutant loadings and impacts as a basis for multi-media permitting of point sources; emphasis should be placed on watersheds or bioregions as the primary unit for assessment, with additional consideration of a vertical dimension (including geological strata and the atmosphere)
Government agencies should coordinate cross-media assessments and communicate information to the public; industry should participate and contribute to joint monitoring activities (e.g. Lambton Industrial Society)
Cost; technical constraints (data interpretation, monitoring methods, quality assurance); data gaps (e.g. air deposition) that lead to uncertainty; difficulty in communicating information to the public
Establish cost-sharing arrangements; apply existing objectives (e.g. RAPs and LAMPs) to assessments; assemble multi-media assessment teams; tie assessments to lakewide/lake basin planning, as well as land- use planning within a watershed; use clear data presentation techniques (visual aids)
Issue multi-media discharge permits to facilities in the context of watershed or bioregion impact assessment and defined impaired uses; this should be accomplished as a joint government-industry process, fostered by cooperative agreements
Government agencies (state/provincial and federal permitting authorities must form partnerships to compile data, as well as evaluate it and set discharge criteria); the public must be consulted throughout the planning process; LAMPs; RAPs
Technical and administrative complexity; exchange of confidential information; a paradigm shift for agencies and industry; fractured framework for achieving compliance (renewal times and fees, penalties, compliance deadlines)
Multi-media permitting will require long-term coordination of federal laws/regulations with state/provincial statutes; prior to forming teams, information should be evaluated from other efforts in this area, most notably the multi-media permitting/assessment pilot project in New Jersey; industry team representatives should be selected from industries with substantial loadings as defined by Toxic Release Inventory and National Pollution Reduction Inventory data; industrial representatives from plants currently participating in the New Jersey project should assist in the team formation transition period
Enhance existing regulatory systems to work towards multi-media and pollution prevention goals; these enhancements fall into two categories: behavioral/interpretive (e.g. direct contribution to cleanup activities as opposed to fines) and written regulatory change
Government (initiate and facilitate change); industry (assist in streamlining the regulatory process, as well as demonstration of benefits from the new process); public (be knowledgeable on the regulatory process and provide feedback); governmental permit writers (taking RAPs and LAMPs into account)
Institutional inertia and inflexibility; incompatibilities in regulatory requirements and other legal challenges
Start with behavioral modifications in enforcing existing regulations, with an emphasis on supporting end goals (e.g. using community services - as opposed to or in addition to fines - like public education, habitat rehabilitation, environmental monitoring); form partnerships for monitoring, technology demonstration, and ecosystem research; build these partnerships into regulatory teams that proceed with pilot projects; use data from pilot projects to add innovative provisions to selected regulations; encourage public comment and feedback
Facilitate and expand the exchange of technical information and provide technical assistance on pollution prevention and multi- media assessment
Municipalities (facilitate through industrial pretreatment programs); government (pollution prevention training, recognition and awards like Baldridge Award for Total Quality Management); industry (show leadership and set pollution prevention performance standards); Great Lakes Pollution Prevention Centre in Sarnia, Ontario (information sharing and training)
Confidentiality of information; cost to government and others; cost of transferring information to small businesses; possible inhibition of development of new technological applications
Create more state/provincial and local awards programs; incorporate technical assistance with enforcement actions; have government and industry set vendor pollution prevention standards in procurement specifications; target industrial groups for collective efforts; create agency trouble-shooting teams