Vol. 13 No. 3 Fall 2003

THE NORTHEAST WASTE MANAGEMENT OFFICIALS' ASSOCIATION (NEWMOA) NEWMOA is a non-profit, non-partisan interstate governmental association. The membership is composed of state environmental agency directors of the pollution prevention, hazardous and solid waste, and waste site cleanup programs in Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont. NEWMOA’s mission is to develop and sustain an effective partnership of states to explore, develop, promote, and implement environmentally sound solutions for the reduction and management of materials and waste, and for the remediation of contaminated sites, in order to achieve a clean and healthy environment. The group fulfills this mission by providing a variety of support services that facilitate communication and cooperation among member states and between states and EPA. NEWMOA's P2 program was established in 1989 to enhance the capabilities of the state and local environmental officials in the northeast to implement effective source reduction programs. The program is called the Northeast States Pollution Prevention Roundtable (NE P2 Roundtable). This program involves the following components: (1) NE P2 Roundtable meetings and workgroups; (2) regional P2 information resource center and databases of information; (3) source reduction research and publications; (4) training sessions; and (5) regional policy coordination and development.

Managing a hotel or related lodging establishment is an art and a science. It requires an ability to balance cost, convenience, and customer satisfaction, and the most minor decisions often require precise planning to ensure the desired outcome. Experience has shown that economics and common sense often drive innkeepers to adopt pollution prevention and resource conservation strategies in order to improve both their economic and environmental performance. Take, as examples of pollution prevention, the use of soap dispensers, towels and linens upon request, hand dryers (versus paper), occupancy sensors, or automatic delivery of newspapers to rooms. Each has a potential environmental benefit, but in the lodging industry the impacts upon the guests, staff, and the facility's reputation and coverage in the media are the central concern. Arguing cost savings with lodging managers also involves an understanding of customer service.

A national nonprofit organization called Green Seal has developed an initiative, starting in 1995 to establish standards and a national certification program for the lodging industry. They began a pilot program in Pennsylvania and are working with hotels there to achieve certification. Other states with Green Seal certified hotels include Arizona, Utah, and Wyoming, and Washington, DC. The Green Seal standards are based on major categories for environmental requirements, waste minimization, water and energy efficiency, hazardous substances handling, and environmentally preferable purchasing. Under each heading there are specific standards that a property must be in compliance with to pass an inspection to become Green Seal Certified.

Called "Vacationland," Maine is a destination for many travelers. A report published by the Maine State Planning Office identifies tourism as the largest industry in Maine. According to the Maine Office of Tourism, there are over 1200 lodging properties in the state. In 1998 out-of-state overnight visitors spent $1.8 billion, and an estimated 8.6 million overnight trips were taken in Maine, which is an increase of 4 percent from 1997. In 2000, overnight visitors in Maine spent $2.2 billion, and accommodations accounted for 13 percent of the total spending.

The number of tourists visiting Maine has grown over the past few years and with each additional overnight stay the potential environmental impact of tourism increases. With more and more visitors in Maine, it would be beneficial to work with the hospitality sector to reduce the environmental impact of its operations. Maine would be better prepared to handle increased growth in the future and avoid the negative impacts of more visitors.

Currently, Maine DEP is considering implementing a lodging certification program. The steps that are being considered for implementation of the program are:

• Research the hospitality sector and determine best management practices for waste minimization, water and energy efficiency, cleaners and other chemicals, and environmentally preferable purchasing.
• Develop standards for a two tiered green certification based on best management practices.
• Contact lodging properties through trade organizations, such as the Maine Innkeepers Association, and partner with other government agencies, such as the Maine Office of Tourism, and the State Planning Office.
• Seek governor sponsorship of the program.
• Determine two or three industry leaders with environmental programs already in place willing to be models and mentors for others in the program. The Colony Hotel in Kennebunkport has already won numerous environmental awards.
• Conduct environmental assessments of lodging properties, including energy audits and waste stream analysis.
• Work with properties on project implementation.
• Conduct a certification evaluation for lodging properties that have completed eight environmental projects.

As part of their daily operations, New Hampshire's top Hotels will soon clean more than their facilities—they will also help clean up the environment. Developed in collaboration with Public Service of New Hampshire (PSNH) and the New Hampshire Department of Environmental Services (NH DES), the New Hampshire Lodging and Restaurant Association's (NHLRA) Sustainable Lodging Program (SLP) will teach Granite State lodging properties how to save energy, conserve water, and reduce waste at their facilities. The NHLRA has been particularly helpful because it represents and understands the lodging industry better than any other organization in New Hampshire.

The SLP brings experts on-site to lodging establishments for multi-media audits of waste generation, water and energy use, and recommends improvements that take into account the conditions at the site. The water audits focus on room faucets and water fixtures (for compliance with federal guidelines), as well as landscaping irrigation practices or equipment. Waste audit reviews tend to focus on reducing waste generation and extracting recyclable and reusable materials from the waste streams, looking at possible markets for materials, and handling storage/transportation logistics.

Tourism is currently the world's largest industry and, if current trends continue, travel and tourism will soon be the largest industry in Vermont. Lodging is an important segment of this growing industry, providing tremendous diversity and stability to the state's economy. This sector of the economy, more than most, however, is highly dependent upon a clean and scenic environment. This is the magnet attracting many visitors to Vermont—and keeps them coming back. The lodging industry in Vermont, with nearly 20,000 guest rooms, strives to be one of the greenest.

The Vermont Business Environmental Partnership is a voluntary, environmental assistance and business recognition program offered by the Vermont Agency of Natural Resources (ANR) and the Vermont Small Business Development Center (SBDC). The Partnership joins efforts of the public and private sectors to achieve environmental and economic goals simultaneously.

