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TABLE OF CONTENTS
Page
SECTION I: INTRODUCTION
Purpose of This Document 2
Background 2
The Role of Environmental Outreach 3
SECTION H: DEVELOPING AN ENVIRONMENTAL PLAN AND
SETTING POLLUTION PREVENTION GOALS
Environmental Planning 5
Goal Setting 6
Types of Goals 7
SECTION ffl: DEVELOPING AN ENVIRONMENTAL OUTREACH PROGRAM
1., Identifying Stakeholder 10
2. Identifying Information Needs 11
3. Selecting a Message and Appropriate Level of Detail
for Outreach Materials 11
4.; Selecting Appropriate Outreach Tools 12
Development of Targeted Strategies 12
Outreach Within the Facility 12
Outreach to the Community 14
Communication With Agency Headquarters .16
Comrnunication With Environmental Agencies (State, Regional, EPA) 18
SECTION IV: PUTTING THE PIECES TOGETHER:
IMPLEMENTING YOUR OUTREACH PROGRAM
Step 1. Identify Issues 19
Step 2. Goal Setting 19
Step 3. Identify Environmental Projects 19
Step ,4. Identify Communication and Outreach Activities 19
Step 5. Conduct Outreach Activities 19
Conclusion 20
APPENDICES: APPENDIX A-EXECUTIVE ORDER 12856
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SECTION I: INTRODUCTION
FEDERAL FACILITY
ENVIRONMENTAL
OUTREACH GUIDE
As a Federal facility environmental coor-
dinator, you may have one of the tough-
est jobs in government. You and the
facility manager are responsible for
ensuring that your facility complies with
all environmental regulations (such as
RCRA, CERCLA, CWA, and CAA).
These regulatory requirements include
the Emergency Planning and Community
Right-to-Know Act (EPCRA) which
directs private facilities to document their
storage and release of toxic chemicals.
Further, EPCRA is intended to promote
pollution prevention as the best environ-
mental protection approach. Under
Executive Order 12856, Federal
Compliance with Right-to-Know Laws
and Pollution Prevention Requirements,
Federal facilities are required to comply
with the applicable provisions of
EPCRA. These new requirements are
intended to ensure that communities sur-
rounding Federal facilities have access to
information concerning chemical use and
release by the facility. The goal is to pro-
mote open communication between
Federal facilities and their surrounding
communities concerning environmental
issues and practices. Further, Executive
Order 12856 is intended to encourage
Federal facilities to demonstrate leader-
ship in environmental protection through
pollution prevention.
The Federal government has taken on
this challenge for one very good reason:
the government is the nation's largest
consumer of raw materials, energy, water,
and manufactured products. The govern-
ment consumes these resources as part of
its production, maintenance, and opera-
tional activities. In many cases, these
activities result in the generation of
harmful liquid, solid, and gaseous wastes.
Such wastes may have an adverse impact
on human health and the environment. In
addition, the management and disposal of
these wastes, as well as the cleanup of
improperly managed wastes, are costly.
Pollution prevention can help the Federal
government reduce the environmental
impacts of its activities and reduce its
generation of wastes.
In response to this challenge, the Federal
government and faculties like yours are
developing environmental goals, includ-
ing pollution prevention goals, imple-
menting source reduction technologies,
and producing tangible results in waste
reduction and in the development of
innovative programs and policies to pro-
tect the environment. As you implement
pollution prevention programs, it is
important that you communicate your
results to all interested parties so they can
learn.of and from your efforts. These
parties may include (1) the community in
which your facility resides, (2) facility
personnel, (3) Agency Headquarters staff,
and (4) environmental agencies. After
all, it is on behalf of these people that the
Federal government has made a commit-
ment to become a leader in environmen-
tal protection.
"Environmental outreach" is the term
used for communicating environmental
progress and challenges to interested par-
ties (also known as stakeholders) within
and outside your facility. Outreach is the
method by which you and your facility
can demonstrate an openness to environ-
mental concerns. Outreach offers your
facility the opportunity to highlight full
compliance with all applicable environ-
mental regulations, trumpet the achieve-
ment of environmental goals, and demon-
strate a willingness to lead by example.
