ENVIRONMENTAL COMPLIANCE ANALYST AT CCI WASTE AND RECYCLING: THE
IMPORTANCE OF ENVIRONMENTAL COMPLIANCE IN AN ENVIRONMENTALLY
SENSITIVE INDUSTRY
BY
JASON BUSELLI
CAPSTONE INTERNSHIP
Submitted in partial fulfillment of the requirements
for the degree of Master of Science in Natural Resource and Environmental Sciences
in the Graduate College of the
University of Illinois at Urbana-Champaign, 2017
Urbana, Illinois
Evaluation Committee:
Piper Hodson, Academic Advisor and Director of the Online M.S. Program
Richard Brazee, Associate Professor
Robert J. Hudson, Associate Professor
ABSTRACT
Ethics behavior and legal compliance are deeply tied to general business, operations, and human
capital management especially within environmentally sensitive enterprises because the
consequences of noncompliance are two-fold and potentially severe. Monetary penalties, loss of
certifications, or a forfeiture of permits resulting from noncompliance can decrease or even
eliminate revenue streams, which can be particularly damaging to small businesses. Additionally,
publicly released records of noncompliance may compromise a business’ social license to
operate, which could be similarly harmful to small waste management firms. Throughout the
internship with CCI Waste and Recycling Services in Dunmore, Pennsylvania, I worked to
achieve the following goals: to work independently as an Environmental Compliance Analyst I
by the spring of 2017, influence CCI employees to increase environmental compliance and other
green business practices, to understand environmental compliance throughout the waste
management chain (from generator to accepting facility), and how small businesses like CCI fit
into this greater inter-business compliance framework. The internship consisted of formal and
non-formal training exercises, practical on-the-job (OTJ) inspections, audits, regulatory
requirements, local company shadowing experiences, and consistent interaction with employee
and company management.
ii
ACKNOWLEDGMENTS
I would like to thank Joe and Mary Jane Ceminaro for allowing me to shape my
internship experience at CCI Waste and Recycling Services to give me the best possible learning
experience. Their flexibility and dedication to my success during my time at CCI enabled me to
become a better, more aware manager and environmental steward. Joe Ceminaro’s mentorship
within the general business management realm was also extremely beneficial as I begin my
studies for a Master’s in Business Administration.
Additionally, I would like to thank Renee Gracon and Piper Hodson for their dedication
to my academic success both within this capstone experience and during the entirety of my
academic journey at the University of Illinois at Urbana-Champaign.
iii
TABLE OF CONTENTS
CHAPTER 1: INTRODUCTION…...….........................................................................................1
CHAPTER 2: LITERATURE REVIEW...……..............................................................................5
CHAPTER 3: INTERNSHIP..........................................................................................................9
CHAPTER 4: DISCUSSION…....................................................................................................19
CHAPTER 5: CONCLUSION…………………..........................................................................23
REFERENCES .............................................................................................................................24
APPENDIX A: SURVEY..............................................................................................................27
iv
INTRODUCTION
CCI Waste & Recycling Services (CCI), is an environmentally sensitive small enterprise.
The company transports thousands of kilograms of potentially environmentally harmful waste
daily. CCI distributes residential, commercial, and industrial waste disposal receptacles,
processes these units, and delivers them to an accepting regional waste management location.
CCI on occasion provides emergency environmental waste clean-up services for the natural gas
industry in Northeastern Pennsylvania. Additionally, CCI is a certified special regulated waste
hauler that transports materials such as contaminated soils and asbestos waste (friable and nonfriable).
CCI complies with national Environmental Protection Agency (EPA), Pennsylvania
Department of Environmental Protection (DEP) and Department of Transportation (DOT)
standards for both waste transportation and regulated waste cleanup operations. The daily
activities of CCI compliance training coordination, logistical planning, and coordination with
local facilities and regulatory organizations during transportation operations.
The U.S. EPA (EPA) imposes federal laws and mandates, but it delegates much of the
enforcement authority to the state level where it is much more manageable. The DEP enforces
state laws and regulations to prevent pollution, protects natural resources, promotes safe disposal
and recycling of wastes, and ensures timely cleanup of contamination. CCI interacts primarily
with the Pennsylvania DEP. CCI must abide by 40 CFR (EPA) Hazardous Waste Regulation,
which is enforced by the DEP through Title 25 of the Pa. Code, during solid waste
transportation. For CCI to begin legally transporting waste, the regulatory guidelines mandate
obtaining licensure (25 Pa. Code § 263a.13) and EPA identification codes (40 CFR 263.11),
1
submitting completed Form HW-C regarding the history of compliance with environmental
protection requirements (annually), preparing a transporter contingency plan, and depositing a
collateral bond set forth in 25 Pa. Code § 263a.32 to offset potential compliance infractions.
These processes are part of a yearly audit procedure, which results in a renewed DEP license and
the ability to legally accept waste for transport.
The recordkeeping process ensures accountability of waste through the transportation
chain from the generator to the accepting facility. The formal procedure begins with the
completion of Uniform Hazardous Waste Manifests (EPA Form 8700-22) governed by (40 CFR
263.20(a)-(c) and 25 Pa. Code § 263a.20, paragraph (2)). This form, which tracks waste from the
generator to the accepting facility, is given back to the waste generator once the transportation
process is complete. The EPA Form 8700-22 is also utilized to maintain records of yearly totals
of hazardous waste and recycled waste deliveries required for end of the year auditing.