The Vermont Business Environmental Partnership recognizes Vermont innkeepers as Environmental Partners when they achieve a set of core environmental standards and six elective standards. Once Environmental Partner status is attained, those wishing even greater recognition can satisfy additional, more rigorous standards to have their properties designated as a "Green Hotel in the Green Mountain State." Although each property achieves program standards uniquely, each conducts an environmental opportunity assessment, adopts environmentally preferable practices, and develops an environmental management plan that guides its efforts to continually reduce the environmental consequences of its operations. The journey toward designation as a Green Hotel in the Green Mountain State typically begins years before a phone call is received at either ANR or the SBDC.

Upon initial contact with a facility the Partnership staff schedule an environmental opportunity assessment. The assessment serves to highlight best management practices already evidenced and, more importantly, to suggest additional strategies and practices in areas such as:

• environmentally preferable purchasing
• waste prevention and reuse
• recycling and composting
• resource conservation (i.e., energy and water)

By taking credit for prior environmental initiatives and by adopting new strategies suggested in the assessment, a property gets recognized as an Environmental Partner. Leveraging its past success into the future, by developing a comprehensive environmental management plan and agreeing to host an educational event, allows a property to be designated as a Green Hotel in the Green Mountain State. Innkeepers are recognized by the Governor at a State House ceremony, their property gets listed on a promotional card distributed at each of the gateway rest areas in Vermont, and the Partnership maintains a website designed to laude the property's successes and to promote their patronage. Program participants complete performance reports annually.

Green Hotels in Vermont in aggregate have:

• computerized energy management systems
• adopted linen and towel reuse programs
• installed energy and water conservation devices and fixtures
• reduced packaging waste by using bulk purchasing
• switched to non-toxic cleaning supplies
• composted organic waste
• converted to renewable energy sources
• educated guests as to how they can contribute to environmental initiatives
• substituted bulk amenity dispensers for single-use plastic amenity bottles
• eliminated the use of chlorine bleach by finding alternative disinfectants
• engineered systems to recapture waste heat

Today, there are more than fifty Program Partners, of whom more than thirty have had their properties designated as Green Hotels in the Green Mountain State. The following is excerpted from the Strategic Environmental Management Plan of the Blueberry Hill Inn, in Goshen, Vermont. The sentiments expressed epitomize the heartfelt passion many proprietors in the Program bring to their businesses:

"...we are committed to environmental improvements within both our business and our lives. We strive to create an environment that makes it possible for all to participate - staff and guests alike. We will continue to scrutinize every area of our operations to find ways to minimize our impact on the earth. We will seek to find ways to educate others, and remind ourselves that every little bit helps, no matter how small the offering. We will strive to continually make a difference—while simultaneously maintaining our commitment to provide our guests the quality service they expect and deserve."

EPA manages programs that provide support in the areas of energy efficiency, environmentally preferable purchasing, solid waste reduction, water conservation, and indoor air quality that are targeted toward the hospitality sector and others.

Feature Article: PBDEs—a Class of BFRs under Fire

by Elizabeth Harriman,
Deputy Director, MA Toxics Use Reduction Institute

Flame Retardants

Polybrominated biphenyl ethers (PBDEs) are a class of brominated flame retardants (BFRs) used in many different combustible materials to ensure fire safety. Flame-retardants are used to slow the spread of an accidental fire and reduce the amount of heat and smoke released. One of the key properties of flame-retardants is to be self-extinguishing once the source of ignition has been removed.

There are three primary classes of flame-retardants:

1. halogenated compounds
2. inorganic compounds (including antimony)
3. phosphorus compounds

Chemically acting flame-retardants (such as the halogenated bromine and chlorine systems) are very effective. Common brominated flame retardants include PBDEs, hexabromocyclododecane (HBCD), and tetrabromobisphenol A (TBBPA). Some BFRs are used as "reactive" and some are "additive." A reactive flame retardant, for example, TBBPA, is reacted into the polymer matrix and is considered to be less apt to migrate out. An additive flame retardant is compounded into the polymer.

Physically-acting inorganic flame-retardants based on metal hydroxides and salts have a weaker effect (e.g., alumina trihydrate, magnesium hydroxide, boron-containing compounds). The performance of primary flame-retardants such as chlorine, bromine, and phosphorous is enhanced by additives such as antimony, zinc, and other metal salts. Antimony oxide is typically used in flexible PVC products. The range of phosphorous-containing flame-retardants is very wide and includes phosphates, phosphate esters, and elemental red phosphorus. Often the phosphorus compounds also contain halogens, which increase the effectiveness of the flame-retardant.

Polybrominated Biphenyl Ethers (PBDEs)

PBDE's are a class of chemical compounds in which up to 10 bromine atoms are attached to a diphenyl ether molecule. There are 209 different possible compounds, called "congeners," depending on the number and position of the bromine atoms. These congeners are grouped according to the number of bromines, for example, the penta-BDE shown here has five bromine atoms.

There are three different commercially available PBDEs: penta-, octa-, and deca-BDE. Each is a mixture of different congeners, for example the penta product is a mixture of 40 percent tetra-BDE, 45 percent penta-BDE, and 6 percent hexa-BDE. The octa product has a wide variation from hexa to nona, and the deca product, which is the most widely used PBDE product, is approximately 97 percent deca.

Uses of PBDEs

PBDEs are used in a wide variety of products. Penta-BDE is used primarily in polyurethane foams, for end uses such as upholstered furniture and automobile seat cushions. Deca-BDE, and to a lesser extent octa, are used in plastics, rubbers and textiles, for end uses such as electronics enclosures and coated wire and cable. World demand for the principal commercial BFRs is shown below.

In Massachusetts, approximately 2.4 million pounds of deca-BDE was reported as used by 16 companies for the year 2000. Approximately 600,000 pounds was used in textile coatings, 400,000 pounds in wire and cable coatings, and the remainder in various plastics and rubbers. Of the 2.4 million pounds used, 2.3 million pounds were shipped as product, only 371 pounds were reported as released to the environment, and only 96,000 pounds were reported as byproduct. Deca-BDE is the only PBDE compound that is reportable under TURA.

