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mechanism to transfer this technology to manufacturers in developing countries where compliance with the ban was expected on a more relaxed schedule. By providing technical alternatives, the North American manufacturers hoped to dispel any competitive disadvantage they might otherwise have encountered as a result of making their own process cleaner.

The list of such initiatives is rapidly growing as industries recognize the importance of establishing some sort of collective image of leadership and commitment. The "Encouraging Environmental Excellence" initiative of the American Textile Manufacturer's Institute (ATMI) calls for companies to adopt a 10-point plan to improve the environment, including the establishment of a corporate policy and goals.

Coordinated Action to Seek Regulatory Relief

Perhaps the greatest consistency is seen between industry groups in their activities to restrict or control environmental regulation. While not a positive goal-setting exercise in itself, this form of action serves to define the regulatory boundaries within which firms have to operate. Lobbying to manipulate those boundaries has traditionally been the extent of industry associations' involvement in environmental issues and remains the key focus of several groups. However, these efforts seem increasingly to be aimed at finding flexible, voluntary solutions that may be more effective environmentally and more efficient economically than "one-size-fits-all" regulation.

The Society of the Plastics Industry (SPI), in its 1995 Issue Activity Report identifies a number of environmental issues it is addressing through lobbying. It strongly supports the risk assessment bill passed by the House of Representatives in February of 1995 and is a founding member of the Alliance for Reasonable Regulation, an industry group that led the lobbying effort. SPI has worked to obtain more flexible agreements with the EPA in several areas of environmental regulation. For example, SPI negotiated an effort to allow the industry to pursue a product stewardship program in lieu of certain toxicology testing for an epoxy resin compound. This is the first time the EPA has negotiated such an effort, and a second negotiation is forthcoming for a different epoxy chemical. The SPI estimates that the plastics industry will save more than $10 million with this approach.56

The SPI is also working with the EPA on the Sustainable Industry Project (SIP) which encourages hazardous waste minimization and pollution prevention. In particular, SPI is lobbying to allow polymerization to be considered as an acceptable control technology to handle hazardous wastes. Elsewhere in its Issues Activity Report, the SPI notes that it is actively representing the plastics industry on several other environmental issues including: hazardous waste, global warming/climate change, Clean Air Act implementation, clean water/Great Lakes initiative, and chlorine.

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