The DOT regulates waste in transport from the generator to accepting facility. Although
this includes all forms of travel (air, rail, sea), CCI deals only with road travel. DOT regulates
CCI through The Waste Transportation Safety (Act 90). Act 90 applies mostly to haulers while
physically in transport under § 285.211. General Requirements. Regulations require that vehicles
are serviceable, leak-proof, litter proof, and tarped (§ 285.213), that companies properly record
waste using waste manifests (§ 285.217), and that loads are marked based on the appropriate
placards (§ 285.218). If there are accidents, spills, or loss of waste of any kind the DEP and EPA
regain jurisdiction over the incident site. The DOT and EPA require training for haulers and
those working within CCI. As part of the internship, I was responsible for tracking and
coordinating the completion of these training requirements in addition to maintaining
serviceability and inspection logs of equipment and waste receptacles.
2
Aside from standard solid waste regulations, CCI encounters additional regulation when
transporting special regulated waste. Asbestos transportation is CCI’s most frequent business
operation involving special regulated waste. Epidemiological research has shown that any
asbestos fiber type, including the most commonly used form of asbestos, chrysotile, causes
mesothelioma in humans (US DOL, n.d.; Mossman and Gee, 1989). Because of the threat to
human health the use, removal, and transportation of asbestos are highly regulated by the
Occupational Health and Safety Act (OSHA), DOT, and the EPA.
The Clean Air Act sets nationally mandated emission standards for hazardous air
pollutants (NESHAP), which includes asbestos. States in coordination with the EPA must
manage airborne contaminants in compliance with the asbestos NESHAP, with regard to
asbestos removal and disposal during building destruction and renovation. Compliance
procedures are a critical component to ensure that workers and bystanders are exposed to levels
of airborne asbestos lower than the dose-response threshold, which has been shown in both
experimental and epidemiological studies to decrease the chance of asbestosis (Yarborough,
2007).
Asbestos has two classifications, nonfriable and friable, which have vastly different
disposal regulations (US DOL, n.d.). A non-friable material cannot be reduced to powder by
hand, while a friable material can be reduced to powder by hand and contains more than 1%
asbestos (US DOL, n.d.). Because of the increased risk of airborne pollutants and exposure,
friable asbestos is more regulated. OSHA provides regulations for the disposal, demolition, and
medical monitoring of employees repeatedly exposed to asbestos, the DOT regulates the
transportation and labeling of asbestos, and the EPA regulates the environmental protection
during handling and preparations for disposal.
3
Unlike what would happen after a petroleum spill, asbestos is a natural mineral and does
not damage the environment when released., Instead, the risk of asbestos-related illness is
almost exclusively a human health concern (Macdonald, 1985). Asbestos is part of our human
environment, and its removal and transition to safer heat resistant insulation alternatives are
critical to mitigate public health risk from the workplace to residential neighborhoods.
CCI also encounters contaminated soil from the natural gas industry. There was a
significant increase in natural gas extraction in North Eastern Pennsylvania in the early 2000’s
due to an advance in cost efficiency of a controversial drilling technique known as hydraulic
fracturing (fracking), which contributed to one of the most substantial domestic energy booms in
the country (Soeder, 2010; Gold, 2012). The regional introduction of fracking created a stark
divide between stakeholders regarding the cost-benefits of the process because fracking releases
toxic chemicals, which can contaminate soil, water sources, and create long-term impacts to
human public health (Finewood and Stroup, 2012). However, small business owners intimately
involved with the extraction process such as CCI saw business opportunities. Like other solid
waste, the excavation and transportation of contaminated soil are governed by the EPA and
enforced by the DEP through 58 Pa.C.S. §§ 3201-3274. CCI excavates affected soil, and
transports it to a soil remediation facility, while other companies handle requirements for in-situ
remediation and/or restoration.
4
LITERATURE REVIEW
The Evolution of Compliance
A common assumption in economics and human behavior is that humans are rational
beings motivated by their given preferences (rational choice theory) (Posner, 1998). From an
elementary environmental management perspective, this could lead to an anthropogenic
overutilization of resources, a principle described by Hardin (1968) as the “Tragedy of the
Commons.”. Environmental legislation and policy, helps ensure that businesses are restrained
from activities that exploit resources unsustainably.
In the case of the waste management industry, environmental law and policy restrict
companies in the sector from consuming a resource as a biproduct of their actions. For example,
steep fines are issued for illegal dumping because illegal dumping costs hundreds of millions of
dollars in environmental damage yearly (Ichinose and Yamamoto, 2011). If acting exclusively by
the rational choice theory, CCI would engage in illegal dumping to increase profits without
regard to their resource depleting actions. Instead, CCI follows compliance regulations that
inhibit this activity, to sustainably operate and protect the environment.
Historical examples of Hardin’s Tragedy of the Commons are plentiful in the rising
industrial economies in the late 18th century. Bound by few environmental laws western
societies saw unrestrained industrial growth followed by sometimes irreversible environmental
degradation (Cameron and Abouchar, 1991). Today, environmental laws and land preservation
activities protect such large-scale degradations and habitat loss (Frank et al., 2000).
Environmental policy has evolved to be deeply rooted in both environmental science and
environmental economics with a goal to partner development with protection through the
greater-use and increased accuracy of market-based instruments for environmental protection
5
(Stavins, 2017). Anthropogenic environmental degradation is often the result of market absence
or the presence of a market that underrepresents the total value of a good (Keohane and
Olmstead, 2016). Expanding on the previously used example, without regulation and acting by
the rational choice theory, CCI would illegally dump solid waste anywhere in proximity without
concern about its impact on the ecosystem because doing so would not cost money. This illegal
dumping could negatively affect the surrounding ecosystem’s function, services, biodiversity and
could over time affect human health. However, illegal dumping is regulated by the threat of stiff
fines and potential licensure loss that is required to operate in accordance with DOT, EPA, or
DEP mandates. Legal dumping is therefore far more appropriate and beneficial for CCI to
practice than illegal dumping. Although this is only one example, environmental protection
protocols are meant to safeguard the environment by bringing environmental degradation to
market.
