The National Environmental Performance Track Program of the U. S. Environmental Protection Agency (EPA) is designed to motivate and reward top environmental performance. Through a systematic approach to managing environmental responsibilities, taking extra steps to reduce and prevent pollution, and being good corporate neighbors, many companies today are leading the way to environmental excellence. At the same time, they are saving money and improving productivity. The Performance Track defines what it means to be a top environmental performer and provides incentives to motivate further improvements. The overall program consists of two levels of recognition: the first level is the National Environmental Achievement Track (Achievement Track), and the second one is the National Environmental Stewardship Track (Stewardship Track). The EPA invited applications for the Achievement Track last fall, and selected an initial list of charter member companies on December 13, 2000. It plans to launch the second level of the program, the Stewardship Track, in May 2001. This article describes this innovative program of the EPA, the benefits and costs for facilities to participate, and some special consideration for small businesses.
Benefits of Participation in the Program
Participation in the Performance Track program enables facilities to implement flexible and potentially more efficient approaches to environmental protection. Participating facilities will receive several incentives in return for their environmental commitments. Incentives include:
- Recognition and Networking -- use of the Performance Track program logo; acknowledgment on EPA's web site and program communications; peer exchange opportunities; opportunities to be featured in EPA publications; and special recognition events.
- Streamlined monitoring, reporting, and administrative requirements -- greater flexibility under the Best Available Control Technology (BACT) requirement of the Clean Air Act (CAA); more direct access to reduced reporting and monitoring under the Discharge Monitoring Reports (DMRs) provisions of the Clean Water Act (CWA).
- Enforcement benefits -- low priority for inspection targeting purposes and consideration of program participation as an indication of good faith under applicable enforcement policies.
- Expedited status for pesticide review -- greater opportunity for expedited review of new, reduced risk pesticide products under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
- Financial benefits -- more advantageous loan terms for Publicly Owned Treatment Works (POTWs) under the State Revolving Loan (SRL) program of the CWA for funding construction of sewage treatment plants.
A number of these incentives will be available to participants immediately. Implementation of some incentives, however, will require the EPA to take administrative actions, issue a rule making, or to coordinate with state agencies. Those incentives include -- reduced frequency of reporting under the CAA Maximum Achievable Control Technology (MACT) provisions; streamlined procedural requirements and expanded opportunity for Internet-based reporting for POTWs; and opportunity to participate in EPA-electronic reporting and consolidated reporting pilot programs. The EPA will take the necessary steps to make these particular incentives available, but they may not be available to participants immediately. In addition, the EPA is considering the feasibility of additional incentives. These incentives include: changes to the Resource Conservation and Recovery Act (RCRA) that allow facilities to accumulate wastes for up to 180 days, and the opportunity for expedited product review for companies that submit Premanufacture Notices (PMNs) under the Toxic Substances Control Act (TSCA).
The National Environmental Achievement Track
The Achievement Track was made available to facilities of all types, sizes, and complexity, public or private, manufacturing or service oriented. Multi-facility corporations were encouraged to develop company-wide policies supporting participation across their facilities, such as corporate environmental management system (EMS) policies, but facilities applying within a corporation had to meet program requirements individually. Facilities seeking entry into the Achievement Track must have had adopted and implemented an EMS (such as Responsible Care of Responsible Distribution Process), committed to improving their environmental performance, committed to public outreach and performance reporting, and have had a record of sustained compliance with environmental requirements. Specific selection criteria were:
- Implementation of an EMS, for at least one complete cycle, which includes a self- or third-party audit. The EMS must include the following elements: policy, planning, implementation and operations, checking and corrective action, and management review;
- Past evidence and future commitments of specific, measurable environmental improvements;
- Past evidence and future commitments of public outreach, including identification and response to community concerns, and performance reporting; and
- A record of sustained compliance with environmental requirements, certification of current compliance, and commitment to maintain compliance.
Cost to Participate in the Program
There is no application or membership fee for the Performance Track program. The EPA has designed this program to be an inclusive, voluntary, and flexible program. The amount of time and money a facility invests in improving its performance varies depending on the size of the facility and the types of environmental improvements sought. Many facilities find that these investments in pollution prevention and other environmentally-preferable practices have favorable pay back schedules and produce real savings, as well as improve their standing with their community and with regulatory agencies.
Special Consideration for Small Businesses
The EPA encourages small businesses and other small entities to apply to the Achievement Track. Many of the requirements have been scaled to meet the size of a facility and allow for greater participation of small entities. For example, depending on the nature and extent of its operations, the EMS for a small facility may be simpler than one for a larger, more complex facility. For this same reason, a small facility may have fewer environmental aspects. Small facilities are not asked to make as many performance commitments as large facilities. Public outreach requirements also are scaled to the size, scale of operations, and setting of the facility. The EPA is creating a more active and focused developmental program for small entities, with the goal of helping to expand the capacity among small businesses and small entities for participation in the Achievement Track and, later, in the Stewardship Track.
The Second Level of the Program
The Stewardship Track is a second phase of Performance Track and is currently under development. The Stewardship Track will be designed to encourage and recognize broader and higher levels of environmental performance than those expected under the Achievement Track. Program elements may include increased commitments to specific environmental performance goals and targets; a focus on environmental management and performance along the product chain through relationships with customers, suppliers, and transporters; a greater concern with product performance throughout their life cycle; and a higher level of community engagement.
Achievement Track Company
At the end of 2000, the EPA selected 225 charter members for the National Environmental Achievement Track. Achievement Track companies and facilities have strong records in environmental management with more waste recycling and greater reductions in air and water pollution than are legally required. They have reduced their energy consumption by millions of kilowatts per year, and are committing to an average of 22 percent improved energy efficiency in the future. Commitments for future water use reduction average 31 percent. Some companies have even succeeded in virtually eliminating discharges to surface water, while others are significantly reducing discharges to groundwater to protect underground drinking water supplies. Waste reduction at these facilities is projected to average 44 percent per year, representing millions of pounds of saved resources as process and packaging materials are recycled or reused. Others are significantly reducing emissions of greenhouse gases to help protect the ozone layer, and some will cut their output of toxic air pollutants in half. Selected pharmaceutical and chemical company participants are listed in the following table:
| 3M Brownwood | 3M Guin |
| 3M New Ulm | Bristol-Myers Squibb |
| Ciba Specialty Chemicals, Newport Site |
Dow Corning Corporation |
| Johnson and Johnson Merck Consumer Pharmaceuticals |
Johnson and Johnson Ortho McNeil Pharmaceuticals |
Conclusion
The expectation of the EPA is that the Performance Track program will motivate other companies and facilities to achieve similar improvements as those already selected companies, and complement existing regulatory activities. The program has been designed so that criteria for participation are proportional to the benefits and that small, medium and large facilities will participate. Emphasis is being placed on continued environmental improvement, effective state/EPA partnerships, and the need to inform and involve citizens and communities. Small chemical companies should be encouraged to consider applying for membership in the National Environmental Performance Track Program. Adherents to the Responsible Care and Responsible Distribution Process programs are in an especially strong position to do so.
For More Information
The Performance Track Information Center
c/o Industrial Economics Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140
Phone: 1-888-339-PTRK
E-mail: ptrack@indecon.com
