Tribal Compliance Assistance Center

Pollution Prevention and Compliance Assistance

Pollution knows no boundaries. Pollution originating in the air, on the land, in the water, even on the other side of the world, can eventually disperse around the globe and degrade human health and the environment. Pollution prevention can be applied across these environmental media (i.e., air, water, and land) to address both point source and nonpoint sources of pollution.

Pollution prevention, also known as source reduction, is any practice that eliminates or reduces pollution at its source. Pollution prevention is achieved through material substitutions, process changes, and the more efficient use of natural resources (e.g., raw materials, energy, water, and other resources). Through pollution prevention, the use and production of hazardous substances can be minimized, thereby protecting human health, strengthening economic well-being, and preserving the environment.

Benefits of Pollution Prevention

Pollution prevention is one of the best ways for tribes to conserve natural resources and decrease chemical exposures and environmental degradation. At the same time, reducing pollution also allows tribes to meet compliance standards, save money on materials and energy costs, and reduce liability. Information on waste streams, along with pollution prevention tips and strategies, is included in this chapter.

Putting pollution prevention practices in place can:

• Help tribes and tribal facilities meet compliance standards



• Improve practices and procedures to ensure continued compliance



• Reduce risk of employee exposure to hazardous waste by creating safer working conditions

Practicing pollution prevention can:

• Save money in production and material costs



• Reduce solid and hazardous waste disposal costs



• Increase regulatory compliance and avoid penalty fees

Implementation of Pollution Prevention

Many tribal governments integrate pollution prevention into their operations. Tribal pollution prevention practices can be applied across a wide variety of operations, including during wastewater pretreatment, purchasing and procurement opportunities, building construction and operation, and educational activities.

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Purchasing Practices That Encourage Regulatory Compliance and Pollution Prevention

Tribal governments use numerous products as they perform services for tribal members. Product manufacturing (including raw material extraction), transportation, use, and disposal can generate byproducts that stress tribal, national, and global environmental resources and pose health threats to product users and the public. By incorporating environmental and health criteria into purchasing specifications, tribal governments can reduce or avoid the use of potentially harmful chemicals, reduce the risk of accidents and toxic releases, and more easily achieve regulatory compliance.

Green purchasing practices (e.g. purchasing energy efficient equipment, low toxicity cleaning materials, recycled content products) are important components of effective pollution prevention programs and can also lead to cost savings, manifested in reduced energy costs and reduced hazardous material disposal costs.

Presidential Executive Order 13101 (PDF) (11 pp, 95K, About PDF) (which strengthens Executive Order 12873) Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition, directs federal agencies to set goals to increase their use of recycled content products and other environmentally preferable products and services. Many tribal and state governments have voluntarily adopted policies that support the Executive Order and have increased their procurement of recycled products and products that are less hazardous, non-toxic, energy efficient, and generate less waste.

Environmentally-Preferable Product Alternatives

The waste stream, and the types of emissions generated by the activities of tribal governments, is directly affected by the products they purchase or use. Choosing environmentally-preferable alternatives to products that are considered hazardous, or that contribute to wastes covered under environmental regulations, is a preventive strategy available to any tribe involved in product requisition. Various sections of the Tribal Profile provide information on specific wastes generated and pollution prevention opportunities as does EPA's Environmentally Preferable Purchasing Web site, where you will find tools, documents, and guidance, including a comprehensive database for specific products.

Top Pollution Prevention Opportunities

The following list highlights selected strategies for preventing pollution through purchasing practices:

• Adopt a purchasing policy that promotes the integration of environmental and health criteria in all product specifications



• Educate tribal staff about health effects associated with chemicals commonly contained in the products they use or are exposed to, and provide information on alternatives



• Choose one department/operation at a time to incorporate environmentally-preferable products; start with a group where you are most likely to succeed. Review final product specifications with product users or operation supervisors to ensure that their needs are satisfied



• Encourage users to choose environmentally-preferable products



• Involve product end-users throughout the decision-making process. Request that vendors perform product demonstrations for staff, and compare products



• Review all purchases and read all product Material Safety Data Sheets and product labels for potential environmental and health impacts prior to purchase and use



• Check products for durability



• Make sure products can be safely used and stored (e.g., adequate storage locations and ensure personal protective equipment is available)



• Avoid purchasing products that are potentially harmful to the user, public, or environment (e.g., contain known or suspected carcinogens or other toxic ingredients), or purchase the least toxic products available to do the job



• Prevent the generation of hazardous wastes in operations by eliminating products that contain hazardous ingredients



• Participate in cooperative purchasing ventures with other jurisdictions to increase availability of environmentally-preferable products, leverage purchasing power, and reduce internal costs associated with the formal bid process



• When researching environmental purchasing, utilize resources and expertise available from vendors, manufacturers, government agencies, non-profits, and other organizations



• Consider environmental and health impacts associated with a product's life cycle prior to drafting bid specifications ("product life cycle" includes raw material extraction or development, product manufacturing, transportation to market, product use, and disposal)



• Implement waste reduction activities (e.g., lease agreements that require vendors to take responsibility for products as they become obsolete; require prospective bidders to avoid excess paper and packaging in their bid and proposal submittals such as avoiding plastic covers and dividers, using both sides of paper, and using post-consumer recycled content paper; specify copiers and printers with double-sided printing capabilities)



• Begin an energy conservation program and invest in energy-efficient equipment and building design (specify EPA "Energy Star" certified equipment and require equipment installers to activate efficiency features upon product installation)

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