Motivations for Compliance in the Workplace
Regulator reputation, market pressures, and internally enforced social responsibility
initiatives are all significant driving factors that incentivize small businesses and their employees
to follow environmental compliance procedures and consequently to participate in environmental
protection efforts (Stafford, 2002; Stavins, 1989; Berry and Rondinelli, 1998). Shimshak and
Ward (2005) found that fines decreased violation rates at a rate of nearly 66%. Citations on a
company also decreased violation frequencies throughout businesses in the region because of a
fear of similar fines. The study suggested that regulator reputation is a strong driver of
compliance because the entire region, which is typically enforced by one regulator, is affected by
fining frequency. Additionally, Gunnigham, Thorton, and Kagan (2005) looked at the motivation
for environmental compliance within the chemical manufacturing and disposal industries,
6
environmentally sensitive industries analogous to CCI. They found that within small and
medium size businesses, similar to the size of CCI, demonstrating the perception of an
environmentally sound practice is among the top motivating factors for maintaining compliance
standards. Specifically, within environmentally sensitive industries, such as waste service and
natural resource extraction , compliance is of particular importance to ensure that individual
companies maintain a favorable public image by minimizing adverse impacts to the environment
that are inherent to their respective industries (Cambra-Fierro et al., 2000).
There has been an increase in the quantity and complexity of waste streams associated
with income growth and economic development both in the United States and abroad (Claudia,
2015). Associated with this increase is an increased risk to human and ecosystem health as well
as a growing concern regarding the sectors’ contribution to climate change (Claudia, 2015). The
pressure to meet the growing waste and recycling demand while maintaining the principles of
green economic development provides opportunities for small enterprises such as CCI to expand
to meet the demand. Because of public scrutiny regarding the risks to human and ecosystem
health inherent to the waste and other environmentally sensitive industries, business development
needs careful management (Claudia, 2015). This public perception of environmental friendliness
is of particular importance because it can affect consumer decision making and alter revenue
(Hartman et al., 2005). Small companies such as CCI need to create strong emotional values to
their green brand by strengthening the link of the benefit of using the service to the person or
environment (Hartman and Ibanez, 2006). Compliance is a method to explicitly show a
company’s dedication to environmental protection, thus substantiating the green brand and
maintaining public support during operations. Larger businesses may participate in public
outreach and eco-friendly marketing campaigns to further confirm their green brand. However,
7
sound compliance records are most practical for small companies due to their limited budgets.
Therefore, creating an environment that incentivizes compliance is in the best interest of a small
business such as CCI’s.
8
INTERNSHIP
During my internship with CCI Waste and Recycling Services, I set out to achieve the
following goals: to work independently as an Environmental Compliance Analyst I by the spring
of 2017 (Goal A), influence CCI Employees to increase environmental compliance and other
green business practices (Goal B), and to understand environmental compliance throughout the
waste management chain and how CCI fits into the compliance framework from generator to
acceptor (Goal C). I primarily achieved Goal A through formal and informal compliance training
(DOT Courses, OTJ Training) and every day required responsibilities (manifests, equipment
inspections, etc.). I achieved Goal B and Goal C by applying knowledge learned through
compliance training, academic training on the human dimensions of the environment at the
University of Illinois, previous management experience, and shadowing experiences, and a
significant amount of self-study. I used specific learning objectives and pre-planned activities to
guide me through my internship experience, which I will explain in detail below.
Compliance Analyst Training – Goal A
I attended a series of HAZMAT Transportation Courses primarily through the
Department of Defense (DOD), which provided me with skills and certifications necessary to
work as a compliance analyst at CCI. The courses included the following:
•
DOT HAZMAT Awareness: General Awareness/Function Specific (10 Hrs);
•
DOT HAZMAT: Security Awareness (2 Hrs)
•
Hazard Classes and Divisions (2 Hrs)
•
Shipping Paper (2 Hrs)
•
Packaging (2 Hrs)
•
Marking (2 Hrs)
9
•
Labeling (2 Hrs)
•
Placarding (2 Hrs)
•
Using the HMT (Hazmat Table) (2 Hrs)
•
Carrier Requirements (Highway) (2 Hrs)
Additionally, I attended an Occupational Safety and Health Administration (OSHA)10hours course for general industry about OTJ safety requirements, which are particularly
important to CCI employees while operating heavy machinery. All HAZMAT courses cover
industry specific, commonly encountered regulations within subject areas taught. Because my
classes were through the DOD, CCI’s Mary Jane Ceminaro provided additional OTJ training to
fill training gaps such as regulations regarding asbestos transportation, and requirements specific
to Pennsylvania (not taught in the course). The general HAZMAT training sessions were
specifically geared toward the EPA’s data entry and management systems, standard placarding
requirements, and typical manifests (shipping papers) used during special regulated waste
transport. All formal training was designed to familiarize compliance analysts with essential
EPA and DOT rules and regulations but more importantly to know how to navigate lengthy
regulatory references that apply to a particular industry.
On the Job Compliance Analyst Work
CCI primarily handles unregulated waste and recycling materials in residential and
industrial settings. Typically, compliance is governed by the DEP before and after pickup and the
DOT during transportation. CCI’s compliance procedures are relatively uncomplicated when
compared to downstream waste agencies such as Keystone Landfill (explained below). The
disposal equipment must be leak-proof and litter-proof, the waste must be disposed at the proper
facilities, and all solid waste weights tickets must be tallied for yearly compliance
10
documentation. Additionally, CCI haulers must ensure that there is no HAZMAT or special
regulated waste within the containers. This is accomplished by visual inspections and a prereceptacle delivery survey given to customers about their waste requirements and a post-survey
that ensures there were no changes while loading the containers.
