November 27, 2006

"Improving Performance" seminar showcases creative approaches to environmental management

The Ontario government recently hosted the first-ever international meeting of the Multi-State Working Group on Environmental Performance (MSWG), a network of regulators, business and industry representatives, academics and environmental organizations with an interest in improving and expanding the application of environmental management systems (EMS). Although based in Wisconsin, the MSWG has actively pursued dialogue with other jurisdictions, and the two-day Toronto meeting showcased a number of creative, collaborative initiatives under the theme "Innovation in Environmental Management: Improving Our Performance."

The presentations addressed several important issues in this area, among them: moving pilot projects into the mainstream; working collaboratively (sharing both risks and rewards); challenges and barriers to innovation; and integrating new approaches to environmental management.

Jay Benforado, director of the U.S. Environmental Protection Agency's National Center for Environmental Innovation (NCEI), outlined the three basic tools comprising the Environmental Results Program (ERP), an approach developed by Massachusetts regulators who were faced with trying to ensure compliance by large groups of small facilities in various sectors, and doing so with limited resources.

The ERP approach represents a move away from the traditional regulation/inspection tools toward an integrated system incorporating compliance assistance, self-certification, and performance measurement and evaluation. Compliance assistance workbooks and workshops are organized around how facilities and businesses operate, providing information designed to address a full range of environmental media and to foster pollution prevention, Benforado explained.

The ERP's self-certification component includes sector standards, return-to-compliance plans and self-certification forms. The performance measurement component is based on environmental business practice indicators, statistical analysis, the use of outcomes to target actions, and reporting of results.

First introduced in Massachusetts in 1996, the ERP generated positive results almost immediately. Return-to-compliance submissions by dry cleaning facilities, for example, dropped from 62 in 1997 to 16 in 1998, four in 1999 and three in 2000 (a decrease in submissions reflecting improved compliance). The ERP initiative began with three sectors across the state (drycleaning, photo processing and printing) and now encompasses 12 sectors, among them autobody shops, auto salvage yards, dental facilities, oil/gas extraction wells and underground storage tanks/retail gasoline operations.

The EPA quickly recognized the potential of the ERP and in 2000, the agency's Innovation Action Council (IAC) selected the ERP as one of two innovations for scale-up efforts. A federal/state steering committee was set up to diffuse the ERP, with the EPA funding ERP testing in a growing number of states between 2000 and 2006. Today, said Benforado, 16 states are using some form of ERP.

The EPA's endorsement of and support for this initiative has contributed to its mainstreaming, both through funding (e.g. grants) and practical assistance such as co-ordination, technical document prepareation, travel support for state-to-state exchanges and tools such as an ERP guide for government agencies, a "how-to" guide for developing an ERP and an EPA national model ERP workbook, available in paper and electronic versions.

Based on this experience, Benforado listed a number of keys to mainstreaming innovations in environmental management, starting with general acceptance of the approach by multiple stakeholders, followed by adoption by a substantial number of jurisdictions. Other contributing factors have been the development of an ERP leadership consortium by the states, provision by the EPA of credit for ERP in its enforcement program, and inclusion of ERP in the EPA's enforcement rules.

The success of a similar Canadian counterpart program was outlined by GÈrard Girouard of Environment Canada's Quebec region office. The Enviroclub, a voluntary pollution prevention (P2) initiative, is co-sponsored by Environment Canada, the National Research Council (NRC) and Economic Development Canada (Quebec region).

Currently operating only in Quebec, the Enviroclub program targets small- to medium-sized enterprises (SMEs, i.e. companies with up to 200 employees). Such companies, said Girouard, are often unaware of the P2 approach to environmental management.

The Enviroclub groups 12 to 15 companies within a particular region or industry sector, offering technical and financial assistance to implement a P2 project or to assess the company's environmental impacts as part of the development of an environmental management system (EMS).