Environmental Health & Safety Issues

The discovery of toxicological and eco-toxicological characteristics of PBDEs has been accompanied by studies demonstrating their growing accumulation in the environment—in sediments, water, indoor air, biota, and humans.

The human health effects of PBDEs have not been studied thoroughly. Most research shows deca to be less bioavailable than the lower BDE congeners. The most data exists for penta, where evidence points to adverse effects on the liver and thyroid as well as neuro-developmental effects. In general, PBDEs are not considered carcinogenic, although limited animal testing shows deca to be carcinogenic in male mice at extremely high doses.

Numerous studies have documented increasing levels of total PBDEs in humans, animals, and the environment. Where individual congeners have been measured tetra and penta forms dominate; they are persisting in the environment, and bioaccumulating up the food chain. Although deca has been shown to be persistent, it is not found in the environment in quantities proportional to its much higher use. One possibility, supported by limited studies on photolysis and degradation in fish, is that deca de-brominates under some conditions to penta and tetra. Other possible explanations are that researchers have not been testing adequately for deca or that deca degrades into other substances. Clearly, there is a lack of understanding of the fate and transport of PBDEs.

US & International Materials Restrictions on PBDEs

The European Union has already acted to restrict the manufacture and sale of certain PBDEs. In response to recently completed risk assessments, the EU has approved a phase-out of penta and octa-BDE in all products as of August 2004. Because many countries in Europe began phasing-out penta in the 1990s, there is very little use at present. In addition, as part of the EU's Waste Electronic and Electrical Equipment Directive (WEEE) and its companion Restriction on the Use of Certain Hazardous Substances Directive (RoHS), all PBDEs will be phased-out in those products as of 2006. While the EU risk assessments for penta and octa have been finalized and have recommended phase-out, there are still unresolved questions with the deca risk assessment. The RoHS Directive defaults to phasing-out deca, but states that it is a priority to review deca based on the final risk assessment conclusions.

The only phase-out legislation in the US is the California Assembly Bill 302 that was passed in August of 2003 and will take effect in January of 2008. The bill prohibits the use, sale, and manufacturing of penta- and octa-BDE in California.

Many voluntary efforts in the US by EPA, states, and manufacturers are underway to seek safer alternatives to PBDEs, and the pressure from environmental groups for action is increasing. EPA just announced on November 3, 2003 that Great Lakes Chemical had agreed to phase- out penta and octa by the end of 2004. This turn of events was likely precipitated both by Great Lakes' development of an alternative flame retardant, and by a recent report by the Environmental Working Group showing more evidence of these substances in San Francisco Bay fish and breast milk. Among other voluntary efforts: EPA Region IX has initiated stakeholder dialogues, EPA has included PBDEs in the High Production Volume (HPV) evaluation and testing programs, the Massachusetts Toxics Use Reduction Institute is working with the coated wire and cable supply chain on safer alternative materials, and a new, multi-stakeholder "International Consortium for Fire Safety, Health and the Environment" has been formed to work together toward these common goals.

Conclusion

While flame retardants, including PBDEs, save lives in the short run by contributing to fire safety, an increasing body of evidence indicates that at least some of these compounds are persistent and bioaccumulative, with serious concerns about toxicity. As Europe moves forward to phase-out their use, U.S. and multi-national companies are setting goals to eliminate PBDEs from their products. Suppliers must be able to provide new, innovative, and safer flame retardant products in order to stay competitive in the global marketplace. These actions will ultimately begin to reverse the disturbing trends of PBDE accumulation in the environment.

Web Resources

This section of the NE States P2 News lists useful web resources that are focused on the topics of the Feature Articles.

HOSPITALITY

P2Rx™ Hospitality Topic Hub™

CONNECTICUT

Connecticut DEP

In light of recent staffing losses and budget cuts, Commissioner Arthur Rocque, Jr. has asked CT DEP managers and staff to consider the Department's existing structure and evaluate other potential organizational structures. The goal of the analysis is to provide the Commissioner with options to create a flexible agency that can maximize its resources and continually assess, revise, and update the priorities and strategies to achieve its mission today as well as address future challenges and opportunities. As an interim step, the decision was made to integrate staff from the Pollution Prevention office with the staff in the Ombudsman's Office. The new, centrally located group will focus on the agency-wide strategic priority of environmental stewardship as outlined in the Department's Environmental Quality Branch Strategic Plan of FY 2002-2007.

CT DEP is an active member of the Bike to Work - Capitol Region Program. Just finishing their fourth season, this group is headed by the Capitol Region Council of Governments (CRCOG). A "Bike to Work" event, including free breakfast, is held on the last Friday of each month from April through October. Benefits include energy savings, emission reductions, air quality improvements, and reduced traffic. The program chooses a monthly "Super Commuter" - a person who has shown a real commitment to bike commuting, illustrated by the frequency and length of their commute, commitment regardless of the weather, and their ability to encourage others to commute via bicycle. The group also works with the state DOT and area towns to improve access and safety for bicycle commuters.

The Offices of Pollution Prevention and Recycling participated in the Connecticut Council of Municipalities (CCM) annual convention on October 9 in Cromwell, CT. The theme of the convention was "Local Governments: New Challenges, New Solutions." The event attracted hundreds of municipal officials, students, and exhibitors. The DEP display showcased two cost-saving programs for municipalities: Implementing Pay-As-You-Throw (PAYT) (unit pricing for solid waste management) and Best Management Practices for Vehicle Maintenance and Repair (highlighting the newly revised, but not yet finalized, Pit Stops Fact Sheets). DEP staff was available throughout the day long event to talk to municipal officials about these programs. There was significant interest in the Pit Stops fact sheets. However, although officials think that PAYT makes sense, few in the state are willing to commit to it because of public resistance.

