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IMPLEMENTATION 69 and missions, (2) be sized to the space available on boats and ships, (3) be reliable and cost effective and (4) produce processed garbage in appropriate form for safe disposal as defined by Annex V (Smookler and Alig, 1992). Technologies tailored for use in port reception facilities also would support Annex V; existing technologies used to manage other waste streams need to be adapted for use in ports. As valuable as technology may be, it is not a panacea for environmental problems. Research suggests there is a maximum 35 percent ongoing implementation level for federal environmental regulations that include technological applications (Burby and Patterson, 1993).1 Therefore, supplementary interventions are required. Organizational and Operational Changes Organizational and operational changes are crucial to the Annex V regime, which attempts to change some very old practices. Responsible handling of vessel garbage has not been emphasized in business or government until recently, and there is much to modify. Necessary organizational and operational changes that have been identified include (1) consistent articulation of commitment to comply with Annex V by top executives of corporations involved in marine activities, (2) standardization and closer integration of vessel and port garbage handling practices so that vessel operators know what to expect, and (3) improved coordination among the various federal agencies responsible for implementation of Annex V. The first of these factors is addressed here. The integration of garbage handling practices is addressed in Chapter 5, and the issue of coordinating federal agency activities is addressed in Chapter 7. Bassow (1992) emphasizes that implementation of environmental regulations requires combining appropriate changes in technology with changes in corporate culture. He explains: In the last 20 years, many U.S. companies have adopted comprehensive environmental policies. They have introduced new procedures and technologies to reduce and eliminate harmful impacts on the environment and human health. But these are technological fixes, engineering fixes. The much more difficult challenge is to change the way people within a company think about the company's environmental policies, to change their attitudes and their mind set, in effect, to change their collective beliefs about the way the company does business. We're now talking about changing the corporate culture. 1 The 35 percent figure was derived as follows: 70 percent of the requisite technology was installed, and adequate maintenance to permit the technology to function was provided 50 percent (or half) of the time; half of 70 percent equals 35 percent total ongoing implementation (Burby and Patterson, 1993).
IMPLEMENTATION 70 TABLE 3-1 Applying the Hazard Evolution and Intervention Model to MARPOL Annex V Provisions Hazard Evolution Behavior that On-board Breakdown in Model Encourages Generation of Compliance Generating Garbage Garbage Intervention Model Modify Behavior Reduce Garbage Prevent that Encourages Generation Breakdown in Generating during Voyage Compliance Garbage Technological Behavior While not modification is mandated by encouraged Annex V throughout regulations, guidelines but waste reduction not mandated by is encouraged Annex V explicitly by regulations. Guideline 3 (Minimizing the amount of potential garbage). Organizational and No restrictions Waste reduction Operational are imposed. As is encouraged long as the but not required. garbage generated is disposed of properly, no on- board activities need be constrained.
IMPLEMENTATION 71 Hazard Evolution Discharge of Exposure to Consequence of Model Garbage into Sea Discharged Discharged Garbage Garbage Intervention Model Block Block Exposure Diminish Discharge of to Discharged Consequences of Garbage into Sea Garbage Discharged Garbage Technological Guideline 4 Pretreatment Guideline 4.3.5 (Shipboard prior to release encourages garbage apparently is recovery of handling and intended to garbage at sea, storage minimize, but retrieval is procedures) and although not not mandated. Guideline 5 block, the (Shipboard exposure to the equipment for garbage. Both processing food and garbage) nonfood garbage address means may be for meeting the discharged after need to retain comminution to garbage on particles less board for than 25 mm in disposal in port diameter. reception facilities (addressed in Guideline 6). Organizational Discharge is Restrictions vary Annex V and Operational only partially by the location emphasizes the blocked. of discharge. elimination of Overboard Annex V plastic disposal of provides discharges, which plastics is maximum are judged most prohibited but protection to harmful. IMO many other coastal sea guidelines items may be so within 25 miles encourage discharged of shore. prevention and (Regulation 3). Floating non- retrieval of lost Pretreatment plastic garbage fishing gear, even (i.e., grinding) may be though such loss is required in discharged does not violate some cases. beyond 25 miles Annex V. (Regulation 3.1.b.i). "Sinkable" garbage may be discharged beyond 12 miles (Regulation 3.1.b.ii). No discharges except ground food waste are permitted from fixed or floating structures.
