Chapter 3

Chapter 3 – How to Write a Pollution Prevention Plan

Who is Required to Write a Plan

The 1990 Minnesota Toxic Pollution Prevention Act (TPPA) provides a definition for pollution prevention and also establishes a requirement for certain industrial facilities in Minnesota to prepare toxic pollution prevention plans. In addition to preparing pollution prevention plans, facility managers are required to submit annual reports detailing progress of their facilities’ pollution prevention efforts. Pollution prevention plans are required for all Minnesota facilities that are required to submit Form R reports for Toxic Release Inventory (TRI) chemicals under the state and Federal Emergency Planning and Community Right-to-Know Act (EPCRA).

If you have questions about whether your facility is required to prepare a pollution prevention plan, please contact the Minnesota Emergency Planning and Community Right-to-Know Act (EPCRA) Program online or at 651-201-7417.

Pollution prevention plans are also required of companies participating in the MPCA Environmental Audit Program. For more information, call the Minnesota Pollution Control Agency (MPCA) at 651-296-6300 or visit them online.

Basic Requirements of a Plan

Required contents of pollution prevention plans include:

  • policy statement expressing management support for eliminating or reducing the generation or release of toxic chemicals (pollutants) at the facility.
  • A description of the current processes generating or releasing toxic chemicals that specifically describe the types, sources, and quantities of toxic chemicals currently being generated or released by the facility.
  • A description of the current and past practices used to eliminate or reduce the generation or release of toxic pollutants at the facility and an evaluation of the effectiveness of these practices.
  • An assessment of the technically and economically practicable options available to eliminate or reduce the generation or release of toxic chemicals at the facility, including options such as changing the raw materials, operating techniques, equipment and technology; personnel training; and other practices used at the facility.
  • statement of objectives and a schedule for achieving those objectives. The TPPA requires companies to express objectives in numeric terms wherever technically and economically feasible. Otherwise, non-numeric objectives can be stated; however, they must include a clearly stated list of actions designed to lead to establishing numeric objectives as soon as they become feasible. Facility pollution prevention plans must contain objectives for each chemical for which a facility submits a TRI Form R report. Pollution prevention plans may also contain objectives for other chemicals as well.
  • An explanation of the rationale for each objective established for the facility.
  • listing of options that were considered not to be economically and technically feasible.
  • certification, signed and dated by the facility manager and an officer of the company, attesting to the accuracy of the information in the plan.

Pollution prevention plans are required to be updated by January 1 of every even numbered year.