Connecticut DEP and Hartford neighborhood groups co-sponsored a series entitled "Smart Growth Training for Hartford Neighborhoods" in 2003. At the first session, a land-use expert talked about sprawl and smarter growth in Connecticut and illustrated how smart growth principles promote a more livable urban community while protecting Connecticut's open space. The program opened with a smart growth quiz show, "Who Wants to be a Millionaire?"

The second program in the series featured a role-play in which the stakeholders in a development dispute presented their case in a mediation session and the audience determined the outcome of the mediation. Using a "Smart Growth Scorecard" participants played the jury to determine the best way to develop the proposed site. Workshops on reading site plans, designing better parking and changing local zoning concluded the program.

For more information contact: Mary Sherwin, CT DEP (860) 424-3246.

In response to numerous requests for information on this topic, the CT DEP developed a web page on environmentally-preferable alternatives to toxic household products. The web page shows a cut-away of a house and gives corresponding green "recipes" for each room. To further promote use of these make-your-own alternatives, P2 staff has put on demonstrations at various venues, including health and wellness seminars, cable TV shows, and fairs. Usually a very dirty window is brought along to demonstrate how effective the alternative glass cleaner is and a raffle is held for a caddy containing the "ingredients" needed to make the basic green cleaners.

MAINE

Maine DEP

Current activities of the Pollution Prevention Program in Maine DEP's Office of Innovation and Assistance include:

• Hosted the annual Multi-State Work Group meeting.
• Unveiled a new P2 web site and held a P2 demonstration day for DEP employees for P2 week.
• Continued to provide on-site assistance to auto salvage and auto repair facilities.
• Provided outreach and assistance to small business development centers and small business counselors.
• Established further partnerships with business assistance providers.
• Established partnerships within the energy efficiency sector and promoted their services to Maine businesses.
• Assisted three companies with the implementation of an environmental management system.
• Conducted onsite compliance assistance utilizing Maine's Small Business Compliance Incentive Policy (SBCIP).
• Continued to provide assistance to the Green Campus Consortium in their efforts to move towards sustainability.
• Worked in conjunction with the Climate Change Steering Committee on the New England Governors' and Eastern Canadian Premiers' initiative to reduce green house gas levels 10 percent under 1990 levels by 2012.
• Continued to provide assistance to a number of industry sectors.
• Revitalized the Compliance Advisory Panel (CAP) as an effective tool to weigh in on OIA activities.
• Attended EPA P2 planning training in Boston.
• Attended Audubon International's Golf Course Planning workshop.
• Attending monthly EPA EMS training.
• Attended Iowa Waste Reduction Center's controlled spay BETA training.

MASSACHUSETTS

Massachusetts OTA

Innovative Manufacturing Workshop

On October 23, 2003, OTA co-sponsored a workshop that highlighted new technologies and approaches that enable "Green and Clean" processes yielding environmental and economic benefits. Secretary of Environmental Affairs Ellen Roy Herzfelder welcomed the 61 attendees from industry and state government. Dr. John Warner was the key note speaker during the luncheon program and spoke about green chemistry to an audience that not only included the workshop attendees but over 25 students from local Worcester high schools. Afterward, the participants and students explored displays of Massachusetts industries that have successfully reduced or eliminated toxics or water use in their processes.

On October 2, 2003, Environmental Affairs Acting Undersecretary Gary Moran and Massachusetts Office of Technical Assistance Director Paul Richard presided over a ribbon-cutting ceremony at Bay Path Regional Vocational Technical School in Charlton, MA for the opening of the first Massachusetts Spray Technique and Analysis Research (STAR) training Center.

The MA OTA established the STAR training center, in cooperation with Bay Path Regional, with a $52,000 grant from the U.S. Environmental Protection Agency that will work to improve manual spray-painting operations, thereby reducing health risks and environmental impacts. The program, originally developed by the Iowa Waste Reduction Center, is directed towards automotive technicians, industrial painters, and students studying to become spray technicians. Participants experience individual, hands-on training using a laser-guided spray gun that optimizes transfer efficiency and reduces overspray, thus reducing pollution and paint waste.

As part of the grant requirements a total of ten business professionals will be trained in this new technology. So far, five spray technicians have been trained from the following Massachusetts companies: Central Coating in West Boylston, Doranco Inc. in Mansfield, Eastern Etching and Manufacturing Inc. in Chicopee, General Dynamics C4 Systems in Taunton, and L & J of New England in Worcester.

On Friday, June 13, 2003, at Natick High School, Environmental Affairs Assistant Secretary Gina McCarthy, Director of the Massachusetts Office of Technical Assistance Paul Richard, and Natick School Superintendent Jim Connolly recognized The Boston Scientific Corporation for its participation in the Massachusetts Mentoring Program for School Environmental Safety and Health. The Massachusetts Mentoring Program for School Environmental Safety and Health brings industry expertise into local schools to create safer learning environments for students.

Boston Scientific has worked with members of Natick High School's Science Department to train teachers in the safe handling of chemicals in classrooms, preparation rooms, and chemicals storage areas. Boston Scientific and Natick High continue to work together to develop further safety initiatives.

The Mentoring Program has received requests to participate in the program from the following 13 public high schools: Amherst-Pelham, Attleboro, Chicopee, Dedham, Haverill, Lee, Longmeadow, Natick, Narragansett Regional, Oakmont Regional, Quincy, Revere, Springfield, and Wayland. Nine of these communities have been matched with business mentors.

Since the Toxics Use Reduction Act (TURA) became law in 1989, major chemical-using facilities in Massachusetts have dramatically reduced their reliance on toxic chemicals, making Massachusetts a national leader in cutting toxics use and waste.

Over the summer, the MA DEP issued its annual report for 2001 on the use of toxic chemicals in Massachusetts. DEP has been tracking a core group of 323 facilities that have been subject to TURA reporting requirements since the base year of 1990. Between then and 2001, those facilities have reduced:

• Toxic byproducts by 69 percent,
• Toxic chemical use by 45 percent,
• Quantities of toxics shipped in product by 60 percent,
• On-site releases of toxics to the environment by 92 percent, and
• Transfers of toxics off-site for further waste management by 58 percent.

