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Preventing Industrial Pollution at its Source
A Final Report of the Michigan Source Reduction Initiative


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Chapter 3

CONCLUSIONS AND INSIGHTS

Note: These comments and conclusions must be viewed as a package, not individually. Each project participant may view certain specific outcomes as more important than others, but what is most significant is that the group as a whole supports all of what follows as valid and important lessons to be drawn from this project.


CRITICAL FACTORS

The following factors were critical to the accomplishments of MSRI:

  • MSRI activists. The direct involvement of the environmental and community participants elevated the importance of the project within Dow and facilitated the hard work necessary to formulate, evaluate and implement pollution prevention projects as they arose and created a strong incentive that kept good projects moving. Also, the activists' direct and on-going communication with Dow business personnel allowed them to communicate their priorities to the line managers in a manner that had not occurred previously.

  • Project was jointly designed. The MSRI was designed and implemented directly through the interaction of the environmental and community participants and the company. The activists and Dow both determined what objectives needed to be accomplished through the project to address their concerns and interests and then were able to work through issues and agree upon a mutually acceptable approach.

  • Early input. The opportunity for the activists to review and discuss the pollution prevention opportunities prior to internal Dow decision making provided them true influence. The project was addressing real business opportunities, not just the development of interesting pollution reduction possibilities.

  • Quantitative reduction goals and deadlines. Goals and deadlines gave the project focus and greatly facilitated conversations among participants with otherwise diverse views on many other matters.

  • Technical expertise. The internal technical consultant (Bill Bilkovich) was able to focus exclusively on pollution prevention activities. He also communicated effectively with the technical people regarding possible pollution prevention projects. Bilkovich located, mobilized and focused the company's skills on getting the information needed to support change and to found the person(s) who would champion change.

  • The involvement of an external technical consultant. Steve Anderson provided technical review and analysis that enabled the activists and environmental participants to discuss issues and opportunities with Dow in a very sophisticated manner. Bilkovich and Anderson were also able to work together to address a number of technical issues which were integral to the project.

  • Commitment of senior Dow management. MSRI had internal support in the organization, starting at the most senior management levels. The direct involvement of Dow senior managers was key to providing incentives for younger Dow employees to view the project as a priority.

  • Direct participation by Dow business leaders and activists. It was very important that the business leaders, not just the environmental staff from Dow, were directly involved in discussing issues with the activists involved in the project. This enabled the discussions to directly address issues related to business decision making. Activists learned about how decisions get made, and business people were made aware of the environmental priorities of the world outside of Dow.

  • Dow framework at outset of project and commitment of Dow EH&S staff. There were several actions that Dow had taken in recent years which provided the groundwork necessary to move toward meeting the MSRI goals. These included:

    • The establishment of the Dow Global Environmental 2005 Reduction Goals which call for significant and ongoing reductions in a range of wastes and emissions.

    • Incorporation of an internal cost accounting mechanism which allocates the costs of traditional waste management activities to the businesses that utilize such services.

    • Restructuring Dow EH&S to attempt to integrate environmental health and safety into each Dow Global Business unit. This effort includes a corporate objective which calls for the inclusion of environmental and pollution prevention goals in individual performance plans and business strategies.

    • Dow corporate and Midland EH&S staff took a leadership role in implementing this project internally, assigning personnel to the task and working with the businesses to keep them focused on the project.

  • Facilitation. The involvement of an experienced and trusted facilitator (John Ehrmann) allowed the group to focus on substance and provided a person and process for addressing controversial issues that arose during the course of the project. He was integral in designing the project at the outset in a way that would meet participants' needs and achieve results. Ehrmann also initiated ongoing communication among the activists and facilitated their conference calls on a periodic basis.

  • Shared understanding on the limits of the project. The participants agreed at the outset that their participation in MSRI did not mean that the same activists and Dow staff would stop interacting in other arenas regarding other critical issues. People acknowledged that for this project to go forward everyone needed to agree that there were other issues where disagreements exist and need to be addressed in the manner seen as appropriate by those involved.

  • Open, accountable project design without confidentiality. The absence of confidentiality agreements ensured that the public would be able to fully understand both opportunities and barriers in the project. The increased sense of accountability motivated the successes the project achieved.

  • Good information and good tracking methods. Dow provided information to the project that went well beyond the public information required by the Toxic Release Inventory. Particularly important was process-level data on waste and emissions that allowed the MSRI participants to better understand the process chemistry and the root causes of waste generation. Progress was quantitatively tracked from meeting to meeting in a way that kept all participants equally informed.



INSIGHTS

Barriers to Pollution Prevention

  • Information. TRI information is not sufficient to indicate where pollution prevention opportunities may lie because it is not process specific. It took considerable work in MSRI to refine the available public information and determine accurate waste and emission baselines in this project. TRI information, however, was crucial in identifying the priority MSRI chemicals.

  • Terminology. Differences in terminology and definitions of pollution prevention, the principles of sustainability, and environmental health and safety between the company and activists got in the way of discussing and developing an understanding of the concepts and the opportunities which exist. Engineers often do not realize that conventional yield improvement initiatives can deliver the sorts of pollution prevention sought by environmental health and safety personnel.