A smaller portion of CCI’s business is with special regulated waste in two forms:
contaminated soil and asbestos. Completing the company’s Uniform Hazardous Waste Manifests
(EPA Form 8700-22) for these two substances was essential to achieving my goal of learning to
efficiently and independently produce required compliance documentation. The Uniform
Hazardous Waste Manifest is a form required by both the EPA and the DOT for HAZMAT or
special regulated waste generators, transporters, and those that store, treat, or dispose of the
material. The form lists the type and quantity of the waste being transported, special instructions
for handling the waste, and space for all handlers’ signatures that are involved in the disposal
process. Each waste handler signs and keeps the manifest for records. Uniform Hazardous Waste
Manifests maintains accountability of the regulated waste in the transportation and disposal
processes. Upon the waste reaching the final destination, the receiving facility returns a signed
copy of the manifest to the generator, providing feedback that the waste has been disposed of
properly. The generator reports this back to the DEP who accounts for total waste disposal
statewide.
During this internship I was responsible for coordinating with asbestos/contaminated soil
accepting locations, ensuring the completion of manifests, and maintaining records while CCI’s
haulers were responsible for ensuring that loads were properly sealed, marked, and placarded.
These processes helped maintain proper accountability of the asbestos waste/contaminated soil
and minimizes risk to CCI’s haulers and the public during the transportation process.
11
CCI participates in environmental audits conducted by the DEP to maintain permits and
licensure. Audits require CCI to disclose all previous violations over the past ten years.
Disclosure is done electronically through an online information management system. Audits
allow the DEP to monitor compliance and provide a method to ensure that companies are not
continuously and negligently disobeying environmental law. Additionally, audits require CCI to
disclose each truck, trailer (receptacle), and hauler that will be licensed. Total yearly weights of
transported solid waste and special regulated waste are also reported during audits. Following a
successful submission of required materials, the DEP issues yearly permits. I was able to take
part in an audit to further my procedural knowledge as a compliance analyst.
Corporate Compliance and Attitudes-Goal B
While generating my internship proposal (GIAF) I was unaware of CCI’s current
compliance and training practices as well as their compliance infraction frequency. I intended to
use my training and OTJ experience to create or enhance an environmental training program for
all CCI employees. I also wanted to track future infraction results to illustrate the effectiveness of
the new program. Before the internship, I underestimated the value of the required DOT/EPA
training. Formal cyclical training requirements with supplemental instruction on a small number
of special regulated waste types that CCI employees encounter makes additional education a
potential waste of working hours. All CCI employees have been working in the waste
management field for greater than five years and are exceptionally knowledgeable on
environmental compliance as it pertains to their roles and responsibilities.
I planned to measure the effectiveness of my new program on employee environmental
attitudes and their knowledge of the subject matter by using a pre and post (training) survey.
Because of my deliberate decision with CCI management to forgo creating an additional training
12
program outside of the required formal training, I modified the questionnaire to provide utility to
management strategies and human capital decision making at CCI by giving management insight
into their employees’ attitudes toward the environment and compliance regulations.
CCI management was interested in understanding the environmental attitudes of the
individual employees within the company. Finding poor attitudes would put the environmentally
conscious mission of management at odds with the indifferent attitude of its employees. The
difference in environmental viewpoints could potentially put the company at risk for future
compliance infractions because of a lack of understanding or empathy for the environment and
environmental regulations (Petts et al., 1999). Similarly, Petts et al. (1999) found that managers
have a higher propensity for optimistic attitudes toward compliance than non-managers, leading
to a “blind-spot” in regards to the company’s likelihood to comply. A stark difference in
environmental attitudes would consequently suggest a need for intervention, such as a shift in
management strategies, or a change in hiring practices to mitigate both the risk of noncompliance
and to create a company culture in line with management policy.
To understand the environmental attitudes of CCI employees, how those views may
influence compliance with environmental regulations, eliminate any manager/non-manger
“blind spots”, and possibly alter human capital decision making, I constructed an environmental
attitudes survey for CCI to distribute.
Survey Design:
The CCI survey is intended to poll all CCI employees that comply with environmental
regulations during day to day operations (N=10). My aim was to collect environmental attitudes
of employees throughout three categories: general, personal, and work related. The general
attitudes section is derived exclusively from questions of the Gallup Inc. Environmental Survey
13
(2017) enabling me to compare the environmental attitudes of CCI employees to those of the
general public. The personal information section is intended to determine an individual’s
willingness and commitment to comply with simple household disposal regulations, while the
work-related section is meant to provide direct feedback to management about workplace
attitudes. All questions that were used from Gallup Inc. (2017) were not modified. The form will
be generated and distributed via Google Forms.
Data will be collected anonymously: participants will have a code. An unbiased
collector will access the the survey responses and summarize the results. Only statistical
information will be reported to CCI management.
Analysis: Descriptive Statistics
Means and standard deviations will be calculated from Likert scale and yes/no questions.
This information will provide a directly comparable data set to Gallup Surveys. Open ended
questions should be reviewed and responses categorized and evaluated by an independent,
unbiased reviewer, to ensure that there is no possibility for a breach in anonymity by
management who might identify employee writing styles.
Hypothesis and Predictions:
I would expect to find a significant difference in the waste employees’ environmental
attitudes versus the general public. I predict that waste management workers would say that the
government is doing an adequate job of protecting the environment (questions 1, 4, 5, 6). I
predict this because CCI workers directly interface with many stringent compliance regulations
that govern their daily activities. For the same reason, I also predict that employees would have a
positive attitude to the current rules influencing environmental problems that the country is
14
facing, which is in opposition to that of the general public as only 26% in 2017 felt that the
government was doing enough to protect the environment (Gallup Inc., 2017).
Insight from Survey Development:
This exercise helped me develop survey design proficiency and was an opportunity to
create a management development product that would provide feedback to my employer about
whether the majority of their employees seem to stand with or against the green brand image of
the company. To help eliminate possible interview artifacts the survey will be conducted
electronically. Management’s known position in the workplace, or their personal writing style
could influence a particular response set from CCI employees (interview artifacts). Social
desirability is choosing the answers that the respondent thinks the researcher or the general
public would like to see (Montello and Sutton, 2012). This particularly relevant to this survey.
