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Policies for the Promotion of Inherent Safety

In the enthusiasm to address the problems from "gradual" pollution of the environment stemming from expected byproducts and waste of industrial, agricultural, transportation and extraction activities, an important consideration which has received relatively little attention among firms and government is the sudden and accidental releases of chemicals (with attendant energy consequences) that affect both workers and communities. Industrial Ecology is being touted as a new all-encompassing paradigm. Its centerpiece, as practiced, is the creation of an industrial ecosystem involving firms which often concentrate and then exchange materials and waste so as to minimize the costs and environmental effects of the disposal and incineration of waste, and toxic emissions to air, water, and soil (for an in-depth review of Industrial Ecology,see Ashford and Cote 1997).The organizing principle for implementing Industrial Ecology concepts among the exchange partners can be a concern for materials containing a common substance (for example, a metal), an industrial sector (likepetrochemicals), or a geographical area (for example, Kalundborg, Denmark). A pollution prevention/cleaner production focus differs from that of the Industrial Ecology centerpiece in that it argues preferentially for reduction of pollution "at the source" through input (feedstock) substitution, process redesign, and re-formulation of final product (Hirschhorn and Oldenburg 1990). Some commentators have pleaded for an integrated approach incorporating both concepts, as well as a healthy dose of end-of-pipe pollution control where appropriate. This article argues that both pollution prevention/ cleaner production and waste and material exchange, as currently practiced, pose the risk of "media shifting" from environmental problems to worker (and sometimes community) health and safety problems, for different reasons and with different consequences. Examples are drawn from a study of this media shifting found in cleaner production data-bases (Ashford et al. 1996),and from generic examples of materials and waste exchange. First, however, the concept of promoting inherently safer technologies through primary accident prevention is introduced. Finally, a review ofU.S.policies to promote inherent safety is provided. INHERENT SAFETY Inherent safety is an approach to chemical accident prevention that differs fundamentally from secondary accident prevention and accident mitigation. (Ashford 1991; Kletz 1984,1989,1991) "Inherent safety" sometimes also referred to as "primary prevention" relies on the development and deployment of technologies that prevent the possibility of a chemical accident. (3)Bycomparison, "secondary prevention" reduces the probability of a chemical accident, and "mitigation" and emergency responses seek to reduce the seriousness of injuries, property damage, and environmental damage resulting from chemical accidents. Secondary prevention and mitigation, by themselves, are unable to eliminate the risk of catastrophic chemical accidents, although improved process safety management can reduce their probability and severity. Most chemical production involves "transformation" processes, which are inherently complex and tightly coupled. "Normal accidents" are an unavoidable risk of systems with these characteristics (Perrow 1984).However, the risk of serious, or catastrophic, consequences need not be. Specific industries use many different processes. In many cases, alternative chemical processes exist which completely or almost completely eliminate the use of highly toxic, volatile, or flammable chemicals. Normal accidents arising in these systems result in significantly less harmful chemical reactions or releases. Replacement of existing production systems by such benign chemical processes sometimes called "green chemistry," as well as non-chemical approaches, are examples of primary accident prevention. Inherent safety is similar in concept to pollution prevention. Both attempt to prevent the possibility of harm from accidents or pollution -by eliminating the problem at its source. Both typically involve fundamental changes in production technology discussed above: substitution of chemical inputs, process redesign, or final product reformulation. (4)Secondary prevention and mitigation, meanwhile, are similar in concept to pollution control and remediation measures, respectively, in that each involves only minimal change to the core production system. The superiority of pollution prevention as a tool of environmental policy has been recognized for more than a