  • Business value. Business value alone will not drive pollution prevention within a company, for several reasons:

    • Small size of many pollution prevention projects. Most of the opportunities identified in the MSRI project required small amounts of capital. Small projects (measured in dollars) often are overlooked by large company engineering staff, although they can lead to large and very significant reductions in wastes and releases.

    • Competition for capital. Large pollution prevention projects have to compete with other capital priorities within the company and individual businesses. This was cited as the most common barrier to implementing pollution prevention projects by EH&S leaders in the various Dow businesses.

    • Market. The role of customer demand in the market is recognized as driving product design. However, that connection to market demand has not been translated into the design and production of "green" products.


  • Reward systems. Personal performance goals and recognition at the staff level are not often linked to the achievement of waste minimization and pollution prevention objectives. Such linkages do exist in other areas of the 2005 goals (e.g., safety).

  • Understanding community concerns. Business leaders normally rely on Dow toxicologists and do not have sufficient information to evaluate community and environmental concerns about the environmental health and safety of their products, wastes, or treatment processes. Business decision-makers normally do not have an accurate understanding of the issues and concerns of the community regarding the chemicals they produce and use at the facility. MSRI played a key role in increasing this understanding.

  • Regulations. Regulations were not an impediment to pollution prevention. Traditional regulations also do not directly encourage pollution prevention. For several businesses the potential for new regulations initiated a review of wastes and emissions that laid the groundwork for pollution prevention initiatives.

  • Confidentiality. Confidentiality agreements were not necessary; it was possible to explain both processes and engineering opportunities without disclosing any business-sensitive information


Information and Communication

  • The pollution prevention initiative created a new lens for the businesses to view their production processes. Starting with the premise that waste must be reduced, rather than only looking through the lens of cost reduction, led to fundamental questions about production processes. This different approach uncovered new information about those processes.

  • It was important that Dow was willing to accept the list of priority chemicals from the activists without debating the merits of the list. This allowed the work to focus on making reductions rather than discussing the list.

  • MSRI fostered effective communication between business leaders and the citizen and environmental participants.

  • MSRI has been the most effective outside input to Michigan Operations regarding pollution prevention and overall sustainability activities. Outside of MSRI, business leaders do not normally have direct interaction with community stakeholders in prioritizing pollution prevention efforts based on community input.



MSRI PROJECT DESIGN LIMITATIONS

  • There were a number of issues (e.g., clean production, product toxicity, genetic engineering, production and registration of chemicals of concern to the community, community accountability for past contamination, and the death of a worker during the course of the project) that are of importance to the activist participants that were not a primary focus of this project. The community participants viewed Dow's activities related to these issues as one measure of the status of institutional change.

  • The environmental and community representatives recognized the tension which existed for them regarding the desire to encourage pollution prevention and doing so for processes which make products that they do not believe are sustainable.

  • While the list of priority chemicals developed by the environmental and community participants reflected their concerns regarding the health and environmental effects of those compounds, the discussions with business leaders did not directly address health and environmental concerns. When those issues were discussed, it was clear that the Dow personnel and the community and environmental representatives had very different information and levels of concern with respect to these issues.

  • The qualitative/institutional goals were not focused on sufficiently in the early stages of the project, and this resulted in insufficient attention being paid to those project goals. It was noted that if someone had been focusing on the institutional change goals with the same intensity of focus as the quantitative goals, more might have been achieved. It is also important to note that it is harder to measure change with respect to the institutional goals than it is for quantitative goals, but this does not make them any less important.



SUSTAINABILITY

  • EH&S Operations Leaders need a better understanding of the ongoing Dow corporate initiatives in sustainability.

  • Sustainability as a concept has not been discussed widely within Dow.

  • Most businesses are not conducting comprehensive full-cost accounting that takes into account all of the true costs associated with producing products. Businesses are also not comparing the lifecycle costs of their products with the lifecycle costs of substitutes to their products.

  • The development and implementation of Life Cycle Analysis (LCA) and other evaluation tools should have input from outside of Dow to gain a wider range of values and opinions.

  • It appears to the activists and environmental participants that health and environmental concerns are not part of the day-to-day mindset of business leaders and are not routinely integrated into business decisions.

  • Sources outside of Dow can provide further input and information to businesses concerning health effects, toxicology and epidemiology.

  • Based on the survey of Dow business representatives, it appears to the activists and environmental participants that there is not a clear understanding of the level of community, governmental and scientific concern regarding persistent bioaccumulative toxics (PBTs). Similarly, they are concerned that there does not appear to be an understanding that the incineration of halogenated products can result in the production of PBTs.

  • Based on the results of the survey, it appears to the activists and the environmental participants that the evaluation of the environmental performance of Dow suppliers and end-users should be focused on to improve adherence to the requirements of Responsible Care.

  • When MSRI ends, an ongoing mechanism will be needed through which business leaders can get input regarding the views of environmental and community representatives regarding pollution prevention priorities.

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