In 2001, the core group used 583 million pounds or 53 percent of the 1.1 billion pounds of toxic chemicals reported statewide, excluding trade secret data. All told, 676 facilities reported using 192 TURA-listed toxic substances in 2001. These facilities fell within specific standard industrial classification (SIC) codes, had ten or more full-time employees, and used listed toxic substances at or above reporting thresholds. All facilities combined reported that they:

• Used nearly 1.3 billion pounds of toxic substances (down from 1.4 billion pounds in 2000),
• Generated 113 million pounds of byproduct or waste (down from 128 million pounds),
• Shipped 377 million pounds of toxics in or as products (down from 424 million pounds),
• Released 9 million pounds of toxics to the environment (down from 11 million pounds), and
• Transferred 35 million pounds of toxics off-site for further waste management (down from 42 million pounds).

The 2001 report contains data on persistent bioaccumulative toxic (PBT) chemicals, such as polycyclic aromatic compounds, mercury, dioxins, and polychlorinated biphenyls (PCBs), reportable since 2000. PBT chemicals are of special concern because they are highly toxic and remain in the environment for long periods of time, are not readily destroyed, and build up in the food chain. Most of the PBT use reported for 2001 was attributable to impurities in materials used, such as polycyclic aromatic compounds contained in fuel oils.

Effective with reporting year 2001, lead and lead compounds were classified as PBTs, and the reporting thresholds were lowered to 100 pounds. Due to the lower reporting threshold for lead and lead compounds, the number of facilities filing for lead increased from 15 to 135, and the number filing for lead compounds increased from 32 to 115.

Bunzl Extrusion of Northborough, MA, produces extruded medical tubing. The company used the lubricating solvent isopropyl alcohol in its cutting and packaging operations, thereby producing emissions of volatile organic compounds (VOCs). DEP discovered that the facility was emitting VOCs in excess of 10 tons per year without a permit.

Under a consent agreement with DEP and a plan approval from the Agency, Bunzl incorporated policies restricting the use of isopropyl alcohol into its ISO 14001 program to reduce and control emissions. The plan included new technology (a new "chiller") and employee incentives that reduced actual solvent emissions from 10 tons per year in 2001 to approximately 4 tons this year.

For additional information contact: Patricia Arp, MA DEP (508) 767-2771.

Dr. Mike Ellenbecker has been named the new Director of the Institute. Ellenbecker was instrumental in writing the legislation to establish the TURA program in 1989 with Dr. Ken Geiser and has served as deputy director since its inception. He is a full professor in the Work Environment Department at the University of Massachusetts Lowell. Liz Harriman has been appointed the new deputy director, promoted from associate director of research. Former director Geiser will chair the Institute's Advisory Board, and is accepting new responsibilities assisting the University's research programs.

During the last four years, the Toxics Use Reduction Institute's Environmental Management Systems Peer Mentoring Work Groups have been extremely successful helping industries from all sectors and of all sizes develop site-specific and highly effective Environmental Management Systems (EMSs). Millipore has been selected as this year's host facility due to its strong corporate culture of environmental stewardship and social responsibility. Several Millipore facilities have already developed EMSs that have been certified under the ISO 14001 standard. Millipore has committed to attaining ISO 14001 certification for its Massachusetts facilities by 2005. EMS Peer Mentoring Work Group meetings will be held at Millipore's corporate office in Billerica. The deadline for applying to be part of the Work Group is November 21.

The TUR Planner Continuing Education Conference on November 18 in Marlborough will offer planners and others interested in reducing toxics four very different topics. At the first of two morning sessions, participants will learn about the effect of international materials restrictions on the electronics and electrical equipment industry and how this $181 billion industry sector is responding. Concurrently, three panelists will discuss how to achieve effective, value-added implementation of an EMS to create monetary and stakeholder value. In the afternoon, Dr. Robert E. Burr, distinguished physician and toxicologist, will take a look at how the so-called "high priority substances" affect the body. Meanwhile, the other afternoon session will cover non-production TUR, illustrating how innovative toxics use reduction strategies have been developed for practicing TUR in municipal buildings (e.g. schools), small businesses, and homes.

General Dynamics, the newest member of the Massachusetts Lead-Free Electronics Consortium, will host the next Lead-Free Electronics Supply Chain Meeting at their facility in Taunton on December 3. Topics will include additional discussion and updates materials declarations, legislative updates, and the latest research and testing results of lead-free solder alloys. The meeting will feature a tour of the General Dynamics facility.

Many Massachusetts companies were required to report for the first time in 2002 or 2003 on their use of such persistent, bioaccumulative, and toxic substances as lead as a result of lower reporting thresholds. Those same companies will also be required to complete a Toxics Use Reduction (TUR) Plan by July 1, 2004. TURI is offering a one-day workshop that covers the essential basics of TUR Planning on December 16 in Marlborough. It is intended for companies that intend to hire an outside, certified TUR Planner to complete and certify their plans, in order to help them understand the planning process and their on-going planning requirements. But it is also appropriate for veteran TUR planners who wish to refresh their skills.

The Greenlist Bulletin continues to be a successful way for people to get information about TURI's library offerings quickly via email. The Bulletin generates diverse queries for the librarian. The most popular topics including regulatory issues, environmental management systems, brominated flame retardants, pressure treated wood, dry cleaning, nanotechnology, inks, green building, homeland security, and European chemicals policy.

NEW HAMPSHIRE

New Hamphsire DES

Dioxin Initiative

The New Hampshire Dioxin Reduction Strategy is a-first-in-the-nation attempt to directly address public health concerns regarding exposure to dioxin by comprehensively identifying and quantifying dioxin releases for sources within the state, and implementing actions to reduce human exposure.