IMPLEMENTATION 72 Hazard Behavior that On-board Breakdown in Evolution Model Encourages Generation of Compliance Generating Garbage Garbage Intervention Modify Behavior Reduce Prevent Model that Encourages Garbage Breakdown in Generating Generation Compliance Garbage during Voyage Educational Guideline 2 calls Placards and (Target on governments to notices must be Population/ "develop and provided to crews Content) undertake of vessels over a training, certain size (under education and U.S. law). Annex public information V can be used as a programmes tool in fostering suited for all public support for seafaring and raising communities mariners' under their environmental jurisdictions." awareness. Guideline 2.2 encourages exchange of information on compliance strategies. Regulation and Guideline 7.3 Enforcement (by recommends that governments and national private governments assist organizations in and recognize signatory nations, compliance as required by the initiatives by treaty and private and international law) professional organizations.
IMPLEMENTATION 73 Hazard Discharge of Exposure to Consequence of Evolution Model Garbage into Sea Discharged Discharged Garbage Garbage Intervention Block Discharge Block Diminish Model of Garbage into Sea Exposure to Consequences of Discharged Discharged Garbage Garbage Educational To effect the (Target changes mandated Population/ by Annex V, the Content) guidelines encourage provision of both general information and specific education about means to comply. Guidelines also encourage technical exchange concerning improvements achieved in performance and equipment used for complying with garbage restrictions. Regulation and Annex V requires Guideline 1.3 Enforcement (by signatory nations encourages the governments and to provide maximum use private "adequate" of port organizations in reception reception signatory nations, facilities. facilities rather as required by the Guideline 7.1 than continued treaty and (Enforcement) discharges at international law) suggests means to sea, even where organize national legal. authorities, record use of port reception facilities, and verify vessel operators' activities.
IMPLEMENTATION 74 Hazard Behavior that On-board Breakdown in Evolution Model Encourages Generation of Compliance Generating Garbage Garbage Intervention Modify Reduce Garbage Prevent Model Behavior that Generation Breakdown in Encourages during Voyage Compliance Generating Garbage Economic Guidelines include (Market Forces) directions for estimating the required capacity of reception facilities but many uncertainties remain. Guideline 7.2 addresses compliance incentives, such as funding for capital investment in port facilities or garbage hauling infrastructure. It is likely that changing the orientation of personnel at all levels of an organization (i.e., changing the corporate culture) becomes more important when compliance with a regulation is very challenging, as in the case of Annex V. Indeed, organizational and operational changes may be essential in order to engage personnel and other resources in the effort to comply with Annex V. Such changes can range from modifying a procurement officer's job description to specifying that suppliers use reusable packaging, to reorganizing a port's waste management operations so that services are integrated. Organizational activities also can include development of company rules for handling garbage and internal penalties for violations of the rules, up to and including dismissal (Estes, 1993). These approaches must be supported by training, to prepare the organization for
IMPLEMENTATION 75 Hazard Discharge of Exposure to Consequence of Evolution Model Garbage into Sea Discharged Discharged Garbage Garbage Intervention Block Discharge Block Exposure Diminish Model of Garbage into Sea to Discharged Consequences of Garbage Discharged Garbage Economic Annex V does not (Market Forces) establish cost criteria for reception facilities but acknowledges implicit costs (delay to ships). Garbage hauling fees add to ship operating expenses. Annex V does not require ports to charge fees or ships to land garbage Annex V compliance, and commitment of organizational resources to develop new internal garbage management plans. Again, Table 3-1 makes it clear that the drafters of Annex V expected seafarers to include organizational and operational changes in their compliance plans. No specific changes are mandated, however. By establishing performance standards, the drafters left managers and operators the flexibility to devise a compliance program that best suits their circumstances. To effect a change in corporate culture, according to Bassow, there must be communication, involvement of all managers and employees, training and support, and system alignment to the new goals. "The experience of large corporations shows that synergy between technological change and a responsive corpo-