Learning to Prevent Pollution: The Chemical Industry in Britain and the United States

Learning to Prevent Pollution: The Chemical Industry
in Britain and the United States
Alastair Iles


Chapter 1 introduces the research problem. First, I observe that the rise of pollution prevention (broadly, the ideas and practices associated with stopping pollution from being generated in the first place) reflects broader trends in environmental regulation in industrial countries. Previously, pollution was thought to be largely an issue of emissions into environmental media, and the governments of industrial nations, such as Britain or the US, relied on regulation as a means to push polluters, including industry, towards reducing releases of pollution as a way of attaining greater environmental protection. They had overseen pollution management through setting standards, regulating factories, analyzing pollution, and making decisions about what goals to aim at. By the 1990s, however, many people had begun to lose their confidence in the ability of governments to control pollution through such means.

The seemingly secure bearings of regulation are being gradually replaced by active questioning by governments, industry, and citizens about what the causes of pollution are, who is responsible for what, where to aim one's efforts, and how to gauge success. In the past 30 years, three major changes have occurred that affect the philosophy and practice of environmental regulation: a growing shift of knowledge production from governments to non-governmental actors like environmentalists and companies; the increasing importance of decentralized activities as sources of knowledge; and greater attention to targeting the decisions of polluters regarding process design and operation, rather than emission controls.

Consequently, industry, environmental groups, and regulators have started to regard preventing pollution at source as potentially a more effective strategy than controlling emissions alone. In doing so, they have tested a range of innovative tools and activities. They have done so through many decentralized activities, notably in the United States. As a result of these moves, the British and US governments no longer function as all-seeing producers of knowledge, claiming control over the process of learning to solve pollution problems. Non-government actors have increasingly become primary managers of pollution, with governments playing a lesser but perhaps no less crucial role: that of persuading and enlisting industry, technical experts, and communities to use their capabilities and knowledge in problem-solving instead of simply complying with regulatory prescriptions.

There also appear to be divergences among industrial countries in how they embody these developments in their regulation and policy, flowing from their regulatory traditions and political cultures. Because of the major differences in their regulatory and political features, Britain and the US provide valuable comparative case studies of how pollution prevention may emerge differently between countries. Britain has had a regulatory tradition of site-by-site regulation in which inspectors negotiate standards with companies, and its political culture has discouraged the involvement of citizens in regulation as well as promoting secrecy in making regulatory decisions. In the 1990s, Britain has undergone some major changes, namely acquiring a more formal regulatory system and making pollution information more available. Britain has also encountered intensifying regulatory pressure from the European Union's environmental policy-making. In contrast, the US has relied on a nationwide, standard-based approach to regulating pollution, and its political culture obliges regulators to make their activities highly transparent. In the 1990s, however, the US has experimented with a variety of voluntary activities undertaken by industry, while moving towards enlisting environmental groups as persuaders alongside industry and government.

In observing these various developments, I ask the following questions:

· Why have many environmental protection developments (in this case, pollution prevention) begun to take hold, despite not being directly mandated by regulation?

· Why have many practices and tools (e.g., the notion of prevention; the Toxics Release Inventory; green chemistry; employee teams; and process diagrams) come into existence and come to be part of the regulatory order, even though they were not regulated from the top down, or have been taken up into regulation from the activities of many actors at many places?

· Why do there seem to be variations - or uneven evolution - between different parts of the pollution prevention issue, firms, localities, governments, and countries in the "taking hold" of such developments?

· Why are there continuing difficulties for governments in trying to regulate industrial pollution at the local level, when it might be expected that making regulation work locally will be more effective for prevention - as a site-specific phenomenon - than centrally directed regulation?

My hypothesis is that a social learning model based on the interpretive, often site-specific work of decentralized actors engaging in activities that test and develop environmental protection ideas and practices can explain these observations.