The comprehensive dioxin emissions inventory for New Hampshire identified 22 major source categories of dioxin releases in the state, five of which accounted for over 80 percent of total dioxin releases. The five major source categories included:

• Hospital/medical/infectious waste incinerators (29 percent),
• Wood-fired boilers and utilities (20 percent),
• Residential burning of domestic waste (17 percent),
• Residential wood combustion (10 percent), and
• Mobile source fuel combustion (8 percent).

The NH DES Persistent Bioaccumulative and Toxics (PBT) Task Force recommended prompt regulatory action to reduce dioxin from two source categories - medical waste incineration and backyard trash burning. In response, a new state rule regulating emissions of dioxin and mercury from hospital, medical, and infectious waste incinerators (HMIWIs) was put in place. After implementation of this rule, six of NH's eight existing hospitals operating medical waste incinerators reduced their generation of medical waste to the point where it was no longer cost effective to operate their incinerators, and permanently shut them down; resulting in a 95 percent reduction in dioxin emissions from this source category. In addition, in 2001 the NH legislature enacted a new law, RSA 125-N, which authorized DES to establish a statewide dioxin reduction and control program, and as its first action, prohibited the practice of residential open burning of household trash in the state. The prohibition on residential trash burning took effect in January 2003 after an extensive outreach effort was undertaken by DES to educate the public regarding the new law and its public health implications. By addressing and acting on these and other dioxin source categories, DES estimates that statewide dioxin emissions have already been reduced by at least 30 percent, and will result in an overall reduction of over 50 percent in the next two years.

In June and August, DES and the New Hampshire Auto & Truck Recyclers Association, sponsored five workshops as part of the New Hampshire Green Yards Program, which covered best management practices at automotive salvage facilities. The evening sessions focused on topics of interest to salvage facilities and the afternoon sessions were geared toward municipal officials. Turnout for all the session exceeded expectations, and the information collected at these workshops will assist DES in future outreach efforts.

NHPPP continues to support the New Hampshire Hospitals for a Healthy Environment initiative. The last quarterly meeting focused on micro-fiber mop technologies as a way to decrease chemical use and conserve water at hospitals. The next session in December will focus on pharmaceutical, chemotherapy, and medical waste disposal and reduction opportunities.

The home care initiative is underway. DES surveyed New Hampshire home care agencies and clinical staff to determine current mercury use and management procedures. The survey illustrated that those home care agencies that responded to the survey do not use mercury-containing blood pressure cuffs or mercury-containing fever thermometers. Unfortunately, on the other side of the coin, only 25 percent are recycling fluorescent bulbs correctly, and only 30 percent of home care agencies have mercury spill procedure training or policies. NHPPP will continue to conduct outreach to this sector by encouraging them to participate in the Hospitals for a Healthy Environment program and to provide publications to their clients on the New Hampshire fish advisory and mercury spill procedures.

P2 staff has been working with the House Science, Technology and Energy Committee on HB 366, the mercury-added products bill that was retained in Committee after the 2003 legislative session. DES has put forth a proposal to the Committee to narrow the scope of the legislation to focus on a sales prohibition for mercury-added measuring devices, switches, and relays (including thermostats). The Committee is currently considering this proposal and will make a decision by the end of November on whether to recommend the proposal for the 2004 legislative session.

Dr. Philip J. O'Brien, Ph.D., P.G., said farewell to the Department of Environmental Services after 13 years as the Waste Management Division Director. More than 100 people from the New England area and DES attended a farewell reception on October 23. DES also enjoyed a lively "roast" for Dr. O'Brien, which highlighted more of his finer qualities. Dr. O'Brien was always a strong supporter of the NHPPP. He particularly enjoyed the P2 Internship Program, the P2 Annual Conference, and Governor's Award for P2. Dr. O'Brien will continue his environmental efforts and serve a three-year term as director of the Lake Sunapee Protective Association. His presence and guidance will be missed.

NEW YORK

New York State DEC

Policy on Environmental Management Systems (EMS)

The New York State Department of Environmental Conservation (NYS DEC) has developed a Commissioner Policy that will incorporate Environmental Management Systems (EMS) and other environmental performance improvement tools into NYS DEC programs. This policy identifies EMS and other environmental performance improvement tools as effective ways to improve the rates of compliance within the regulated community and to diminish the environmental impact resulting from both regulated and non-regulated activities. The policy authorizes the development of programs to: 1) develop and implement an Environmental Leadership Program (ELP) to encourage the development of EMSs; 2) develop and use environmental performance improvement tools in the Department's enforcement program; and 3) pilot the use of EMSs in NYS DEC operations. In addition to the elements found in EMS models, such as ISO 14001, the Draft Commissioner's Policy requires Department programs to promote EMSs that consider the following: views of stakeholders; measurable performance; credibility; and public disclosure and communication.

P2 Conference

Staff is working on the development of a P2 Ski video for the ski industry of NY. A Memorandum of Understanding (MOU) between DEC and NY Network is being developed, which will allow NY Network (part of the State University of New York system) to assist DEC in the development and recording of a training video to illustrate various P2 practices that can be carried out by operators at ski areas throughout New York State. DEC is partnering with the Ski Areas of New York (SANY) on this project and filming is expected to commence in December.

RHODE ISLAND

Rhode Island DEM

The Department of Environmental Management is proceeding with an Auto Body Environmental/Occupational Health Compliance Self-Certification Program that was launched in December 2002 as a voluntary initiative. It is designed as a multi-media program, a simpler and more useful way to regulate the auto body repair sector in a less threatening manner, and to improve compliance with environmental and occupational health standards with business assistance through a single source. The auto body repair industry is a previously under-regulated small business industry sector.

With startup funding from EPA Region 1-New England in 1994, the results of field research addressing environmental releases, take-home toxics, and work place exposures (to lead and to other toxicants) were incorporated into a broad based self-certification program. The program covers training requirements, hazardous waste management, air quality standards, occupational health and safety, and pollution prevention techniques.

