E.P.A. sheds light on issues surrounding bakers and snack food makers plans

by Anne Giesecke
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In this article, the Environmental Protection Agency (E.P.A.) answers questions to help bakers and snack food manufacturers plan for 2011.

Dr. Giesecke: Bakers are required to have a Spill Prevention, Control and Countermeasure (SPCC) Plan to prevent oil spills into the waters of the United States. The latest rule has a new compliance date of Nov. 10, 2011, and continues the discussion of milk as oil and other guidance. How can food facilities best manage compliance when faced with on-going changes?

E.P.A.: The E.P.A. is aware of the uncertainty confronting food manufacturers who handle milk and milk products along with other oils and is working to clarify issues related to compliance with the Spill Prevention, Control, and Countermeasure (S.P.C.C.) requirements. Food manufacturers that are currently subject to the S.P.C.C. rule should continue to maintain their existing S.P.C.C. plans until the E.P.A. addresses milk and milk product containers under the rule.

For facilities that are reviewing their applicability under the S.P.C.C. rule, owner/operators should count all containers of oils (other than milk or milk products) such as gasoline, diesel fuel, hydraulic oils, lubrication oils, and vegetable oils of 55 gallons and larger and determine whether the facility has a reasonable potential to discharge oil to water. If it does and it has more than 1,320 gallons in above ground storage, it should develop its S.P.C.C. plans in anticipation of the compliance deadline.

Dr. Giesecke: The E.P.A. has had both strong enforcement and assistance programs to manage compliance with E.P.A. regulations. How will the E.P.A. use resources next year to enforce compliance and offer assistance to companies?

E.P.A.: The E.P.A. maintains strong enforcement and compliance programs to effectively implement environmental laws. The agency uses an integrated, common-sense approach to address noncompliance, including a mix of data collection and analysis, inspections, compliance assistance and incentives, and civil and criminal enforcement. This next year, the E.P.A. will further integrate this mix of approaches by merging its compliance assistance and incentives activities into its civil enforcement program, removing the budgetary obstacles that have separated and emphasized these separate tools. This merger will allow the E.P.A. to better focus on compliance and environmental outcomes, using the best approach — assistance, incentives, inspections or enforcement — to address the unique characteristics and requirements of specific compliance problems.

Dr. Giesecke: One of E.P.A. Administrator Lisa Jackson’s priorities for the E.P.A. is cleaning up our communities. To avoid future contamination what is the E.P.A. doing to plan for disposal of alternative lighting, such as LED, or other new products that are saving energy and water?

E.P.A.: The E.P.A. is increasingly encouraging Americans to focus on materials management. That extends beyond how to handle materials at the end of intended use, to looking at the whole lifecycle of materials to identify opportunities to minimize waste and conserve resources.

Dr. Giesecke: Climate change and air quality are priority issues linked closely with the burning of fossil fuels. Is the E.P.A. encouraging utilities to operate cleaner and to be more flexible with companies trying to reduce energy use?

E.P.A.: The E.P.A. and states have a number of regulations that apply to utilities to protect public health from air pollution. In addition, the agency has several programs to encourage utilities and their ratepayers to be more energy efficient. Utilities do not receive additional regulatory flexibility as a result of their energy efficiency efforts. It’s important to note, however, that increased energy efficiency is both financially and environmentally beneficial because it saves energy costs while reducing emissions of both greenhouse gases and conventional air pollutants. These benefits are powerful incentives for utilities to improve efficiency.

Dr. Giesecke: Protecting America’s waters is also one of Administrator Jackson’s priorities. Water is an important ingredient in baked foods. How will the E.P.A. help companies to understand that water is becoming a scarce resource?

E.P.A.: Commercial users of water consume a large amount of fresh water and can have a great impact in helping to meet challenges faced by our nation, including growing water needs and increasing demands on water infrastructure. By adopting and promoting water-efficient products, services, and practices, commercial and institutional water users can greatly reduce annual water and energy costs, as well as help reduce the stress on natural resources.

The E.P.A.’s WaterSense program helps raise our national awareness of water as a scarce resource and encourage water efficiency among utilities, manufacturers, and consumers. WaterSense seeks to protect the future of our nation’s water supply by promoting water efficiency and enhancing the market for water-efficient products, programs, and practices. The WaterSense label makes it easy for consumers to recognize products and programs that save water without sacrificing performance or quality.

Independent, third-party licensed certifying bodies certify that products meet E.P.A. criteria for water efficiency and performance by following testing and certification protocols specific to each product category. Products that are certified to meet E.P.A. specifications are allowed to bear the WaterSense label. Since the program’s inception in 2006, WaterSense has helped consumers save a cumulative 46 billion gallons of water and $343 million in water and sewer bills.

For additional information on the E.P.A.’s WaterSense program, please visit: http://epa.gov/watersense/index.html.

For additional water efficiency information and resources for commercial and institutional entities, please see WaterSense’s “Commercial & Institutional Water Users” web page at: http://epa.gov/watersense/spaces/ci.html.

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