In Chapter 2, I review two theories of learning, advocacy coalitions and adaptive management, and show how their presuppositions about the nature of learning reinforce what may be characterized as the "positivist" features of conventional learning approaches. These approaches take learning actors and pathways for granted, do not look at how everyday conditions may give rise to learning, and do not acknowledge that learning may occur in multiple, messy, highly contingent ways. Similarly, regulation is treated as if it was something that could be imposed on many local places and actors from the top down, and thereby, inevitably, work. In response to these limitations, I build a model of social learning that combines Deweyean pragmatic philosophy, science studies, and comparative politics.

Social learning is interpretive work by actors through their activities, demonstrations, persuasive efforts, and tool-makings in connection with environmental protection. These actors, furthermore, reflect on the consequences of all these actions and discourses, evaluating whether or not certain things appear to work, deciding whether and how to adapt things in further work. I argue that the interpretive work by actors can involve often site-specific, but sometimes wide-ranging or multi-sited, "experiments" in the form of inventing, testing, and using "things" like institutions, tools (such as pollution numbers}, or practices. Part of the interpretive work by actors is to give these "things" an existence, a persuasive power, or the ability to travel between sites or be part of a nationally applying regulation. Actors can do so through engaging in demonstrations that are more or less persuasive, in locally contingent ways. Yet, such patterns are not infinitely variable and contingent: they may embody the regulatory traditions and political culture prevailing in a particular country. If this is so, social learning may vary between countries with differing regulatory traditions and political cultures, even though the chemical industry is one of the most internationalized.

Chapter 3 investigates how pollution prevention emerged, as a new norm that combined environmental protection with economic advantage, in Britain and the United States. Despite its seeming advantages, "non-waste technology" faltered in the 1970s. Rather, prevention first emerged and then took hold more much rapidly in the US, even though site-specific knowledge was not valued in regulation. In contrast, prevention only arose later in Britain, whose regulatory system was much more congenial to site-specific knowledge. To explain this divergence, I look at how prevention emerges from culturally and politically specific crises. For instance, whereas pollution came to be viewed in the US as contamination and as very difficult to control out in the environment, British actors continued to see pollution as something that did harm to the environment. Prevention, then, was seen as a response to the uncertainties of pollution in the early 1980s in America. Concomitantly, political culture in the US requires that industry, government, and citizens should make their actions "seeable" and "believable". Thus, the US chemical industry (but not their British counterparts) realized that prevention could be turned into a new norm that could help make their voluntary activities more seeable and credible.

Chapter 3 then looks at the different ways in which prevention entered official policy in each country. It takes a comparative look at how, in the US, prevention came to be defined in regulation as "source reduction", while prevention was introduced in the 1990s by the UK government in response to economic - not regulatory - crises. In the US, the discourses of technical experts and some chemical firms, using definitions of prevention, played a central role in moving prevention from activities into a new norm that could be enshrined in policy. The technical experts assumed that asserting prevention as a new norm or definition would be efficacious. They thought that relying on demonstrations of the effectiveness of prevention (in both health and economic terms) would be enough for the chemical industry to take up prevention. But in the UK, it was the government that sought to use practical demonstrations (rather than definitions), in the form of "waste minimization clubs", to persuade the chemical industry to do prevention. Subsequently, pollution prevention has acquired different meanings in Britain (almost exclusively economic) and the US (more of an environmental and health orientation), even though the techniques might be expected to be similar across their chemical industries. The chapter concludes that prevention is not a concept that can be given form in itself. It needs to be connected to other things and made tractable. It has to be demonstrated, linked to numbers, made accessible. Relying on definitions (in the US) or on projects that are very difficult to see, to bring pollution prevention into a workable form has not been very effective. Thus, the other case study chapters help show how actors went on to try to test ways of making prevention tractable and "real" through making tools, institutions, and other artifacts.

