March 1998

Compliance with regulatory requirements, worker exposure, permitting, installing capital intensive control equipment, waste disposal, and many other factors may pose a threat to your profitability and ability to compete in the marketplace.

Pollution prevention, which reduces or eliminates waste at the source, will help you cut those costs and improve your ability to stay competitive and profitable.

On Nov. 15, 1990, the Clean Air Act Amendments (CAAA) were signed into law. Thousands of small businesses are affected by the amendments’ controls on small air pollution sources. The requirements affecting small business owners and operators depends on how badly the local air is polluted, and the kinds and quantities of pollutants their businesses emit. Auto body shops, bakeries, distilleries, dry cleaners, fiberglass fabricators, foundries, furniture manufacturers, gasoline service stations, general contractors, metal finishers and fabricators, photo finishing laboratories, printing shops, and other small businesses may be affected by the air pollution control programs the law may require. Complying with the law’s requirements, however, is not the only cost that influences your bottom line.

Bottom Line Busters
Operating a business using raw materials that contain regulated chemicals costs money. Estimated costs of using hazardous substances and generating wastes often are inaccurate because many of the "hidden" costs are unaccounted for. On Page 2 are typical costs and activities that often are overlooked when estimating the total costs of processes that use hazardous substances and generate wastes. Also detailed is a step-by-step approach you can take to reduce or eliminate those costs through pollution prevention.

 

HIDDEN COSTS OF USING REGULATED CHEMICALS

Receiving Area Spill response equipment Emergency response plan Raw Materials Storage Storage facilities Secondary containment Right-to-know training Reporting and records Safety training Container labels

Process Area Safety equipment Right-to-know training Worker exposure Waste collection equipment Emission control equipment Sampling and testing Reporting and records Solid and Hazardous Waste Sampling and testing Containers Labels and labeling Storage areas Transportation fees Disposal fees

Air, Water Emissions Control Permit preparation Permit fees Capital costs Operating expenses Recovered materials Inspection and monitoring Recording and reporting Sampling and testing Emergency planning Discharge fees

 

AN ALTERNATIVE: POLLUTION PREVENTION

The most effective way to reduce the costs of complying with requirements in the Clean Air Act Amendments and other environmental regulations is to stop using the materials that are regulated in the first place. Reducing or eliminating waste and the use of hazardous substances is called “pollution prevention.” The following pollution prevention approach can help your company:

• Comply with regulations and cut your paperwork burden;
• Reduce costs by using fewer raw materials;
• Cut waste transportation and disposal costs; and
• Reduce long-term liability and insurance costs.

 

The Pollution Prevention Approach

Step 1: Establish a small group of people in the facility to sit down and have a waste minimization brainstorming session. To help gain the most from this session:

• Gather information on the amount of money being spent to purchase, use and dispose of the higher-volume/more-toxic raw materials used. Be sure to account for all the costs:
     Labor — material handling, recordkeeping, labeling, manifesting, training, permitting and reporting
     Materials — raw materials, training materials, safety materials
     Equipment — cleaning/degreasing, waste treatment, air pollution control, protective equipment storage area/equipment.
     Other — waste disposal, regulatory fees and fines, testing fees
• Identify problem areas. Paints, primers, thinners, cleaning solvents, adhesives, inks, stains, varnish, and reducers typically have high percentages of regulated chemicals in their makeup.
• Represent a cross-section of responsibilities in the meeting group.

Step 2: Determine from the group’s input the top three air emission sources, in terms of cost and quantity emitted. For example, write down the three air emission sources that are the most expensive to manage:

1. Degreasing/surface preparation
2. Solvent-based painting operations
3. Parts washing in maintenance department

Then, for example, write down the three air emission sources that have the highest level of raw material use:

1. Solvent-based painting operations
2. Degreasing/surface preparation
3. Parts washing solvent

Step 3: Focus on one of your listed items for your first pollution prevention effort. Talk to your suppliers and explain to them your interest in finding a way to eliminate the use of regulated chemicals. Ask if they supply other products that can get the job done without the added hazardous chemicals. Also, talk to your customers about changing specifications to allow the use of alternative process materials.

Step 4: As time permits, evaluate opportunities to eliminate or reduce the second- and third- ranked waste streams. Continually look at all processes at your facility, and evaluate pollution prevention opportunities to reduce and eliminate hazardous substance use.

 

WHO TO CALL FOR HELP

Through each state in the Northwest, non-regulatory assistance is available for small businesses with air quality questions. The purpose of these programs is to:

• explain the air quality rules and recommend ways to comply;
• provide free, on-site technical assistance visits;
• help businesses estimate their air pollution emissions;
• refer businesses to needed resources; and
• provide information on potential sources of financing for compliance requirements.

For free, non-regulatory assistance and referrals, contact PPRC.

This fact sheet is intended for general reference only; it is not a complete statement of the technical or legal requirements associated with this regulation.