All CCI employees know that management is keen on effective environmental compliance and
that the survey is environmentally based. Choosing patterns of extreme compliance would be
favorable to the distributers. CCI will stress the anonymity of the survey taker, and how the
results will be used to better the company. Additionally, order effects are other possible
mechanisms that could decrease my survey validity (Montello and Sutton, 2012). The order
effect is when the order of questions given affects the way a respondent answers. To lessen the
order effect, the order of the items within subsections of my survey are random.
Most of the closed-ended questions are Likert scale responses, which require respondents
to express a degree of agreement or disagreement with a series of statements. Likert scales
typically have from 4-9 response- choices (Montello and Sutton, 2012) because fewer options
would not provide adequate validity to which a human can make, while more than nine would
provide too many options to a point at which discrimination cannot be done. For this survey
15
Interval data are statistically manipulated to provide the best possible feedback to CCI. After
looking at commonly used surveys, such as the New Ecological Paradigm and Gallup
Environmental Survey, questions from the Gallup Environmental Survey were selected because
many questions specifically related to compliance and government action. Gallup Inc. also has
data ranging back to the early 1980’s, which can be used to compare CCI employees to recent
U.S. averages.
The survey contains both open-ended and closed-ended items. Although open-ended
responses are not quantitative data, they are behavioral records, which may be coded to make
qualitative data. In this case, open-ended items will be aggregated and summarized in order to
formulate suggestions to CCI management. Quantitative data will come from closed-ended
questions. For example, I asked the following question: What needs to be done to make
compliance easier? CCI management will use the ten employee responses to help develop
strategies for management to ensure that they are providing their employees with the necessary
tools for success if needed.
Petts et al. (1999) found that employees with a lack of understanding or empathy for the
environment and environmental regulations have a greater risk of committing compliance
infractions. The Gallup poll questions provide an opportunity to understand CCI workers’
empathy toward the environment. Gallup polls historically have found the public to believe that
business/industry does not support environmental protection (Dunlap and Scarce, 1991). Finding
consistent results that suggest CCI employees feel that there are currently adequate protection
measures in place would put CCI in opposition to Gallup poll trends, and could suggest a passive
stance toward further environmental protection regulation. Poortinage et al. (2004) found that
people put more emphasis on how their decisions affect outcomes when they value what is in
16
question. The Gallup Environmental Polls help reveal environmental values through attitudes
toward environmental protection and therefore may assist in determining a relationship between
compliance and environmental attitudes in waste management employees. Further distribution
of this survey in different businesses is necessary to determine if a correlation between
environmental attitudes and compliance infractions exist (see below suggestion for future
studies).
Aside from Gallup poll questions, it is hoped that work related questions will provide
CCI management with immediate suggestions for training needs, attitudes toward compliance,
and ways to improve the work environment for haulers.
Future Studies:
To strengthen the validity and reliability of the survey, the same survey can be delivered
to similar companies within the waste management industry. Survey answers/environmental
attitudes can be compared with total compliance infractions of each company. This comparison
would help determine whether the survey (aside from direct feedback open-ended questions) is
appropriate to use for management decision making by relating answers to the survey to the
likelihood of compliance.
The IRB did not review the survey, and it was not distributed the during my internship,
therefore the results be reported in this paper. I will, however, work closely with management in
the future to determine from the survey results (if they choose to distribute it) whether they see a
need to alter management strategies, initiate additional training or motivational programs or
adopt different hiring practices.
Compliance from Generator to Accepting Facility- Goal C
17
My final goal was to understand environmental compliance throughout the waste
management transportation chain and how CCI fits into the compliance framework. This goal
was accomplished primarily through a shadowing opportunity at the Keystone Landfill.
Keystone is the terminal location for non-hazardous waste, friable asbestos, and contaminated
soil. Waste is compacted and disposed of in permitted disposal areas, and friable asbestos is
maintained in one pad of the landfill. Contaminated soil delivered to the site, is remediated and
used as fill. CCI must deliver non-friable asbestos to another landfill nearly 75 miles away in
Tiago County. Solid and asbestos waste generates three transactions (generator, hauler, landfill)
while contaminated soil generates two transactions (hauler to the landfill with remediation
capabilities) Non-friable asbestos is the only waste not delivered to Keystone unless there is a
more cost beneficial landfill location for a specific job.
Currently, Keystone Landfill has 135ha of permitted disposal area. There is also an
unlined, non-operational, 43ha disposal area that served as a former disposal facility when
environmental considerations were less stringent during waste management process. With the
Director of Compliance Operations, I toured the premises and witnessed the entire disposal
process, from the weigh-in, to off-load, to waste compaction, to waste covering, and by-product
recycling, among other things.
18
DISCUSSION
Compliance training through the DOT and EPA does not require perquisite
environmental science academic training. However, the coursework that I’ve experience at the
University of Illinois at Urbana-Champaign allowed me to make connections between regulation,
science, and the stakeholders that are affected. For example, a portion of the DOT solid waste
training focused on litter prevention (spillage and lost waste) during transport and proper odor
control. Although it may be evident that litter generation can negatively affect the environment,
litter in addition to odors affects the human environment via perceived amenity. The local
community suffers from litter and odor via a loss in the environmental amenity, which is
typically monetized using hedonic pricing studies to measure the effects on local housing
markets (Rabl, 2008).
This loss of perceived amenity is minimal while considering the effects of only CCI. One
must instead look at the compounding effects of litter and odor generation from various waste
accepting facilities. Keystone landfill, for instance, is a repository for thousands of kilograms of
solid waste daily. A very high priority for Keystone’s compliance division is to prevent litter and
odor because public complaints are very likely to occur if litter and odor are present, which could
negatively affect their standing with the local community. Landfills can decrease local housing
prices, which increase with the size of the landfill site, decrease with the age of the landfill, have
a higher impact on high valued properties and less impact in more built up areas (Rabl, 2008).