Chapter 4 reviews chemical industry perspectives to prevention since the early 1970s. It examines the ways in which prevention has come to be understood in the form of the decentralized activities occurring at plants in Britain and the United States. Source reduction has been enshrined as the regulatory definition of prevention in the US, yet chemical firms in both countries continue to use a broader definition that emphasizes the site-specific, activity-based character of prevention. In both countries, it continues to be difficult to "see" what happens inside plants and in the form of activities whose details are not necessarily reported outside. Therefore, I investigate the varying interpretive conventions used by firms, regulators, and environmentalists to define the "sources" at which pollution should be prevented. I also examine the efforts of some actors, respectively, to use different definitions of "source" to persuade each other to adopt specific preventive activities, or to make activities more "seeable" and "believable". Definitions are political in their uses and in the ways that they can open up social and spatial spaces for some actors. Some environmentalists are trying to change what "site" means by their acts, whereas others rely on changing ideas about "expertise" (see below). Such efforts predominantly occur in the US, reflecting its political culture.

In parallel, I look at the industry's own moves from emissions to plant operations, then to process design, and most recently to chemical reactions. Even through industrial chemistry and process engineering seem to be highly "material", or very difficult to change technically, the evidence is that considerable interpretive work happens, and has happened, in how processes and reactions are thought about. The interesting question, then, is what is driving these new kinds of interpretive work. In part, I attribute this work to tests of new ways of people working together inside plants; the recognition by firms of site-specific knowledge; the emergence of computer modeling as a tool for interpretive play; and new interpretive procedures for studying processes. These are examples of experiments with tools and practices on the industry's part. Then I analyze the emergence of green chemistry, whose proponents argue that, rather than perceiving processes as sources, it is the underlying chemical reactions and their products that should be the target of attention. Interestingly, in the US, it has been regulators who have sought to promote green chemistry, whereas in Britain the ideas of green chemistry took much longer to emerge and were principally supported by academic chemists. I therefore explore green chemistry as an effort by various actors to shape actively what prevention at "source" is understood to mean. Nonetheless, I note that regulators, environmentalists, and citizens are little aware of many of these developments - which presents difficulties for "seeing" and "believing" now and in the future. The chapter concludes that interpretive work can, and does, happen in the chemical industry, thus allowing the kinds of activities seen in the remaining chapters.

Chapter 5 considers the role of regulatory expertise and authority in gaining access to plants and influencing company decision-making. Because prevention is not mandated, regulators are faced with the problems of persuading the chemical industry to undertake preventive activities viewed as site-specific. Whereas British regulators have long recognized - and derived authority from - site-specific expertise and persuasion as central to regulating pollution, their American counterparts have favored a command-and-control practice in which they check the compliance of sites against, and acquire authority from, regulatory requirements. Thus, British regulators should logically be better able to bring about prevention in the chemical industry, if regulatory tradition is thought to be determinative. But in the 1990s, there have been repeated, perplexing failures by regulators in both countries to intervene effectively in plants, irrespective of whether "inductive" (looking at specific settings) or "prescriptive" (making rules regardless of settings) methods are employed. Both countries have tried inductive methods, but these have not worked for different reasons.

I review these failures in detail, as well as various experiments by regulators in each country to try to fashion new ways of regulating in such unpromising circumstances. They have sought to develop new forms and configurations of regulatory expertise, in order to be able to gain entry to plants. Frequently, they have borrowed from the decentralized experiences of private actors. What is striking is that, in Britain, the experiments still remain within the site-specific regulatory tradition, without attention to either their "seeability" or to the involvement of actors other than firms and regulators. In contrast, US regulators are taking more interest in building the capacity to see and believe. For instance, I look at the US EPA's Project XL framework and find it instructive that the majority of chemical plants seeking to participate withdrew their applications. Only one plant so far has proceeded - but that plant's experience is very recent and suggests that the EPA is working to enlist environmental groups and citizens as persuaders alongside regulators (in great contrast to their British counterparts). The chapter concludes that the perplexing puzzle of why regulation has not been effective so far reveals much about the character of pollution prevention. Prevention cannot simply be brought into existence through definitions or regulatory mandates that are really voluntary. Prevention, with its highly particular, site-specific features, challenges the capacity of governments to impose their regulatory templates onto decentralized activities. Rather, a culture of seeing and believing needs to be built to support preventive activities.