This is done through setting aggressive
pollution reduction goals, especially
those emphasizing prevention, and
implementing innovative programs
and technologies.
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PURPOSE OF THE
DOCUMENT
The purpose of this document is to provide
Federal facility environmental coordinators
(i.e., you) with practical information to
help you develop and implement effective
environmental outreach programs that
communicate facility environmental goals
and program approaches. Of particular
importance is the communication of results
and successes of facility pollution preven-
tion programs and compliance with
EPCRA reporting requirements. This doc-
ument will support you and your facility in
developing an outreach program.
Specifically, this document will address
what information you should develop, to
whom you should distribute this informa-
tion, and how this information should be
disseminated. In essence, the who, what,
and how of environmental outreach.
This document is closely linked to the EPA
Federal Facility Enforcement's (FFEO)
Federal Facility Pollution Prevention
Planning Guide, which focuses on support-
ing your efforts to develop pollution pre-
vention plans to assist facilities in meeting
the reduction goals set forth in Executive
Order 12856 and by Agency Headquarters.
While the Federal Facility Pollution
Prevention Planning Guide addresses goal
setting and public outreach in the context
of facility environmental planning, this
document stresses the importance and ben-
efits of goal setting and communication
strategies in promoting better environmen-
tal outreach, especially in pollution preven-
tion activities.
The remainder of this section presents
additional background information on envi-
ronmental planning outreach. Sectionn
provides general information about devel-
oping an environmental plan and establish-
ing pollution prevention goals. SectionIE
presents a step-by-step approach for devel-
oping an effective, targeted environmental
outreach program. Section IV helps you
"put the pieces together" and implement
your outreach program as part of your
facility's environmental protection efforts.
BACKGROUND
On August 3,1993, President Clinton
signed Executive Order 12856, entitled
Federal Compliance With Right-To-Know
Laws and Pollution Prevention
Requirements. This Executive Order
requires Federal agencies to comply with
the Emergency Planning and Community
Right-To-Know Act of 1986 (EPCRA) and
the Pollution Prevention Act of 1990
(PPA). In requiring compliance with
EPCRA, the Executive Order affirms and
strengthens the Federal government's com-
mitment to be a responsible neighbor
through better communication and open-
ness with the public concerning environ- .
mental matters. Federal facility require-
ments related to EPCRA are discussed later
in this document By mandating adherence
to the PPA, the Executive Order embraces a
leadership position for the Federal govern-
ment in environmental management
Appendix A provides a complete copy of
Executive Order 12856.
Executive Order 12856 promotes environ-
mental outreach by requiring Federal facili-
ties to fully comply with EPCRA.
Additionally, it champions environmental
leadership by establishing aggressive pollu-
tion prevention initiatives for the Federal
government Executive Order 12856 is
partly modeled after EPA's 33/50 program,
a voluntary initiative aimed at achieving a
national decrease in releases and transfers
of 17 high-priority toxic chemicals. Using
1988 baseline data, the 33/50 program set
reduction goals of 33 percent by 1992 and
50 percent by 1995. EPA encouraged facil-
ities enrolled in the initiative to set their
own goals and use pollution prevention to
meet them. Progress, both nationally and
for each participating facility, is tracked
through the Toxics Release Inventory, a
data base that is accessible by the public.
The success of the 33/50 program prompt-
ed the Federal government to try a similar
approach for Federal facilities Executive
Order 12856. It also is important to note
that pollution prevention and public
accountability are components being incor-
porated into many government agency ini-
tiatives and into other Executive Orders
(Le., 12873,12902,12843,12844,12845,
and 12898). Exhibit 1 provides additional
information regarding the requirements of
these Executive Orders.
