Pollution Prevention and
Responsible Care® -
Dow’s recipe for Success
Judy Castledine
Director of Environment Health & Safety, Dow Chemical
Pacific Ltd.
Vice Chairman of Association of International Chemical
Manufacturers (AICM)
Chairman of AICM Responsible Care Leadership Team
Abstract
Globally, environmental concerns have become a critical
challenge to the profitability and future viability of companies
in our industries.
It is hard to remember how much things have changed in the last
ten to fifteen years let alone the last thirty. Science and
technology have caused a revolution in the way we do our jobs; but
it is not just science and technology that have changed.
Our global society has changed. We now live in a much more open
society, one which expects to be informed and involved in
decisions affecting its well being.
I agree that public expectations about environmental
performance are far more developed in the U.S., but concerns in
Hong Kong and China are growing and will continue to grow and
accelerate towards the same general expectations as we are
experiencing in the west. In fact public concerns in Hong Kong and
China has clearly increased dramatically in the last decade as
evidenced by increased activity of the government and concerned
citizens.
The tremendous contributions to society made by the chemical
industry such as the control of disease, lower food costs,
improved crop yields and energy savings, are too often forgotten
as society concentrates on real and perceived environmental
problems.
Meeting these challenges will require new strategies, new
systems and new approaches to problem solving. It will mean we
have to combine innovative thinking, consultation and public
accountability, with the desire to balance the realities of today
and the goal of tomorrow.
Responsible Care® and the Chemical Industry
We have to change our performance and the way we appear to the
public. We need to demonstrate that we are socially responsible
and responsive to the needs and concerns of the public and that we
are working hard to protect human health and the environment. We
needed to demonstrate that we are willing to lift the veil of
secrecy and talk to the people about what we are doing and about
the risks associated with our products and processes. It is also
important to talk about the way we manage risks and our unwavering
concern for the health and safety of our employees and the
community. We need to show we are implementing pollution
prevention.
In two words this is the voluntary industry initiative called
“Responsible Care” started by the Canadian
Chemical Producers Association (CCPA). When it was developed in
1985, Responsible Care was the first industrial commitment and
management system of its kind. The CCPA took a real leadership
role in aggressively encouraging other industry sectors and the
chemical industry associations around the world to make a similar
pledge to responsibly manage of chemicals. It has since been
endorsed as the model system for the chemical industry globally
through the International Council of Chemical Associations (ICCA)
and adopted in more than forty countries including Hong Kong,
Indonesia, Thailand, Malaysia to name just a few. The Association
of International Chemical Manufacturers and its members are
actively implementing Responsible Care in Hong Kong and China
Responsible Care is not just some codes; it must become a way
of life or an ethic as well as practices to improve performance on
the road to sustainability.
Responsible Care is the “initiative” by the chemical
industry for the chemical industry. It is designed to meet the
needs for a sustainable industry.
The key objectives of Responsible Care globally are:
- to continuously improve performance in environmental health
and safety
- to help others to improve theirs
- to communicate about our performance, and
- to listen and respond to concerns of the community
We believe the outcome, in the long term, needs to be that we,
the chemical industry are accepted and welcomed by the community
and government as a responsible citizen.
Continuous improvement in EH&S performance is the public
commitment. Accountability is the cornerstone of this commitment.
We must have safe processes and products that are safe to use and
dispose of. We need to embrace the concepts of sustainable
development and contribute to the global attainment of this goal.
We, the industry, and we, individual companies accept that to be
successful we must meet community and government expectation.
Dialogue with community with government and other key stakeholders
is necessary to understand and effectively respond to their
expectations. Lastly, teamwork is the only way forward. Together
we can succeed in earning and retaining the respect of our key
stakeholders.
Responsible Care through its Guiding Principles, Codes and
other features is the unifying ethic and process to ensure that
the activities of the chemical industry meet community
expectations for protection of people and the environment and for
a sustainable industry.
Responsible Care and Pollution Prevention
Let’s take a key topic for China; Pollution Prevention. The
objective of this code is to prevent environmental impact of our
operations through minimization of waste and emissions.
The 14 management practices covers a range of topics and are
listed in attachment 1.
In China, the government has a significant thrust to improve
the quality of the environment and promote cleaner production.
This code of management practices fits really well with this
direction. It requires that companies understand their waste and
emissions, and put in place plans for reduction based on
assessment of risk and community needs. There is a requirement to
consider the waste reduction hierarchy, not just waste treatment.