Chapter 6 looks at whether and how citizens and environmental groups seek to gain entry to plants, and to participate in preventing pollution. A contentious issue in pollution prevention is whether or not environmental groups and citizens are able to act as "experts" in their own right and to deal with the technical aspects of prevention (as outlined in Chapter 4). I explore the ways in which citizens and environmental groups have invoked and interpreted "expertness" with regard to politics and overseeing industry activities, the health effects of pollutants, or varying local conditions. I explore how prevention in the US has tended to reflect the economic and technical priorities of firms, whereas environmental groups and local activists stress human health concerns in seeking to gain entry to plants. In Britain, health concerns have only just begun to appear, reflecting the contingent nature and different timing of the political and regulatory crises that each country faced (seen in Chapter 3).

I argue that, in the US, there is some growing experimentation in defining expertness and with ways of entering plants. A number of private groups have tried to enlist industry and government experts in the work of examining plants and processes. They have used different routes and institutions to do so. Sometimes, they rely on experts (notably, retired engineers who volunteer to help); at other times, they claim the authority and credibility of expertise in their own right. I examine how these various activities - ranging from good neighbor agreements, citizen campaigns, to collaborative teams of activists and company staff - have begun to shift the boundaries between plants and communities, between experts and lay people. These activities show that plants are unlikely to be fully accessible without access to technical expertise, and that no negotiation process will fit every situation. In contrast, British environmental groups do not seek entry to plants, but to illuminate the pollution that chemical firms generate. In part, this reflects the political culture prevailing in Britain: not only are there considerably fewer environmental groups that target industrial pollution, there is also a lower level of local activist intervention. There is far less experience in seeking to enter plants in Britain. The chapter concludes that extensive, ongoing interpretive work underlies the making of "expertise" in preventing pollution. Expertise is intertwined with efforts to make institutions for entering plants.

Chapter 7 appraises the ways in which quantifying pollution and waste in plants and processes have come to be important for performing prevention. Prior to the mid-1980s, firms focused on the emissions exiting their plants, yet they began to locate preventive opportunities inside processes. I examine the experiments in which chemical engineers and process operators used quantification through waste audits and process surveys (or "mapping") as means to demonstrate to their fellow employees and their companies that pollution should be regarded as part of processes. In this way, some actors inside firms created new "tools" that could be used to interpret the existence of pollution. These tools helped move many firms towards understanding that previously "immutable" processes could be changed to reduce pollution. This occurred first in the US chemical industry, with some firms testing methodologies of mapping processes. In contrast, British firms were initially less inclined to engage in such tests. As a result, "mapping" activities have helped transform pollution and preventive activities into visual terms imbued with great persuasive value. These activities have also helped create new "witnesses," or actors who can testify to pollution prevention's occurrence and possibilities.

Next, I investigate how governments in Britain and the US have respectively made regulatory requirements (or not) for the chemical industry to survey its processes and plants. They have taken divergent routes in taking up the experiences generated by the industry's decentralized activities into regulatory form. Seeing the results of "mapping" in the US chemical industry, British regulators have sought to enforce mapping activities as compatible with valued site-specific knowledge. Their American counterparts have left it to the chemical industry to decide on whether and what to look for. In this regard, the British regulatory approach enforces pollution prevention more than the American voluntary approach. Significant, yet incomplete, advances have been made in the British chemical industry in visualizing processes. Finally, I explore the ways in which mapping activities are nonetheless aimed at specific kinds of witnesses in both countries: those working within plants or companies, rather than regulators and environmental groups. This reflects, and reinforces, the confidentiality of the industry with regard to the interior of plants.

Chapter 8 analyzes the development of pollutant inventories as indicators, or means for "outsiders" to plants to witness progress in preventing pollution. Inventories, such as the Toxics Release Inventory, have rapidly become accepted as evidence of progress by the chemical industry. Yet many actors have come to view numbers as in need of further elaboration if these are to establish that prevention has taken place. In their view, pollution needs to be connected to prevention at specific places. First, I compare the appearance of the Toxics Release Inventory in the US and the Pollutant Inventory in Britain. In the US, pollution numbers have come to be widely used as means for demonstrations by regulators, firms, and environmentalists to prove that prevention needs to be undertaken, and that progress is, or is not, being made. I explore how these numbers were imbued with persuasive value through the creation of new interpretive conventions, such as those associated with emission reductions. To explain the initial failure of pollution numbers to acquire persuasive force in Britain in the early 1990s, I invoke the differences in political cultures between the US and Britain. This illustrates how a culture of seeing and believing needs to be built if there are to be witnesses capable of using pollutant inventory numbers.

