The C.L.C. National Pollution Prevention Strategy was developed through the C.L.C. National Environment Committee, the C.L.C. National Workplace Health & Safety Committee, and the C.L.C. Toxic Substances Working Group. The strategy was endorsed by the Environment Committee (of which I am Secretary) in February 1992. Particular Canadian unionists who contributed to the development of the strategy were: Cathy Walker (C.A.W.); Brian Kohler (CEP); Cliff Andstein (B.C.G.E.U./N.U.P.G.E.); Larry Stoffman (U.F.C.W.); Andy King (U.S.W.A.); and Jennifer Penney (O.F.L).
2.
CommnonerB.Making Peace with the Planet. New York: Pantheon, 1990, Chapter 3. RossiM.“Techniques in T.U.R.,”New Solutions, Fall, 1991, and the works cited in that article. Barry Commoner tends to confine prevention to the wholesale banning of chemical substances, confining their use to the manufacture of pharmaceuticals and videotape (two products which, ironically, we have far too much already).
3.
The distinction between prevention and control is not always as absolute as it may seem. For one thing, prevention methods are not always 100 percent effective either. For instance, a chemical may be eliminated to be replaced by a substitute: But the substitute is likely to be at best less harmful than what it replaced, not 100 percent safe. The “soft” CFCs are a case in point Even then, we have to work out a scheme by which we have reason to believe that substitutes are, in fact, less harmful than what they replace. This scientific exercise in priority-setting or criteria for relative environmental friendliness is not well advanced. The Massachusetts T.U.R. program, for instance, does not embody any scheme for rating the relative hazard of different chemicals, relying evidently on common sense for what counts as a reduction of hazard and, therefore, of the resulting waste. Or again, take this example: A “site-specific intermediary” is a chemical compound both produced and used within a single industrial enterprise in the middle of an industrial process. If the efficiency of the industrial process is increased, the concentration of the resulting pollutant, for example, residues of the intermediary, can be reduced. This will count as a prevention method. Or, the pollutant can be controlled by any one of the methods listed above. From the point of view of the environment, there may be little to choose between the approaches, since (cost aside) the result may be the same. Clearly, if a pollutant is treated on the way out of the waste pipe (for example, scrubbers) or at the end of the pipe (for example, secondary treatment ponds for pulp mill effluent), these will count as control methods. But, if a potential pollutant, such as the residue of a site-specific intermediary, is treated at the periphery of an industrial process, but deep within the plant, it will count as a prevention method. This is not to say that there may not be a better prevention method such as the elimination (or substitution) of the site-specific intermediary; but there is a gray area in which the distinction between prevention and control becomes blurred. Crudely, if the method is an engineering process method, it will count as prevention. If the method depends on chemical or physical treatment of a pollutant (including a persistent site-specific intermediary), it will count as a control method. The general point remains: Prevention is primary, and it is much more effective in reducing pollution than control.
4.
CairncrossF., Costing the Earth, Economist Books. London: 1991, Page 110 ff, documents the energy inefficiency of East European industry.
5.
Canadian Labor Congress. C.L.C. Policy Statement on the Environment, endorsed by the C.L.C. Executive Council, December, 1991. The C.L.C. position is in the same realm of debate as that in the U.S. over a Superfund for Displaced Workers. See, for example: WykleL.MorehouseW. & DemboD., Worker Empowerment in a Changing Economy, Jobs, Military Production and the Environment. New York: Apex, 1991. But, the Superfund idea seems to me to condone too readily the massive de-industrialization of the U.S., something that American governments have failed to prevent over the last decade.
6.
For instance, worker body burden limits for lead are several times more lax than the recommended standard for the general public. In ionizing radiation protection standards, the discrepancy between levels for workers and for the public is enormous.
7.
Workplace exposure limits include Permitted Exposure Limits (PELs), Threshold Limit Values (TLVs), and the like.
8.
MurrayL., “The Politics of Pollution Prevention,”New Solutions, Fall, 1991.
9.
Attacks on the idea of zero discharge take two forms: (i) Since a discharge level of literally zero is rarely possible, short of shutting down a polluting industry, the idea of zero should be abandoned; or (ii) Since Virtual Elimination is a radically unclear idea or incapable of a proper definition, it should be abandoned in favor of something less ambitious and more attainable. All this is in need of an extended examination in the pages of New Solutions, dealing with the relationship between science and public policy and ways in which business seeks to discredit the environmental movement, ostensibly on scientific grounds.
10.
Rossi Cited at Note 2 above, Page 1.
11.
MyersQ.C.M. and LemieuxMatthews V.J.“Whistle-Blowing Employee Loyalty and the Right to Criticize: The Employee's Perspective,”Labor Arbitration Year Book. Butterworths, Canada, 1991, Volume 2.
12.
Some ideas for the ranking of hazards and criteria are to be found in BennettD.“Pesticide Reduction, A Case Study from Canada,”New Solutions. Fall, 1991.
13.
Canadian Environmental Protection Act. Sections 61–65.
14.
Report of the Auditor General of Canada, October, 1990.
15.
See, for example, “The Environment and the Canadian Constitution, A Discussion Paper,” Draft 3. C.L.C. Environment Committee, June 1991.