It was viewed as the first ever regulatory and assistance partnership involving the state environmental and health departments, a state university, and a state vocational training institution. Program participants are the Rhode Island Departments of Environmental Management, Health, and Business Regulation, U. S. Department of Labor, Occupational Safety & Health Administration (OSHA), and William M. Davies Jr. Career & Technical High School. The program leverages scarce resources, reaches a substantially higher percentage of the regulated sector than routine enforcement inspections, and requires relatively less effort to comply by the regulated community than traditional permitting and enforcement programs.

The program has already begun to show environmentally measurable results. Certification workbooks and self-certification checklists were sent to 373 auto body shops licensed by the Rhode Island Department of Business Regulation (DBR) in December 2002, with a June 30, 2003 deadline to respond. Shops were sent a reminder letter in May 2002 of the upcoming deadline to respond. Initial results from review of electronic information logged from submitted checklists show that:

• There were 367 entries from shops in business at the deadline
• 170 completed checklists were returned and 14 businesses in the auto repair industry filed Non-Applicability Statements (a 50.1 percent response rate to the mailing)
• 282 Return-to-Compliance (RTC) Plan Forms were returned with Checklists

Additionally, ten shops licensed by DBR since the original mailing were identified from DBR's October 2003 List of Licensees. Those shops were sent a packet in October 2003 with program information, the Certification Workbook and Self-Certification Checklists, and invited to participate in the program.

Some examples of compliance improvements being taken by these shops include:

• Facility modifications to improve vehicle wash water management
• Purchase and use of solvent recyclers
• Contingency procedures and emergency plan development
• Purchase and use of technologies that prevent the release of and reduce worker exposures to metal bearing sanding dust
• Sending staff to physician's offices for physical exams as part of upgraded respiratory protection programs
• Environmental and health and safety training for workers
• Eliminating the use of the EPA and OSHA regulated carcinogen methylene chloride, as a paint stripper.

The program will proceed in the following areas:

• Field audits and enforcement inspections of facilities selected randomly
• Follow-up with shops that submitted RTC Plan forms for compliance status on items identified on forms
• Work with the DEM Management Information Systems Unit to develop a comprehensive database of information from participating shops that allows for data management and analysis
• QA/QC each checklist returned, and make follow-up calls or communicate with shops as needed
• From submitted checklists by shop, summarize data
• Prepare a summary report of data
• Share results of data with DEM regulatory offices, state partners, and stakeholders

In order to conduct post program implementation field audits, entries were assigned identifier numbers in alphabetical order by shop. Seventy identifier numbers were chosen by electronically generated random selection. Of those shops selected, thirty-four (34) shops submitted completed checklists, thirty-four (34) did not submit checklists (one awaiting submission), two (2) submitted Non-Applicability Statements, and one is in the process of returning the final checklist.

Field audits of selected shops that submitted checklists will be conducted by DEM Office of Technical and Customer Assistance staff, enforcement inspections of those not submitting checklists will be conducted by DEM Office of Compliance and Inspection staff.

The Narragansett Bay Commission (NBC) has been awarded a $25,000 EPA Pollution Prevention Grant to work with junkyards and scrap metal facilities within the State of Rhode Island. Through this project NBC will identify pollutant sources and ways of utilizing P2 and sound environmental management practices to eliminate or at least reduce environmental impacts from these facilities' operations.

The first steps to be taken by NBC will be to survey a representative sampling of the more than 45 licensed automotive salvage yards located within NBC servicing. This survey will help to identify environmental impacts from common scrap metal facility practices and procedures such as:

• Vehicle crushing/shredding operation
• Removal and management of automobile fluids including:
  • Automotive waste oil
  • Anti-freeze
  • Transmission fluids
  • Brake fluids
• Management of mercury switches
• Employee environmental awareness training
• Management and disposal of tires

The goal of this initial survey will be to develop P2/Environmental Compliance audit procedures that can be used by NBC staff and project partners from the Rhode Island DEM and the University of Rhode Island to conduct P2 assessments of auto salvage operations throughout the state. Efforts will focus on collecting information that will both allow for a quantitative measurement of pollutant loadings to air water and land from auto salvage operations and will help in the development of appropriate technical assistance programs to minimize these environmental impacts. Work on this project is scheduled to commence during the fall months of 2003.

NBC's Pollution Prevention and Industrial Pretreatment Programs have developed a set of Environmental Best Management Practices (EBMPs) for dental offices that focuses on proper management of dental amalgam waste and establishes streamlined wastewater discharge permit conditions/guidelines for these operations.

Dental offices that adopt these EBMPs will be allowed to eliminate end-of-pipe monitoring requirements provided they certify compliance with EBMP guidelines that include:

• Installation and proper operation of an ISO certified Amalgam Separator with a 99 percent or greater amalgam removal efficiency,
• Development and implementation of mercury spill control procedures,
• A thorough assessment of all existing sink traps and drains,
• Proper maintenance and operation of vacuum pump filters
• Compliance with specific record keeping requirements,
• Development and implementation of an employee environmental training program, and
• Installation and proper maintenance of chair-side amalgam traps

NBC plans to finalize these EBMPs and distributed them as part of a permitting initiative early next year.

The City of Providence has been noted to have more artists per capita than most other cities in the United States. Recognizing that many of these artists work in more than one media and that certain materials that they work with can be dangerous to human health, and the environment, NBC formed a working group consisting of representatives from RI DEM, the Rhode Island School of Design, the Rhode Island State Council of the Arts and an independent artist to develop an environmental, health and safety educational program for these local artists.

During the summer months of 2003 NBC's P2 Program worked with an engineering intern from the University of New Hampshire on a series of on-site environmental technical assistance audits of eight Rhode Island hospitals/health care facilities. Each audit focused attention on multi-media environmental issues, pollution prevention, and environmental regulatory compliance and helped to identify issues of importance to hospital environmental, health and safety personnel. Major environmental issues identified during these audits included:

• Hazardous Waste Management
  • Contingency Plans
  • Satellite Accumulation
  • Labeling
  • Employee Training
• Universal Waste Management
• Spill Control Procedures
• Underground Tank Management
• EPCRA Compliance

NBC will be organizing a half-day pollution prevention/environmental compliance educational workshop for all of Rhode Island's healthcare industry early next year to help address these major areas of concern.