The primary objectives of Executive Order
12856 are to (1) establish goals related to a
reduction in the use and release of toxic
chemicals, reductions in all environmental
impacts, and the acquisition and procure-
ment of "environmentally safe" products
and materials, (2) develop pollution preven-
tion plans to reduce toxic releases by 50
percent and achieve facility-specific envi-
ronmental goals, (3) collect and report
(through such vehicles as the Toxic Release
InventoryTRI) data on the quantity and
toxicity of the hazardous materials/waste
stored, used, treated, released, and disposed
of at the facility, and (4) ensure public
access to information on releases, transfers,
and pollution prevention activities.
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Section I: Introduction
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THE ROLE OF
ENVIRONMENTAL OUTREACH
Environmental outreach is part of a new
approach to environmental protection.
The old approach emphasized cleaning
up past mistakes and concentrating con-
trol actions on single-media problems.
The new philosophy is more proactive.
It recognizes that a multimedia approach
is more sound and that an emphasis on
pollution prevention will have long-last-
ing, positive effects on the environment.
Goal setting and communication of pol-
lution prevention successes are integral ^'-C^;^dW|&
to this new environmental philosophy. "'" .-i_-_i^^
Exhibit 2 summarizes the Federal facility
requirements under Executive Order
12856, the PPA, and EPCRA. Each
Federal facility should establish a strong
outreach program to highlight pollution
prevention, compliance, and environ-
mental protection, including the follow-
ing activities:
Develop an environmental plan and
set pollution prevention and other
environmental goals
Develop an environmental outreach
program that includes identifying
stakeholders, defining information ^ ,,._ ,, ,.v,,, iv-_,.,,. ^^, ,.., ^ ^ _
needs, and selecting a message and '; *;v^OU,I3E^r'--\v^ ^ '>'; "V^; V;'"x' 'f\:** '-V* '>
level of detail for appropriate out-
reach materials
Initiate the plan to achieve environ-
mental goals through pollution pre-
vention and other environmental pro-
tection activities
Distribute outreach materials in the
facility, the community, Agency
Headquarters, and Environmental
agencies at all government levels
Continuously track results of environ-
mental programs, especially pollution
prevention projects, to document suc-
cesses and provide information for
continuing outreach efforts.
Ultimately, these activities will strength-
en your environmental protection pro-
grams and provide continuous informa-
tion on progress to all interested parties.
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Exhibit 2-Outreach and Pollution Prevention Requirement for Federal Facilities
Executive Order 12856
Comply with EPCRA emergency planning and response requirements.
Report releases and transfers of toxic chemicals to TRI.
Make TRI reports available to communities surrounding your facility.
Develop facility pollution prevention plan including, where appropriate/applicable, a plan to reduce
releases and transport of toxic chemicals by 50%
Ensure plan supports agency-wide strategies and goals.
Comply with the provisions set forth in section 301 through 312 of EPCRA
Pollution Prevention Act
Establishes pollution prevention as the Nation's
preferred approach to environmental protection
and waste management
Requires that the Federal government identify
opportunities to use Federal procurement to
encourage pollution prevention.
Emergency Planning and Community
Right-To-KnowAct
Sections 302 and 303 require planning for
community response to rare but potentially
catastrophic events such as the release of
hazardous chemicals during a facility accident.
Section 304 provides for public notification of
emergency releases of chemicals potentially
harmful to the community.
Sections 311,312, and 313 enhance a
community's awareness of chemical hazards by
requiring facilities to document and report to
EPA information on the amounts and types of
chemicals stored and used at a facility.
Federal Facility
Section I: Introduction
-------
II. DEVELOPING AN ENVIRONMENTAL
PLAN AND SETTING POLLUTION
PREVENTION GOALS
This section discusses how to establish an environmental plan and set
pollution prevention and other environmental goals (e.g., remediation,
compliance, land management and preservation, and environmental jus-
tice). The discussion of environmental planning identifies specific facili-
ty planning requirements contained in environmental regulations and
Executive Orders and outlines the steps involved in developing an envi-
ronmental plan that will contain activities to be publicized through your
facility's environmental outreach program. The discussion on goal set-
ting presents detailed information on establishing effective and meaning-
ful facility pollution prevention goals that can then be communicated
through your environmental outreach program.
