The New Challenge in State P 2 Programs : Measuring the Progress and Impact of P 2 Regulatory Integration

In the late 1980s and early 1990s, most state pollution prevention (P2) efforts focused on the provision of technical assistance, based on the premise that a lack of technical knowledge was the primary impediment to business implementation of P2. It has become increasingly apparent that technical assistance alone is insufficient to motivate systematic change in industry. As a result, state and federal agencies have adopted policies aimed at infusing P2 into the regulatory system. This process of "P2 regulatory integration" is an attempt to overcome regulatory inertia against P2. It works by weaving P2 fully into agencies' core environmental programs — including permitting, enforcement, rulemaking, and inspections. State's measurement of their own progress in promoting P2 has followed a similar course: that is, a focus on measuring the impact of technical assistance has preceded measurement of P2 regulatory integration. States began by tracking their activities related to technical assistance provision, such as the number of training sessions offered or facility P2 assessments performed. The recent P2 Review article by Manns and Varlamoff indicates that, in 1996-1997, most states were still focusing their P2