VERMONT

Vermont DEC

A statewide workshop series entitled "Vermont Hazardous Waste Regulations Explained for Small Businesses" was sponsored in October at five locations by the Environmental Assistance and Waste Management Divisions. There were over 150 attendees in this second year of workshops targeted at conditionally exempt generators that covered regulatory and pollution prevention issues. 85 percent of attendees indicated that they would make operational changes as a result of the workshop. It is likely that the workshops will be repeated in future years.

DEC completed a voluntary dental self-certification program with over 350 dentists in the state. Over 90 percent of dental practices filed self certification forms indicating their compliance with environmental best management practices for hazardous waste, solid waste, and wastewater management compliance.

DEC received an EPA PBT grant to provide mercury education and outreach to populations most sensitive to mercury contamination. Targeted mailings of brochures on mercury in fish will be mailed to recently married couples and new parents. Childbirth educators, day care centers, pediatrician's offices, and other health care providers will be mailed brochures and posters. An educational video for schools will also be produced under the grant. DEC will work on this project in collaboration with the Vermont Department of Health.

DEC was awarded an EPA fluorescent lamp recycling outreach grant to implement business/commercial outreach programs to increase fluorescent lamp recycling rates. Baseline recycling rates are being determined to compare recycling rates before and after outreach efforts. These efforts will include mass mailings of brochures to businesses, daily newspaper inserts, and various media outreach, including radio and TV.

As part of an effort to better understand consumer behavior and barriers toward purchase and use of less toxic and environmentally preferable products, DEC is conducting a consumer phone survey through the University of Vermont. The Department expects the survey results by the end of the year and hopes to use these results, along with a recent survey of retailers, to develop one or more pilot projects to test approaches that encourage toxics use reduction and environmentally preferable purchasing.

EPA REGION 1 - NEW ENGLAND

On October 21, EPA Region 1 - New England and NEWMOA hosted a conference call that discussed EPA's draft Guidance for P2 Core Measures. The Core Measures were developed by EPA Headquarters for state and local P2 programs that receive funding from EPA's P2 Grant program. The purpose of the measures is to collect consistent national data on P2 outcomes and, more directly, to provided numbers to support the goals listed in EPA's Strategic Plan (i.e., "by 2008, reduce pollution by 76 billion pounds, conserve 360 billion BTUs of energy and 2.7 billion gallons of water, and save $400 million, from a baseline year of 2003). Interest in the subject is high and work will continue with NEWMOA to brief the states on future developments and to elicit feedback.

EPA Region I-NE has developed a Hospital Assessment Tool Template as part of an OECA grant to collect information from hospitals on environmental performance indicators, waste generation, pollution prevention, and energy/water conservation. Three states (CT, RI and NH) took the template and made it a state specific tool. To conduct the survey, two UNH interns went to 25 hospitals (8-NH, 8-RI and 9-CT) with the state specific tool and collected data to help assess the hospital's environmental performance and potential opportunities. EPA and the States will use the data collected and analyzed by UNH to evaluate hospital mercury programs, to identify sector-wide issues, to develop compliance assistance tools, and to further define healthcare sector activities.

On October 8, EPA Region 1 - New England helped to organize three sessions at the Massachusetts' 9th Annual Buy Recycled and EPP Vendor Fair and Conference in Worcester, MA. The first session, "EPP 101," provided an introduction to environmentally preferable purchasing with an emphasis on cost saving opportunities and critical communication approaches. The second session "Federal Focus on EPP: Purchasing Info and Update" included presentations on EPA's Federal Facilities program, EPP and EMSs, online procurement systems that tabulate purchases of recycled content products, and electronics recycling. The third session, "Best Management Practices: Sustainability in Action," featured success stories highlighted in EPA Region 1-NE's Best Management Catalog for Colleges and Universities. The Vendor Fair featured approximately 100 exhibitors and received over 800 attendees from colleges and universities, hospitals, and state, local and, federal government.

EPA REGION 2

Reducing Nitrogen Loadings from Golf Courses

The U. S. Golf Association, Cornell University, Cornell Cooperative Extension of Suffolk County, Peconic Estuary Program, EPA Region 2, NYS DEC, and the Suffolk County Department of Health Services, are organizing a meeting to discuss the management of nitrogen applications on golf courses on November 13 in Riverhead, New York. The Agencies and organization are focused on Eastern Long Island's golf courses because of concern for the ecological health of the Peconic Estuary and neighboring surface waters. These waters are impaired or threatened due to nitrogen loadings from multiple sources. Working with golf courses is part of a larger pollution prevention effort in the area. The Peconic Estuary Program is also actively working with the municipal, marine, agricultural and residential sectors of Eastern Long Island to achieve an overall reduction in nitrogen loading.

NORTHEAST P2 ROUNDTABLE

Guidance on Mercury Product Labeling & Phase-Out

Topic Hubs™ are web-based guides to peer-reviewed pollution prevention (P2) information and expertise on a particular subject and are designed to provide assistance programs and others with a single point of access to P2-related information on that subject. The Topic Hub™ Project is being carried out by the Pollution Prevention Resource Exchange (P2Rx™), a consortium of eight regional pollution prevention information centers that work collaboratively to create national P2 resources. NEWMOA is the P2Rx™ Center for the Northeast states.

The "Topic Hubs™" are designed to provide an overview of the issues, process information, P2 options, and the best pollution prevention-related documents (links) for the industrial sector or topic. The Regional P2 Information Centers that make up P2Rx™ have published 48 Topic Hubs™ to-date including a Hub on P2 in Hospitality published by the Western Regional Pollution Prevention Network (WRPPN).