FEDERAL FACILITY
ENVIRONMENTAL
OUTREACH GUIDE
ENVIRONMENTAL PLANNING
As a Federal facility environmental coor-
dinator, you are responsible for all facility
environmental program activities. Certain
environmental regulations require facili-
ties to conduct planning activities. For
example, EPCRA Sections 302 and 303
require planning for emergency response
to hazardous chemical releases. In addi-
tion, Executive Order 12856 requires all
Federal agencies to develop pollution pre-
vention plans to reduce releases and trans-
fers of toxic or hazardous chemicals.
Executive Order 12856 defines the
importance of pollution prevention. As
an environmental protection approach,
pollution prevention should be integrated
and used to improve almost every area of
a facility's environmental program. As
the environmental coordinator, therefore,
you should devote particular attention to
pollution prevention. Exhibit 3 identifies
seven steps for developing an effective
facility pollution prevention plan. The
first of these steps is to develop pollution
prevention goals, which will be the ini-
tial subject of your environmental out-
reach program.
To assist in developing pollution preven-
tion plans and meeting the requirements
of Executive Order 12856 and other laws
concerning pollution prevention, EPA's
Federal Facilities Enforcement Office
developed the Federal Facility Pollution
Prevention Planning Guide. The guide
provides detailed information concerning
the development and implementation of
your pollution prevention program. This
document is a companion volume to that
guide and should be used with it to pre-
pare and implement pollution prevention
plans and communicate the results of
these efforts.
An effective pollution prevention plan and
its resulting activities are powerful tools,
and your outreach program can help
advertise your successes. The elements
of your pollution prevention program
should be integrated with your facility
outreach activities. You can then use your
pollution prevention plan and outreach
activities to publicize your pollution pre-
vention goals and all measurable achieve-
ments to stakeholders. Demonstrating
successes specified in your pollution pre-
vention plan will illustrate your facility's
strong commitment to improving environ-
mental performance.
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GOAL SETTING
Goals are a critical requirement of
Executive Order 12856. The Executive
Order requires agencies to adopt a goal
of reducing releases of toxic chemicals
by 50 percent by the end of 1999, as well
as acquisition and procurement goals to
eliminate or reduce the purchase of prod-
ucts with extremely hazardous sub-
stances or toxic chemicals. These goals
can also be highlighted in your facility's
environmental outreach program.
To meet these goals, as well as others
established by you or your Agency
Pollution Prevention Strategy, you will
need to think carefully about your envi-
ronmental program and the activities you
will need to implement. For example,
you will need to:
Determine which goals apply to your
facility
Identify which projects will assist
you in meeting these goals
Identify your short-, mid-, and long-
term goals, given a specific budget
and timetable, and involve concerned
stakeholders in the goal-setting
process
Identify measurement standards
Examine and refine your data collec-
tion activities to ensure that you have
an accurate baseline from which to
measure reductions and document
future reductions
Receive endorsement from the facili-
ty manager on all activities related to
the achievement of goals
Publicize goals to all concerned
stakeholders through environmental
outreach activities.
Goal setting and public outreach are not
simply exercises conducted by Federal
facilities in compliance with environmen-
tal requirements. They are useful activi-
ties to support and improve your environ-
mental program. In the private sector,
many companies have set aggressive pol-
lution reduction goals and actively strive
to publicize their achievements through
outreach. Goal setting and outreach are
becoming standard operating procedure
for today's businesses. AT&T, for exam-
ple, has set significant goals for reducing
air emissions and ozone-depleting chemi-
cals and 3M has pledged a 90-percent
reduction of toxic chemicals by the year
2000. Many other companies, spurred in
part by the voluntary 33/50 program and
mandatory reporting under the TRI,
have used goal setting in a very positive
way, as demonstrated in Exhibit 4.
