A. RELATION OF R&D GOALS TO SECTOR GOALS
Metal finishing operations have historically been regarded by EPA as having a significant environmental impact due to their toxic emissions to air, water, and land. The metal finishing industry consists of 8,000 - 10,000 metal finishers, of which over 75% have less than 10 employees and over 98% have less than 100 employees. These small businesses--and the industry as a whole--do not have the resources to fund environmental research and development (R&D) on their own. There is a clear need for government leadership and support in collaboration with industry and other stakeholders to meet the environmental R&D needs of this industry.
The industry voluntarily came forward to participate in the Common Sense Initiative (CSI) to improve their environmental performance and economic competitiveness. The CSI Metal Finishing Subcommittee has drafted strategic National Performance Goals for the sector that include: improved resource utilization, reduction of hazardous emissions, and improved economic and compliance performance for both individual facilities and the industry as a whole.
This National Metal Finishing Environmental R&D Plan is one way by which EPA and other stakeholders, including the industry, are attempting to better focus limited resources on the specific R&D needs of the industry to help it meet its strategic goals. While the R&D planning process was begun significantly (close to two years) before the strategic goals planning process, it is really not surprising that they match as well as they do. There have been consistent themes in the environmental R&D needs as stated by the industry and the other stakeholders that clearly are related to the strategic environmental goals that have been developed by all the stakeholders.
To examine and demonstrate the proposition that both sets of goals are congruent Table 1 contains a matrix that states the strategic goals across the top (these relate to: resource utilization, hazardous emissions reduction, economics and compliance, and industry sector goals) and the eight "specific" recommendations (there are also two "general" recommendations) that are contained in the Recommendations section at the end of this Plan down the left-hand side of the table.
It can be seen that every one of the R&D recommendations is directly related to at least two of the sectoral goals; nearly all are directly related to several or to all the sectoral goals. The recommendations dealing with emissions and risk characterization were seen as more indirectly than directly related to the goals, while the recommendations relating to the reduction of emissions from most of the materials of concern--i.e., hexavalent chromium, cyanide, chlorinated solvents, and cadmium--are directly related to all the strategic goals.
All the proposed R&D is intended to help increase resource utilization and reduce hazardous emissions by developing or testing practical, low-cost pollution prevention and control technologies. This approach will contribute to improved economic paybacks and the ability to achieve compliance and go beyond compliance requirements at individual metal finishing facilities. In addition the R&D projects are intended to be as widely applicable as possible to the industry, thereby leading to wide-spread adoption with industry-wide benefits.
| 1. Emissions & Risk Characterization | ||||||||||
| 2.Hexavalent Chromium | ||||||||||
| 3. Cyanide | ||||||||||
| 4. Off-Site Recovery Processes | ||||||||||
| 5. Chlorinated Solvent Substitution | ||||||||||
| 6. Rapid Verification Protocol | ||||||||||
| 7. Cadmium Emissions Reduction | ||||||||||
| 8. Technology Assistance | ||||||||||
Key:
3 = direct
relationship with the strategic goal area
2 = indirect relationship
1 = a limited or uncertain
relationship
0 = no perceived relationship
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