Since the first Enviroclub was formed in 2000, Girouard said 145 projects have been conducted, including 128 technical projects and 17 EMS. Together, the participating companies have achieved substantial reductions in resource consumption, including one million cubic metres (m3) per year in water use, 22,500 m3 in wood and 4.3 gigawatt-hours (GWh) of electricity. This last, he noted, translates to a reduction of 29,000 tonnes of greenhouse gas emissions. As well, releases of toxic substances from Enviroclub participating companies have declined by 303 tonnes. while hazardous waste generation is down by 815 tonnes.

The program has helped SME participants save money as well, noted Girouard. In return for a contribution of $2,500, Enviroclub companies have realized savings averaging over $70,000 per year each. Since the first Enviroclub was established in 2000, the program has expanded to four this year, with six expected to be set up in 2007. Among the sectors covered are food manufacturing, wood product manufacturing, plastics and rubber manufacturing and fabricated metal product manufacturing. Enviroclub participants report a 99% satisfaction rate, Girouard noted.

While the Enviroclub program delivers net, measurable economic and environmental benefits, recruiting participant SMEs remains a challenge, he continued. Some companies sign on, only to drop out at the last minute. Marketing the program relies on personal contacts, dissemination of success stories and plant visits to seek out P2 opportunties. (More information is available on the Enviroclub Web site,

Other initiatives that have taken a creative approach to resolving environmental issues have included Quebec's EcoPeinture stewardship program for collection and recycling of used paint, and Alberta's Clean Air Strategic Alliance (CASA).

Set up by the paint and coatings industry in Quebec, EcoPeinture began as a non-profit, industry-led, voluntary product stewardship program featuring a small ecological surcharge levied on paint and coatings containers, backed up by a province-wide network of container collection depots.

Provincial regulations implementing the program in 2001 made it necessary for the industry to co-operate with other stakeholders; this has contributed to the success of the program, noted Georges Portelance, EcoPeinture's executive director. He also attributed the program's success to industry leadership, simplicity of the system and a good understanding of the roles and responsibilities of government and industry.

Alberta's CASA, established in 1994, represents a multi-stakeholder, consensus-based approach to assessing and improving air quality in the province, Peter Watson, deputy minister of Alberta Environment (and current CASA president) told the conference. While open and transparent, providing ample opportunity for public input, the CASA process also incorporates a "fall-back" provision giving government the final say in the event a consensus cannot be reached.

This approach, said Watson, has been used to develop strategies that meet both environmental and economic needs, with solutions to air quality problems that are long-term, doable and supported by all stakeholders. Among its successes to date have been the establishment of airshed zones within the province, the creation and work of project teams addressing electricity generation and sour gas venting and flaring, a framework for dealing with particulate matter and ozone, and scientific symposia on topics such as acidic emissions and air quality and human health.

The CASA experience has provided a low-cost ($600,000 per year budget), high-results mechanism for addressing air quality issues. From industry's perspective, it offers balanced treatment of the environmental, economic and social issues related to air quality. Its consensus-based approach ensures greater accountability and careful analysis of tradeoffs. Government benefits from credible results, innovative measures and "smarter" regulation, while non-government organizations (NGOs) are afforded access to a larger pool of ideas and perspectives, plus the opportunity to build positive relationships with traditional adversaries.

In summing up the conference sessions, MSWG president Jeff Smoller said one of the main challenges is to 3"do the right things right." Companies seeking to achieve optimum environmental performance are confronted by (a) competition, which affects both large and small firms; and (b) the significant complexity of the issues.

Emerging from the discussions as well, he said, is the importance of keeping "transaction costs" associated with environmental management. Smoller observed that drawing upon the resources and knowledge of trade associations can help keep costs down and can foster self-regulation.

Finally, he said, there remain questions surrounding terminology and the collection of data, i.e. what data should be collected and what terms used or not used. We may not be collecting the right kind of data to influence behavioural change, and we need better ways of describing what we are doing, where we are going and how we're going to get there, Smoller said.

More information is available on the MSWG Web site,

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