The decrease in housing prices because of a loss of amenity may contribute to why the existence
of Keystone Landfill is a contentious subject for Dunmore Pennsylvania residents. Keystone
landfill accepts waste from regional producers, and the adverse effects of waste management
such as odor, litter, and large truck traffic are realized almost exclusively by Dunmore residents.
19
Environmental compliance in this industry minimizes the impact to the community and
enables a sustaining business operation. It is also important to note that the landfill’s success is
what drives the success of local businesses throughout the waste management chain including
CCI. For the past two years, Keystone has been applying for additional permits to expand. The
expansion is causing mixed emotions within different stakeholder groups of the town (Writer,
2016). Keystone relies on its green strategic public image to gain support from the local
community, which is currently hesitant to support an increase in landfill operations. This green
strategic image is achieved by sound compliance, preventing decreases to amenity, and
community outreach. For example, Keystone puts significant effort to satisfying the public by
acting immediately to odor complaints and sends out daily trash collecting patrols multiple times
daily. Additionally, Keystone participates in area beautification activities on a yearly basis.
Like Keystone Landfill, CCI is reputation-sensitive and relies on environmental
compliance to maintain permits and licensure and presumably consumer demand for services.
Although anecdotal, a CCI manager noted how a local company went out of business after it was
cited for illegally dumping waste, some of which contained regulated solid waste (J. Ceminaro,
personal interview, May 2016). The company faced more than a $10,000 fine, a temporary loss
of necessary permits, and a decreased customer base following the publication of the citation (J.
Ceminaro, personal interview, May 2016). This incident supports why strategic green branding is
important in the reputation-sensitive waste management industry and demonstrates a market
pressure that incentivizes environmental compliance to maintain business operations. Aside from
this “social license to operate”, which is the green reputation and the subsequent support of the
consumer that helps keep a high demand, this evidence also demonstrates the power of
governmental agencies to promote environmental protection (Gunnigham et al., 2005). A single
20
case was enough to incentive CCI management emphasize environmental compliance within
CCI because a loss of required permits would force CCI to rely on non-waste business efforts,
which is less than 20% of its current income base (J. Ceminaro, personal interview, May 2016).
Throughout the past two years, CCI has been infraction free, likely because of their
skilled employee base, local regulator reputations, and most importantly CCI management’s
emphasis on ethics and environmental stewardship. Environmental stewardship in the workplace
is best accomplished through sustained inspection and corporate culture development
(Gunnigham, et al., 2005, Petts et al., 1999). CCI’s onsite management (site visits, ride alongs,
etc.) and daily hands-on interactions with staff provide an effective example of how to lead a
company and promote their environmentally friendly mission.
Throughout this internship, I took a practical look into the “human dimensions of the
environment”; the interaction of key stakeholders and subsequent actions leading to a change in
the well-being of the environment. Environmental stewardship within this industry is mandated
by compliance through regulatory agencies but promoted by the passion of everyday individuals.
A key to ensure compliance and consequently, the environmental benefits associated with
compliance, is to inform employees of the importance of compliance and to motivate them to
proceed with ethically sound behaviors (Boiral, 2009). Through everyday conversations with
staff I was able to explain my studies, how they related to CCI, and why they were important.
For instance, I commonly explained how CCI employees were engaging in environmental
protection during their contaminated soil clean up jobs. Drawing upon my Ecological
Restoration coursework (Transfer Coursework- spring 2013), I was able to explain how this
contaminated soil excavation and reclamation process protects local waterways from the harmful
effects of runoff. I also explained hedonic pricing, a principle that I learned in Environmental
21
Economics (Transfer Coursework- spring 2013), its relation to litter control and how something
such as tarping to prevent litter was necessary to CCI and the local community. These
interactions were an opportunity to interface with cross-functional backgrounds to explain
science based regulations and were perhaps the most beneficial part of this internship. My
interactions with employees allowed me to use my subject matter knowledge in environmental
sciences to substantiate the importance of compliance activities and to, therefore, motivate
employees to continue to comply. Although mere compliance is possible with the DOT/EPA
mandated training, motivation to comply can be increased when the reason for the policy is
explained and understood by the employee. This motivational leadership to instill environmental
awareness across different professions (and associated personal incentives) is in my opinion an
essential task to promote environmental stewardship in the workplace.
Environmental stewardship within an environmentally sensitive industry helps create and
maintain a favorable public image and the ability to attain state and federal licensure, which
could be compromised by consistent noncompliance. High rates of noncompliance or poor
attitudes within an environmentally sensitive industry would suggest a need to alter management
strategies, initiate additional training or motivational programs or adopt different hiring
practices. The survey (Appendix A) is a tool to obtain feedback on the environmental attitudes of
the employees. which could provide early warning to noncompliant behaviors and enable
management to pursue preventative actions. The survey can also be used to screen potential
employees, to ensure that environmentally conscious individuals are placed in positions where it
is useful.
22
CONCLUSION
The primary purpose of an internship at CCI as an Environmental Compliance Analyst
was to begin bridging science with management in the natural resource field. Interning within the
waste management industry allowed me to experience firsthand the delicate balance between
environmental stewardship and business management. Being academically trained in the
sciences, it is easy to lose sight of the main stakeholder groups, such as waste industry business
operators, that benefit from activities that are sometimes at odds with environmental
conservation. This experience showed me that through compliance, environmental protection and
economic development are not always opposing efforts. Compliance is designed to mandate
necessary levels of environmental stewardship. Individual managers can create a positive
corporate environment to promote compliance and stewardship beyond minimum compliance.
