EPA`s performance track program - going beyond compliance

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About 8 years ago, the US EPA began its Performance Track Program (PTP). This program is an effective way for facilities to demonstrate a strong commitment to protecting the natural environment. Facilities in this program receive benefits in exchange for having a sound environmental management system in place that ensures compliance, continual environmental improvement, past environmental achievements and a commitment to reaching out to the community. Recently, the program passed its 500 member mark.

The PTP web-site (link at end of article) provides a number of tools which would help you make a case to your management that taking the steps required to join Performance Track would benefit your company. We encourage you to review the web-site. Below are a few of the benefits of this program:

- Recognition on the local and national levels: EPA works with facilities to promote their environmental achievements. This includes letters to elected officials and articles in trade association journals.
- Regulations are available that reduce the regulatory burden at PTP facilities: These regulations provide for: flexible air & water permits, reduced reporting under MACT, low interest loans for water quality improvement projects, extended hazardous waste accumulation times, and reduced hazardous waste inspection frequencies.
- Low priority for federal inspections.
- Networking opportunities for exchange of best practices: This includes an annual conference, regional round-tables and invitations to EPA meetings on relevant topics.

In order to understand the effectiveness of this program, we interviewed Jerry Haniff, of McNeil Consumer Healthcare (McNeil) located in Fort Washington, Pennsylvania. Their facility manufactures a variety of over-the-counter medicines including Tylenol=AE, Motrin=AE, Imodium=AE, and Mylanta=AE. They have been a member of PTP since 2001. McNeil has committed to a wide variety of environmental goals, including reducing over-all energy usage, increasing percentage of renewable energy use, reducing waste generation and land conservation. While it is becoming more of a challenge to find new commitments, Mr. Haniff stated that 'For companies who can spare the time and resources, this program will give them a good partnership with EPA and help reduce their impact on the environment.'

McNeil joined Performance Track in order to show their commitment to the environment, become more transparent, and to develop a partnership with EPA. They have found the experience to be a positive one. The networking opportunities provided by the program have been useful as they work to come up with ideas for continual improvement. Because Pennsylvania does not have its own version of PTP (Delaware has one), participation has not directly impacted McNeil's relationship with the state environmental agency. However, they still receive regulatory relief for hazardous waste as well as reduced inspections from EPA.

Environmental and Engineering Solutions is available to work with your facility in developing a case for joining PTP, implementing an environmental management system, identifying conservation opportunities and completing the application for PTP. If you are interested in more information, please contact Tom Petersen.

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