Chapter 3 – How to Write a Pollution Prevention Plan
Step Four: Determine and Analyze Alternatives
Once there is a good baseline of how the present processes generate waste or pollution and how much it costs, options for reducing these may be explored. The analysis of these options can be done concurrently with the gathering and analysis of the data, but a meaningful options analysis will need the data analysis done and a baseline determined before the options can be effectively screened.
Options analysis is the heart of the pollution prevention planning process. All other steps and all benefits will be affected by how well this step is done.
Options analysis should include an examination of all the methods of pollution prevention covered in Chapter 2: Looking at substitutes for the chemical, how the chemical moves through the manufacturing system, how a process is performed, automation and alternative technologies for the manufacture of the product.
This analysis may also include developing criteria for determining which alternatives may be implemented. These will depend on the culture of the company and other factors. However, some tangible factors to consider are how much an alternative will reduce Form R reporting requirements, how much an alternative will reduce hazardous waste generation and the return on investment for a project. Other considerations include compatibility of the pollution prevention option with the current manufacturing process, ability to maintain product quality requirements and storage or process layout considerations.
Just like costs associated with current manufacturing processes that are determined in the baseline research, costs will be associated with each pollution prevention idea and should be considered during options analysis. Among these include costs for design, testing and implementation. These should be weighed against the savings that would result if the option is selected. Savings can come from reductions in chemical purchases, compliance costs and disposal costs. Changes in labor cost should also be taken into account.
Tap all the available public and private resources for information on alternatives and how they meet your criteria. These include technical assistance sources such as the Minnesota Technical Assistance Program (MnTAP), the Minnesota Pollution Control Agency (MPCA), trade/professional groups, trade publications and vendors. In addition, regulatory agencies can help determine how alternatives may impact compliance and fees.
After a complete options analysis, the option(s) that meet the criteria for acceptance should get a final verification for feasibility. The reasons that the other options were not selected should be obvious at the conclusion of the analysis. Each step of the options analysis needs to be documented, including whether options are rejected on technical or economic grounds. By maintaining records of all options that have been explored and why some were rejected, it will be easier to revisit these should future developments warrant further consideration.