I am better prepared to serve as a manager based on an understanding of the complexity
of human factors because of my work at CCI. Similarly, CCI management has a better
understanding of the how compliance is linked to not only how they convey their mission and
vision to their employees, but also how their employees view the regulations that they must
follow. To understand attitudes about waste management, environmental compliance/protection,
and economic development is to comprehend the interwoven factors that drive the actions of
stakeholder groups. I will use my experience as an intern in an environmentally sensitive
company to develop solutions to environmental problems in a management setting that provides
utility and seeks equity for all stakeholder groups.
REFERENCES
23
Berry, M. A., & Rondinelli, D. A. (1998). Proactive corporate environmental management: A
new industrial revolution. The Academy of Management Executive, 12(2), 38-50.
Boiral, O. (2009). Greening the corporation through organizational citizenship behaviors.
Journal of Business Ethics, 87(2), 221-236.
Cambra-Fierro, J., Hart, S., & Polo-Redondo, Y. (2000). Environmental respect: ethics or simply
business? A study in the small and medium enterprise (SME) context. Journal of
Business Ethics, 82(3), 645-656.
Cameron, J., & Abouchar, J. (1991). The precautionary principle: a fundamental principle of law
and policy for the protection of the global environment. BC Int'l & Comp. L. Rev., 14, 1.
Ceminaro, J. (2016, May). Personal interview.
Claudia, O. G. R. E. A. N. (2015). Corporate initiatives and strategies to meet the environmental
challenges–contributions towards a green economic development. Studies in Business
and Economics, 10(3), 62-70.
Cosgrove, B. M., LaFave, D. R., Dissanayake, S. T., & Donihue, M. R. (2015). The economic
impact of shale gas development: a natural experiment along the New York/Pennsylvania
border. Agricultural and Resource Economics Review, 44(2), 20-39.
Dixon-Fowler, H. R., Slater, D. J., Johnson, J. L., Ellstrand, A. E., & Romi, A. M. (2013).
Beyond “does it pay to be green?” A meta-analysis of moderators of the CEP–CFP
relationship. Journal of Business Ethics, 112(2), 353-366.
Dunlap, R. E., & Scarce, R. (1991). Poll trends: Environmental problems and protection. The
public opinion quarterly, 55(4), 651-672.
Finewood, M. H., & Stroup, L. J. (2012). Fracking and the neoliberalization of the hydro‐social
cycle in Pennsylvania's Marcellus shale. Journal of Contemporary Water Research &
Education, 147(1), 72-79.
Frank, D. J., Hironaka, A., & Schofer, E. (2000). The nation-state and the natural environment
over the twentieth century. American Sociological Review, 96-116.
Gallup, Inc. (2017, March). Environment. Retrieved June 21, 2017, from
http://www.gallup.com/poll/1615/environment.aspx
Gold, R. 2012. Oil and gas boom lifts U.S. economy. The Wall Street Journal. February 8, 2012.
Accessed
at http://online.wsj.com/article/SB10001424052970204652904577195303471199234.ht
ml on May 10, 2017.
24
Gunningham, N. A., Thornton, D., & Kagan, R. A. (2005). Motivating management: corporate
compliance in environmental protection. Law & Policy, 27(2), 289-316.
Hardin, G. (1968). The tragedy of the commons. Science, 162 (3859), 1243-1248.
Hartmann, P., Apaolaza Ibáñez, V., & Forcada Sainz, F. J. (2005). Green branding effects on
attitude: functional versus emotional positioning strategies. Marketing Intelligence &
Planning, 23(1), 9-29.
Hartmann, P., & Apaolaza Ibáñez, V. (2006). Green value added. Marketing Intelligence &
Planning, 24(7), 673-680.
Ichinose, D., & Yamamoto, M. (2011). On the relationship between the provision of waste
management service and illegal dumping. Resource and energy economics, 33(1), 79-93.
Keohane, N. O., & Olmstead, S. M. (2016). Market-Based Instruments in Practice. In Markets
and the Environment (pp. 199-230). Island Press/Center for Resource Economics.
McDonald, J. C. (1985). Health implications of environmental exposure to asbestos.
Environmental health perspectives, 62, 319.
Montello, D., & Sutton, P. (2012). An introduction to scientific research methods in geography
and environmental studies. Sage.
Mossman, B. T., & Gee, J. B. L. (1989). Asbestos-related diseases. New England Journal of
Medicine, 320(26), 1721-1730.
Petts, J., Herd, A., Gerrard, S., & Horne, C. (1999). The climate and culture of environmental
compliance within SMEs. Business Strategy and the Environment, 8(1), 14.
Poortinga, W., Steg, L., & Vlek, C. (2004). Values, environmental concern, and environmental
behavior: A study into household energy use. Environment and behavior, 36(1), 70-93.
Posner, R. A. (1998). Rational choice, behavioral economics, and the law. Stanford Law Review,
1551-1575.
Rabl, A., Spadaro, J. V., & Zoughaib, A. (2008). Environmental impacts and costs of solid
waste: a comparison of landfill and incineration. Waste Management & Research, 26(2),
147-162.
Shimshack, J. P., & Ward, M. B. (2005). Regulator reputation, enforcement, and environmental
compliance. Journal of Environmental Economics and Management, 50(3), 519-540.
Soeder, D. J. (2010). The Marcellus shale: resources and reservations. Eos, Transactions
American Geophysical Union, 91(32), 277-278.
25
Stafford, S. L. (2002). The effect of punishment on firm compliance with hazardous waste
regulations. Journal of Environmental Economics and Management, 44(2), 290-308.
Stavins, R. N. (1989). Harnessing market forces to protect the environment. Environment:
Science and Policy for Sustainable Development, 31(1), 5-35.
Stavins, R. N. (2017). The Evolution of Environmental Economics: A View from the Inside. The
Singapore Economic Review, 62(02), 251-274.
