INTERNATIONAL
Du Pont's environmental men in Europe James Parsons, the first technical director of environmental affairs-Europe, talks of the progress of one chemical manufacturer in meeting a divergence of regulations The Du Pont international activity in Europe represents a $770 million investment including subsidiaries and principal affiliates. Total business of the European group was $556 million. according to 1972 corporate figures. By the end of the 1972 accounting period (Oct. 1972), the company had invested and authorized $16.5 million in environmental controls in Europe and spends about $1.7 million annually on the operation of these controls. in general, the Du Pont plants are modern and exceed
Du Pont's Parsons
"Good neighbors to any community" the local environmental control standards. The investment is probably a bit lower than it would be for comparative, relatively older companies operating in Europe. James Parsons, who arrived on the job in Geneva, Switzerland. last September, teiis ES&T that Du Pont over the years has had a very strong position in environmental controls. "The general policy of the company is that we will protect the environment to the extent that we are good neighbors to any community in which we exist," Parsons says. "in addition, we 118
Environmental Science &Technology
will meet all regulations and laws in these locations." Du Pont plants here manufacture a variety of products but "not as many products as the company manufactures in the U.S." "The European situation has been in good shape right along," Parsons explains, "because of the fact that Du Pont has relatively new facilities over here and, in these plants, installed the best technology available at the time to provide protection to the environment." The first Du Pont facility in Europe, the Mecheien Finishes piant in Belgium, started in the spring of 1959. I n 1960. the comoanv started neoprene production .at -the Maydown plant, near Londonderry in northern ireland. Then in rapid succession, production of "Orlon" at Dordrecht in 1962, photo products at Neu-lsenburg acquired in 1962, "Hylene" at Maydown in 1963, "Mylar" at Luxembourg in 1965, "Teflon" at Mechelen in 1966, and so on. Divergences and generalities It's very definite that the early awareness of environmental quality in the U.S. has reached Europe. And while the U.S. may be ahead today, Europe is definitely catching up very fast. For example, the noise problem, which is just now rearing its head in the U.S., is getting a good deal of attention in Europe. Water pollution is a major concern in Europe because of the limited water supplies, obviously. But air pollution doesn't seem to have anywhere near the pressure in Europe that it has in this country; European concern for air pollution control is farther down on the priority list. Nevertheless, solid waste disposal is a big concern there because o f . the limited amount of land mass that you can landfill. Certainly, there are similarities and differences. In Europe, there is a rather large divergence of regulations, from country to country, and they are different from U.S. regulations. For example, there is a deeper and more dense population in the
location of its industrial plants; industry is more concentrated in certain European areas so that solutions to environmental problems which may be suitable for certain areas in the U.S. may not be suitable in the long run for European facilities. On-site explanation "All of the European countries have regulations and laws which, if properly utilized, would protect the environment quite adequately," Parsons offers. "It's surprising but the laws are generally available, but oftentimes the enforcement is not applied uniformly, being influenced by economics and publicpressure." Enforcement is highly variable. "in general, the Federal Republic of Germany is pretty strict," Parsons notes. "The Netherlands have adequate regulations but since their industrial plants are on the tail end of the European water supply, they are not looking too hard at older sources because they are not getting anything to start with. New sources are closely regulated." At this time, the European Economic Commission (EEC) is making an effort to coordinate the different environmental protection laws in the various countries. EEC aims to provide guidelines on pollution control for the European area. When these guidelines become available later this year, then they will assist the European countries in coming closer to a consistent type of control requirement. There is yet another important point on consistency of controls. I n Europe, there are different types of governments and different types of laws. Each country must work within its own framework of legal requirements, even though each may be aiming at the same standard end point. "In this area the EEC cannot write laws and regulations that are generally applicable," Parsons explains. "EEC has to recommend a performance; then the countries must study it and develop their own
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E NVI ROTE C H
laws or regulations that fit into their governmental situation for control." According to the view of the Du Pont coordinator, the EEC guidelines will be issued from the standpoint of environmental quality. For example, EEC might come out with a level of contamination that is acceptable from the standpoint of no harm to people or vegetation. Then, individual countries will have to establish some type of regulatory procedure to achieve that level. Many of the industries in Europe are old established companies; they have been polluting for years prior to the big drive on antipollution. "It's very difficult to clean up the whole place very rapidly," Parsons continues. "The main thing that most of the countries are looking at now is not to let in any new contaminants that are going to cause trouble later. New facilities are being looked at very closely to see that they will be compatible with the environment." Track record As the Du Pont plants were set up in Europe, each plant had its own environmental control regulation; in other words, company regulations In literally all cases, the plants met the regulations and in many cases, the company regulations were more stringent than the prevailing local regulations. But the problem of environmental control is one that escalates; it has a climbing expectation curve. We are all aware of the U.S. situation. A few years ago, a plant in the U S . would install certain control equipment; then two years later, the controls would be inadequate and the company would have to install something else. "This escalation of controls is undoubtedly occurring in the European situation just the way that it did in the U.S.," Parsons warns. "But it cannot continue ad infinitum." "The Du Pont plants use modern
aimS to reduce the amount of generated in order to be able to produce the goods at a reasonable price," Parsons explains. "I have been with the engineering department for a good deal of my caknow a reer," he explains. " I lot about resources within the com-
Regulations There is some concern today that individual states within certain European countries are not doing an adequate regulatory job, somewhat like the developments in the U.S., at which point the federal government found it necessary to take over a large portion of the air and water pollution control activities. And there is some pressure in various European countries to provide a similar international control. "But I would not necessarily agree that international control is necessarily better," Parsons adds. "National federal regulations may impose stricter regulations in some areas than are needed in order to satisfy that particular area, and there may not be enough regulations in another area. It's probably more true in Europe than for the U.S. Don't forget, in European countries, the industrial manufacturing plants are usually located in a very dense industrial sector of the individual country." International regulations, if applied throughout Europe, cannot be stringent enough in certain industrial situations and too strict in others. "What's more, international regulations could increase the investment required to meet an arbitrary standard without significant environmental improvement, even to the point of making the operation uneconomical," the Du Pont coordinator warns. Other team players "I am not the man in charge of environmental controls at our sites," Parsons explains. "Each site has a so-called 'environmental coordinator' who is locally responsible for seeing to it that the plant meets the regulations and does what is necessary to protect the environment." These men take care of the local situation. Each makes sure that his facility is meeting the controls for that area. I f it is not or when regulations become tighter, then they report to Parsons. "One of my assignments is to assist the local plants and their coordinators in their contact with the regulatory people," Parsons says. "When governmental people write regulations without adequate engineering and scientific input, sometimes they come up with requirements that simply cannot be met. It's our opinion that this type of regulation is worse than none and does little for environmental protection." "We think regulations should be realistic-things that can be done and are necessary to protect the environment," Parsons says. "Du Pont men stand ready to assist European environmental agencies in this type of development." SSM