Federal agencies and facilities
have established similar goals.
preparation of TRI environmental reports
has served as a yardstick for helping
facilities track their own progress toward
meeting pollution prevention and other
environmental goals. In addition, TRI
reporting can help your facility identify
priority areas for setting additional envi-
ronmental goals, particularly pollution
prevention goals. Reporting under TRI
also provides the general public with
easy to understand information on the
environmental performance of companies
and individual facilities in their area.
Facility-specific goals are critical to
communicating the direction of your
environmental program to facility and
agency staff, as well as to the public.
Properly developed goals should be easi-
ly understood by your stakeholders and
integrated into outreach materials.
Setting goals also can help measure
progress and show good faith and a com-
mitment to achieving tangible results. In
addition, setting goals and achieving
them provides a sense of accomplish-
ment for the facility and staff. This is
vital to the continued success of any
environmental program.
Step?: Conduct a Management Review
Step 6:
Step 5:
Develop Criteria and Rank
Activities/Opportunities
Conduct P2 Opportunity
Assessment
Develop a Baseline
Establish a Pollution Prevention
Obtain Management Commitment
Develop Pollution Prevention
Goals
If your facility meets reporting
thresholds specified under
EPCRA and TRI, your
goal setting and TRI
reporting efforts can
be interrelated. The Step4:
Step 3:
Step 2:
Stepl:
Exhibit 3-Steps in
Pollution Prevention
Plan Development
Section If: Developing an Environmental Plan and Setting Pollution Prevention Goals
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TYPES OF GOALS
There are two general types of goals:
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short period of time. Long-term goals
define the overall direction of the facility's ,";\';
approach to addressing environmental
issues. Achieving short-term goals rein-
forces the facility's commitment to reduc-
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achievable. Remember that goal setting is
not a one-time event Goals must be
examined, modified, and documented reg- " ''*ง? ^^t'!^^',- V^ '^^?*ปฎ "tJfUJCTO^ftl^^--. ^ ,v ;198^*|S|^.A, *ฃ*ฃ$$:, tt~~
ularly as achievements are made and situa- ^.V-'^nS''" "" ฐ "* " >-~------~-----^
tions change. Use achieved goals to identi-
fy improvements and new initiatives for
your environmental program. Each goal
that you set and achieve is a success story
that can improve your relations within the
facility, your Agency Headquarters, and
the outside community.
Well-conceived goals are the stepping
stones to reducing or eliminating pollution
and establishing a successful environmen-
tal outreach campaign. However, goals
that are poorly conceived, meaningless,
unrealistic, or too conservative will not win
the confidence of stakeholders and do not
demonstrate a real commitment to pollu-
tion prevention and environmental protec-
tion. To develop meaningful goals, you
should consider several questions:
Does the facility have an accurate base-
line by which to measure success in
meeting this goal?
How accurately can results be mea-
sured?
Is the goal achievable within the given
timetable?
Are technology improvements/ changes
or other process modifications neces-
sary before the goal can be achieved?
Could any factors outside the facility's
control delay the attainment of these
goals?
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III. DEVELOPING AN ENVIRONMENTAL
OUTREACH PROGRAM
FEDERAL FACILITY
ENVIRONMENTAL
OUTREACH GUIDE
Environmental outreach is "the right thing
to do" for many reasons. A successful
environmental outreach program will
improve your relationship with your sur-
rounding local community. Communicat-
ing effectively will help you to publicize
reductions in releases and the achievement
of environmental goals, including those
involving pollution prevention. It will also
help you to establish a cooperative and
trusting relationship between the facility
and the community and may lead to the
development of new partners in pollution
prevention opportunities. An effective
outreach program can also support you in
reporting activities required under Federal,
state, and local regulations. For example,
the motivation for EPCRA reporting
requirements was that the public has the
right to know about potential releases and
transfers that can affect human health or
the environment By establishing an out-
reach program, your facility will be well
prepared to conduct outreach as needed.