United States Department of Labor (n.d.). Asbestos. Retrieved June 01, 2017, from
https://www.osha.gov/SLTC/asbestos/
Writer, K.Y (2016, November 03). Keystone landfill expansion facing organized opposition. The
Times Tribune. Retrieved July 10, 2017, from http://thetimes-tribune.com/news/keystonelandfill-expansion-facing-organized-opposition-1.1781974
Yarborough, C. M. (2007). The risk of mesothelioma from exposure to chrysotile
asbestos. Current Opinion in Pulmonary Medicine, 13(4), 334-338.
26
APPENDIX A: SURVEY
Environmental Survey Consent Form
CCI is proud to have a group of dedicated, passionate employees dedicated to the success
of the company and the efficient disposal of materials for processing or recycling. Without your
support, diligence and commitment, the company would be unable to succeed at our tough job to
follow the stringent guidelines of the DEP, DOT, OSHA, and EPA when disposing and recycling
waste.
We are constantly looking at ways in which we can improve the company, and better
serve our community. The first step in this process is to determine how to find more employees
like yourself. We invite you to participate in this 10-15 minute survey to determine your
attitudes regarding the environmental and regulatory procedures related to this job.
****Your responses are confidential and anonymous. Only aggregate data will be shared
with CCI Management. This survey will provide the management team with information that
will enable them to maintain the company’s green image by helping them to identify what
qualities that they would like to see in future employees. If you consent to participate, the link to
the electronic survey will be sent to you within 5 days and you will have 10 days to complete the
survey.
If you have any questions regarding the survey, please feel free to contact Jason Buselli at
215-932-5812 or buselli2@illinois.edu.
Please select your choice below and sign and date in the space provided. Checking “Agree”
indicates that:
•
•
•
You have read the above information
You voluntarily agree to participate
You are 18 years of age or older
Agree
Disagree
Signature: ___________________________________________________________________
Date: _______________________
Email Address:__________________________________
27
Environmental Attitudes Survey
Directions: You can only take the survey once, but you can edit your responses until the survey is
submitted. Please select responses that best apply to the question provided. Open-ended questions require
a typed response. Please respond to all questions.
GENERAL
*1. With which one of these statements about the environment and economy do you most agree?
a) Protection of the environment should be given priority, even at the risk of curbing economic
growth.
b) Economic growth should be given priority, even if the environment suffers to some extent.
*2. Thinking about what is said in the news, in your view the seriousness of global warming is,
a) Generally exaggerated
b) Generally correct
c) General underestimated
*3. For each of the following problems facing this country, please select the response that best
corresponds to your level of concern:
a) A great deal
b) A fair amount
c) Only a little
d) Not at all
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
Pollution of rivers, lakes and reservoirs.
Air pollution.
Global warming or climate change.
Pollution of drinking water.
Extinction of plant and animal species.
Contamination of soil and water by toxic waste.
Urban sprawl and loss of open spaces.
Maintenance of the nation’s supply of freshwater for household needs.
Damage to the earth’s ozone layer.
Acid rain.
Loss of natural habitat for wildlife.
Ocean and beach pollution.
Contamination of soil and water by radioactivity from nuclear facilities.
*4. Do you think the US government is doing too much, too little or about the right amount in terms of
protecting the environment?
a) Too much
b) Too little
c) About the right amount
*5. How would you rate the overall quality of the environment in this country today?
a) Excellent
b) Good
c) Fair
28
d) Poor
*6. Right now, do you think the quality of the environment in the country as a whole is getting better,
worse or staying the same?
a) Better
b) Worse
c) Staying the same
PERSONAL
*7. Do you consider yourself an environmentalist?
a) Yes
b) No
*8. If you answered “yes” to #7, do you consider yourself a strong environmentalist?
a) Yes
b) No
9. How often do you recycle at home?
a) Never
b) 1-2 times weekly
c) 3-4 times weekly
d) All the time
10. At home, what do you do with your hazardous materials (batteries, gasoline, explosives)?
a) Throw away in municipal waste container
b) Dispose all HAZMAT at an accepting facility
c) Dispose some HAZMAT at an accepting facility
11. To what extent does your on-the-job training affect your handling of household biological or
hazardous waste?
a)
b)
c)
d)
A great deal
A fair amount
Only a little
Not at all
WORK RELATED
12. What needs to be done to make compliance easier on the job? (Equipment purchases, additional
training, etc)?
13. How well do you understand the expectations associated with HAZMAT or regulated waste
transportation?
a) A great deal
b) A fair amount
c) Only a little
d) Not at all
29
14. How well do you understand the human health risks associated with handling, storing, and
transporting asbestos?
a) A great deal
b) A fair amount
c) Only a little
d) Not at all
15. To what degree do you feel that complying with contaminated soil disposal regulations positively
affects the environment?
a) A great deal
b) A fair amount
c) Only a little
d) Not at all
16. To what degree do environmental training programs from regulatory agencies prepare you for
your everyday environmental compliance requirements?
a) A great deal
b) A fair amount
c) Only a little
d) Not at all
17. How willing are you to do additional training to minimize personal risk in regards to asbestos
exposure?
a) Very willing
b) Somewhat willing
c) Only a little willing
d) Not at all
18. How willing are you to do additional training to maximize on-the-job efficiency while dealing
with HAZMAT, or special regulated waste?
a) Very willing
b) Somewhat willing
c) Only a little willing
d) Not at all
19. To what degree is CCI an environmentally friendly organization?
a) A great deal
b) A fair amount
c) Only a little
d) Not at all
20. What needs to be done to promote the environmentally friendly image of CCI to the general
public and our clients?
* Questions marked with asterisk are from Gallup, I. (2017, March). Environment. Retrieved
June 21, 2017, from http://www.gallup.com/poll/1615/environment.aspx
30
Purchase answer to see full
attachment