The waste hierarchy is
- Source reduction, i.e. don’t produce it
- Recycle, reuse
- Waste treatment
- waste disposal
At Dow, pollution prevention was first articulated in 1971 by
Carl Gerstacker, chairman of the Dow Chemical Company. He said,
and I quote:
“I firmly believe
that protecting the environment is good business as well as good
citizenship, and that we ought to look at the opportunity
presented to tighten up our production processes and build up our
profits. There’s a profit opportunity in pollution prevention
that we’ve only just begun to realize.” (end of quote)
It might sound complicated but it simply means making more with
less. We’ve known for a long time that pollution is economically
and environmentally wasteful. It we reduce our waste to the
environment, we can increase our global competitiveness through
greater efficiency. We can increase resource productivity by
significantly reducing our emissions, waste and waste water, and
by using less energy to make our products.
One of the aspects of the pollution prevention code is the
setting of goals to reduce waste and emission. At Dow as part of
our commitment to Responsible Care; aligned with our EH&S
policy and direction, we set goals for many aspects of EH&S.
They can broadly be defined.
Responsibility and Accountability:
To be a responsible corporate citizen; to be open and
responsive to ideas and concerns; to integrate environmental
considerations into our business decisions; to design or modify
our products and processes to minimize their environmental, health
and safety impact, to foster partnerships among key stakeholders
to find practical solutions to challenges; to manage our lands to
protect and enhance wildlife and ecosystems.
Prevent Environment, Health and Safety Incidents:
To value – above all things – the safety of our people and
our communities; to continuously improve Dow’s performance to
protect the environment, health and safety of our workforce,
neighbors and the public; to work with our distributors, customers
and suppliers to continuously improve the way we and they handle,
transport and use our products.
Increase Resource Productivity:
To continue enhance resource productivity to reduce risk,
minimize Dow’s impact on the environment and health and increase
global competitiveness through greater efficiency; to emphasize
pollution prevention in our processes; to transfer and use the
best available technology throughout the Dow world to build the
most environmentally sound and safe facilities.
Further reduce air and water emissions for global
operations:
- Priority compounds by 75 percent
- Chemical emissions by 50 percent
- Reduce the amount of waste and waste water generated per
pound of production by 50 percent
- Reduce energy use per pound of production by 20 percent
Priority compounds include persistent, toxic and
bioaccumulative (PTB) compounds, known human carcinogens, selected
ozone depleting substances, and high-volume toxic compounds.
- Related Goal: Reduce dioxin emissions by 90 percent
by 2005.
The last one of these has the greatest relevance to the
pollution prevention code though all have some impact of achieving
the objectives.
You may be wondering why we distinguish between priority
compounds and other chemical emissions. It’s a matter of risk:
we will invest more resources to reduce emissions of priority
compounds that may pose a higher potential risk to human health or
the environment – a feature of the pollution prevention code.
Perhaps our most challenging goal of all is to reduce waste by
50 percent by 2005. Why is this the most challenging? Because I
can’t tell you today exactly how we’re going to reach the
goal. We need to invest capital, develop technology, and seek
innovation from Dow people to find solutions. I’m confident that
we’ll get there – we have a strong economic incentive.
Today, our wastes cost us about $1 billion a year – money
spent for treatment, disposal, transportation. If we meet our
goal, there is a large potential cost saving for our businesses.
Such reductions will come at a cost, too. Eliminating waste and
emissions will require capital for technology development,
equipment upgrades, and plant modifications.
Another efficiency goal relates to energy use. We plan to
reduce our energy use by 20 percent by 2005. We see a tremendous
cost savings here – reducing energy use will save almost $600
million by 2005.
The new competitive reality drives us to be more productive by
reducing wastes and incidents. We know from experience that it
works. We see tangible proof in our return on capital for many
environmental projects. In our experience, voluntary environmental
improvements return as much as 53 percent on capital, compared to
a negative 16 percent when the improvement are mandated.
This tells us that we need to build a new and efficient
regulatory framework based on performance, and on flexibility
linked to accountability and market incentives. A system with
performance-based objectives would accomplish several things. It
would encourage industry to do what we do best – solve problems
through science and technology using the concepts of the pollution
prevention code, Dow’s WRAP program and our innovation in new
process technology.
In 1986, Dow formalized its waste reduction initiative to
re-emphasize our waste reduction efforts and to chart progress and
future direction in waste reduction. This initiative is called
WRAP, which stands for Waste Reduction Always Pays.
Waste reduction is the cornerstone of Dow's waste management
policy and fits into a number of the management practices in the
Pollution Prevention code. It is primarily targeted at the
existing facilities but is also useful in identifying where we
need to improve our technology for new plants to make them more
environmentally efficient. That's not to say waste will completely
disappear. It's an inevitable part of the manufacturing process.
But through programs such as WRAP, Dow will continually seek out
projects to reduce those waste streams.
The WRAP program has five basic goals:
- To reduce waste to the environment. Continuous improvement
in our processes can reduce emissions and the volume of waste
currently being treated.
