Measuring the integration of pollution prevention into PADEP's Bureau of Air Quality field force activities
In the late 1980s, environmental professionals realized that environmental protection had come to depend on a reactive, end-of-pipe control mentality. This is especially prevalent in regulations addressing air pollution. A new concept came to the forefront, pollution prevention, a basic idea of preventing or eliminating wastes and pollutants at the point where they originate instead of trying to control them or reduce their negative impacts. Due to its prevalence in field usage, the term "pollution prevention", and its acronym "PT" are used throughout this thesis to convey the same meaning as source reduction, the term found in the Pollution Prevention Act of 1990, where Congress declares as a national policy that pollution of all types, not just hazardous, should be "...prevented or reduced at the source whenever feasible..."1.
The new environmental paradigm represented by pollution prevention has been difficult to implement at the regulatory level. There are hundreds of case studies in the pollution prevention literature dealing with implementation actions at individual companies, but little guidance to help a state environmental agency integrate pollution prevention efforts into their regulatory functions. Since 1996, attempts have been made to integrate the concept of pollution prevention into PADEP's Bureau of Air Quality (BAQ) routine regulatory and enforcement functions.
No administrative tool had been developed until now to measure the degree of success in achieving this goal. This research defines the present level of integration through analysis of a questionnaire given to Bureau of Air Quality field force personnel who have routine, direct contact with regulated facilities, AQ Specialists, AQ Field Supervisors, and AQ Permitting Engineers. The survey was conducted among personnel holding these positions at the regional offices only. The survey is the first which aims to develop baseline data to measure future use of pollution prevention strategies by the BAQ field force as integration efforts develop.
A total of 57 respondents, representing 36.3 per cent of the studied field force returned the survey form. Survey analysis shows that pollution prevention education is reaching at least part of the target audience. The correct definition of pollution prevention, the elimination of pollution in-process, is known by 86.3 per cent of the population studied. Still, 69.1 per cent of all respondents either "never" or only "sometimes" initiate P2 discussions with facilities they inspect. Based on the yearly number of inspections conducted by the field force, about 3,261 opportunities to promote pollution prevention are lost yearly due to their failure to initiate the discussion. In addition, few regulated facilities are being referred by the field force to program areas of PADEP dedicated to pollution prevention, whether OPPCA and BAQ CAPP or to outside sources of information such as ETAC. If pollution prevention is to be adopted widely, the field force must promote the idea by initiating the issue more often with the regulated community.
1U.S. Congress, Pollution Prevention Act of 1990, Chapter 133, Section 13101(b), accessed 2 May 2002, available from http://www4.law.cornell.edu/uscode/4213101.html