Despite the considerably greater visibility of emission releases in the US, activists are paradoxically calling for numbers to be embedded in the context of specific plants and their prevention measures. Environmental groups and local activists in the US increasingly demand that they should be able to observe preventive activities occurring inside plants, not just the reductions in emissions that firms point to as proof of prevention. They have realized that emission reductions do not necessarily equate to pollution prevention. In contrast, in Britain, environmental groups are still trying to establish a culture of seeing and believing in order to be able to say that their numbers reveal the pollution of companies. Many actors in both countries view pollution numbers as most persuasive when these are related to specific sites. Yet both Britain and the US have neglected the possibilities of the most specific kind of quantitative information, namely process level data, in helping establish what firms are doing inside their plants. There have been very few experiments with regulators and local activists in using process level information to work with companies. This is partly because of the confidentiality that is assumed by the industry to surround the practicalities of prevention.

In Chapter 9, I draw conclusions about how the interpretive model of learning can illuminate the emergence of pollution prevention in Britain and the United States. These conclusions include:

· Pollution prevention emerged as a new regulatory possibility, not through conventional learning about environmental problems, but out of culturally and politically specific crises and contingencies in Britain and the US respectively. Prevention, then, shows how new regulatory possibilities result from seeing and responding to the political challenges of how to shore up regulatory authority, not necessarily from identifying environmental problems.

· Pollution prevention did not appear by itself, but needed extensive interpretive work by a wide range of actors to be embedded in institutions and practices. Such work involves persuasion, demonstration, and other activities. This happened in different ways in different places and over different periods. Simply regulating, or at least proclaiming a regulatory preference for prevention, does not lead to pollution prevention taking hold. Rather, social and spatial spaces need to be created for experiments in interpretive work.

· To enable particular institutions and practices to take hold, both nationally and at many local sites, a culture of "seeing and believing" has had to be created and built up through often site-specific, decentralized experiments with "tools" (like pollution numbers) and practices (like ways of bringing community activists inside chemical plants). These experiments help make pollution prevention highly variable within and between countries.

· This experimentation, in turn, has generated many further difficulties for regulators and other actors that are still being realized, let alone responded to. While experimentation can produce valuable experience and innovation, it can weaken regulatory efforts to bring about environmental protection, without looking at how the social and spatial spaces where experiments happen are shaped. Regulation continues to play a central role, but in terms of helping create, enforce, and make public these spaces. "Seeing and believing" need to be attached to these spaces; and we can do this through policy innovations.

Finally, I make some practical recommendations as to creating a "seeing and believing" culture, and attaching this culture to the social and spatial spaces where prevention may take place. They pertain to institutional and regulatory means to empower citizens to make locally contingent, yet enforceable, agreements with industry and regulators; to provide expert and financial resources to activist groups; and to make inductive regulatory processes more easily seen and tracked by regulators.

My bottom line conclusion is that regulation by government is central to the continuing emergence of pollution prevention. It is very difficult to assure that cooperative, voluntary approaches will "work" without careful attention to institutionalizing their visibility and openness to participation by actors outside plants. This insight is based on my extensive evidence of how regulation has facilitated and enforced the invention of tools, institutions, and practices. Many actors in the US, for example, increasingly realized that definitions were insufficient and started to develop tools, such as pollution numbers and waste audits, to "see" prevention more readily. Despite all the experiments with voluntary activities, regulation continues to be a site where many contests over interpretive conventions and access to experiments are fought out. This will shape the chemical industry's development in the next few decades as a transition to green chemistry occurs.

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For Academic Citation: Iles, Alastair. “Learning to Prevent Pollution: The Chemical Industry in Britain and the United States.” Paper, .

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