- Recognize excellence. Recognizing employee efforts sends a
positive message that reducing waste is a top priority for the
Company. It also motivates and encourages employees to
continue seeking new methods of waste reduction.
- Enhance waste reduction mentality. Because these programs
are employee-driven, awareness of and action toward reducing
waste at its source is promoted throughout the organization.
- Measure and track progress. Waste reduction efforts are
being measured in order to track progress of waste reduction
within each operating division.
- Reduce long-term cost. While all WRAP projects have a
positive impact on the environment, some also have a positive
impact on the Company's bottom line. Many WRAP projects have
led to savings in fuel, raw material and environmental control
costs.
Responsible Care, Pollution Prevention and Dow in China
Dow, in China has implemented Responsible Care pollution
prevention in its businesses and its plant e.g. Tsing Yi, Ningbo
and Zhangjiagang. Dow has shown that Responsible Care, - a concept
born in Canada can be implemented effectively in facilities
throughout the world.
We have found real economic benefits in ensuring we do not
generate waste. At ZJG for example the two plants under
construction do not require a waste water treatment plant since
there is no process waste water generated to be treated. This is a
major capital and operating savings.
The basic philosophy is to build new plants that meet Dow
standards or the country standards whichever is the most stringent
and use the latest and best technology available to the company.
Dow's process technology is one aspect of the "state of
the art" plants built in countries such as Thailand,
Indonesia and China. There are many examples I could give of the
technologies used to reduce waste and emissions in these new
plant; some are new and had not been used elsewhere in Dow.
Some examples:
- computer controlled plants to reduce potential for incidents
and improve productivity and resource conservation
- re-designed reactor system to eliminate the vent system
- vent incineration
- process vent recovery
- roofing to eliminate rainwater in process areas
- solid and liquid waste incineration
- double mechanical seal or sealless pumps on all hazardous
materials
These are just a few examples. One of our achievements has been
that as we have built new plants, we have challenged the need to
install treatment systems for waste water. An example of this is
our site in Thailand at Map-Ta-Phut. It has no central treatment
facility except for sewage, and no process waste water discharge.
We are following a similar strategy for ZJG
Are there challenges or barriers to building these plants? Yes,
there are. The key one is the capital cost of the facility vs. the
competitor. There is no doubt these aspects added to the capital
costs. However it is not incremental as there are savings from not
building treatment facilities. But the larger saving is on
"the long term cost of ownership", i.e. reduced
operating costs and potential future liabilities. This does
require management commitment and a long term view of your
investment.
However, the challenge doesn't end with building clean plants;
we must also operate and maintain them.
It is important that this aspect be considered at the design
stages. If not, there may be no support for the technologies
installed, e.g. maintenance and spare parts.
This may mean you need to supply your own infrastructure or
support a local company to improve their systems. At Dow we use
both methods. In one country we have "partnered" with a
local company to transport our raw materials and products. We
supplied the technology to the company to ensure distribution
safety.
Of equal importance are the people you hire. In many Asia
Pacific countries the general level of EH&S awareness and
experience in the chemical industry is low. This has meant that
hiring needs to be done early (and well); not only for engineers
and managers but also support staff and operators and then train,
train, train. For many key jobs, overseas experience has been part
of the development of the employees. This overseas experience is
not just on technology but includes environment health and safety
aspects. For ZJG we have a number of engineers overseas on
training.
These employees with overseas experience bring back with them
the culture of the company - helping Dow to integrate EH&S
into everyone's job.
The training of the operators and support staff is also
critical. Through the Dow system, classroom and simulation
training is provided to all operations employees to ensure
readiness prior to start up. We have already hired the operators
and put them through extensive training sessions and we won’t
start up till next year!
Conclusion
Clean technology plants can be built and operated in China.
Dow's and other companies' experiences have proven this. Yes,
there are some challenges such as infrastructure and availability
of experienced people. But it can be done.
What is needed to ensure our future is a concerted effort by
the industry as a whole to accept that environmental protection,
cleaner production and ultimately sustainable development is our
issue for the new millennium. Dow has shown this is a recipe for
success. Together in partnership we can promote the implementation
of pollution prevention while working towards sustainable
development.
Attachment 1 - Pollution Prevention Code based
on American Chemical Council Code
- Management Commitment
- Waste Emission Inventory
- Reduction Prioritization
- Education and Dialogue
- Reduction Plans
- Waste Management Hierarchy
- Progress Measurement
- Progress Communication
- Management of Change
- Community and Industry Outreach
- Periodic Review
- Contractor Manufacture
- Groundwater Protection
- Past Practices
Responsible Care® -- Service
Mark of the International Council of Chemical Associations |
