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Ohio Pollution Prevention in Supplemental Environmental Projects
When the Pollution Prevention Act of 1990 was enacted, leaders in the State of Ohio's Environmental Protection Agency (Ohio EPA) incorporated pollution prevention into all aspects of its regulatory programs. Working with and learning from other state leaders about P2 concepts, Ohio EPA determined that P2 could be incorporated into education and outreach, permitting, inspections, and enforcement settlements. As a result, the Ohio EPA Office of Compliance Assistance and Pollution Prevention (OCAPP) now coordinates with agency enforcement staff and defendants to identify appropriate P2 Supplemental Environmental Projects (SEPs) for enforcement settlements. Since 1991, funded by Federal media program grants and the State's general revenue funds, Ohio EPA has incorporated pollution prevention programs, assessments, and projects (including third party projects) into 145 Supplemental Environmental Projects negotiated with violators of environmental laws.
The most valuable resources used to complete this project included the state's Attorney General's Office, the Ohio EPA legal office, the Ohio EPA media programs, the Office of the Governor, other pollution prevention leading states, and the National Pollution Prevention Roundtable.
Positive Results
This project enables enforcement staff to participate in pollution prevention. Further, and perhaps more importantly, this project documents pollution prevention successes. By clearly identifying and specifying pollution prevention projects for specific facilities through an enforcement vehicle, Ohio is able to track pollution prevented. Since 1991, pollution prevention has been incorporated into over 145 enforcement settlements. As a result of these settlements, 6 case studies have been developed that document pollution prevented as a direct result of the projects undertaken by the previous violators. The results of these studies (posted on Ohio EPA's website as listed below) cannot be aggregated due to the facilities' unique and disparate environmental impacts. One case study example is that of an electroplater who developed a comprehensive, facility-wide P2 program and conducted a P2 assessment. These actions resulted in the reduction of the use of water and the generation of subsequent waste water by 7,400 gallons per day and a reduction in the use of chromium by 420 pounds annually. In addition, a compendium summarizing all 145 enforcement settlements is updated annually and available upon request using the contact information listed below.
Key Elements, Suggestions, and Challenges
In order to succeed, everything must be documented in as much detail as possible, including program guidance and case studies where applicable. The fact that Ohio's new governor was a champion of pollution prevention facilitated support for and the success of this new effort. Program managers state that top management support from the businesses was also very important.
Because there was inherent media staff and business resistance to this new approach, incentives such as the incorporation of pollution prevention into media staff job descriptions and performance evaluations, and reduced cash penalties for the business should be considered. In the end, through persistent education, outreach, and ultimate project success, the culture did change and these barriers were overcome. Eventually, the regulators and businesses understood that the up-front investments of effort, time, and money would pay back for them, their shareholders, and the environment.
More Information
P2 SEPs Pollution Prevention Supplemental Environmental Projects