Further, your community will already rec-
ognize and trust your facility because of
your ongoing outreach activities that
describe environmental issues and suc-
cesses at your facility. This can be critical
if an accidental release occurs.
Environmental outreach is an integral part
of a facility's communication network.
The facility uses this network to commu-
nicate with stakeholders on a variety of
program issues (e.g., employment oppor-
tunities, special events, security issues,
and environmental compliance require-
ments). The objectives of the environ-
mental outreach component of this net-
work are to:
Communicate the results and
approaches of environmental initia-
tives to interested stakeholders
Actively engage stakeholders in par-
ticipating in facility development and
implementation of environmental
goals and projects
Receive input from other stakeholders
(e.g., other Federal facilities, EPA,
and local and national environmental
groups) on new environmental man-
agement/reduction techniques and
opportunities.
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Exhibit 5 illustrates the environmental
outreach components of a facility's com-
munication network. Remember that
each outreach activity should be directed
at a target audience for a specific issue:
1. Facility. Worker Safety, Pollution
Prevention Projects, Compliance
Requirements
2. Community. Openness/Trust,
Progress in Reducing Environmental
Problems, Environmental Justice
Goals
3. Agency Headquarters. Compliance,
Technology Transfer, Pollution
Prevention Successes, Funding Needs
4. Environmental Agencies.
Compliance and Progress in Meeting
Reduction Goals
8
Section II: Developing an Environmental Plan and Setting Pollution Prevention Goals
-------
Exhibit 5 - Outreach Components
DD
ffl
Environmental Reporting Requirements,
Guidance, Technical Assistance
Environmental Agencies
(Federal, State, and Regional)
DODD
nann
nnn f
DDDD
DDDD
1 nnn
Environmental Reports, Progress Reports,
Requests for Assistance
Agency
Headquarters
*When communicating envi-
ronmental information to
stakeholders, it may be bene-
ficial to coordinate with both
the public information spe-
cialist and legal counsel at
the facility. If these special-
ists do not reside at your
facility, consult with Agency
Headquarters to receive the
needed assistance.
-------
Your mission is to ensure that all compo-
nents of your communication network
receive the appropriate information to
gain an understanding of your environ-
mental programs.
Each issue area (e.g., compliance or pol-
lution prevention) will have an accompa-
nying goal(s). Part of your purpose in
these outreach activities is to clearly com-
municate the facility's environmental
goals. Describe the approach for imple-
menting these goals and the impact of
these goals on stakeholders. Remember
that your goals should be aligned with the
information needs of the audience/stake-
holder. Each stakeholder will have an
interest in, contribution to, and overall
bearing upon different aspects of the envi-
ronmental program. Therefore, your
facility's outreach program should
encourage and support the needs of your
stakeholders.
You might use a systematic approach to
develop an environmental outreach pro-
gram. There are basically four steps to
developing and implementing an effective
environmental outreach program. These
steps are cumulative and build upon one
another. Completing each of the steps in
turn will make completing each succeed-
ing step easier and more valuable. The
four steps for developing an environmen-
tal outreach program are:
1. Identifying stakeholders
2. Identifying information needs
3. Selecting a message and appropriate
level of detail for outreach materials
4. Selecting appropriate outreach tools.
It is important to recognize that develop-
ing and implementing an environmental
outreach program is a continuous effort.
You will need to regularly modify and
update your outreach messages and tools
based on factors at your facility and in the
surrounding community. The factors may
include changes in facility operating prac-
tices, addition of new staff, successful
implementation of pollution prevention
projects, identification of new facility
goals, addition of new environmental
10
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nrten-tai:rtoe^' ::LvxiปV i i^SiisMrts feM ri)f^s:^!fci?tomiM^w4sttete= -.' >:ii
throughout the country. In most cases,
there is a national headquarters and, in
some cases, regional or other oversight
offices. The headquarters and other
related offices act as focal points for
producing funding, awards, and techni-
cal support for facility environmental
programs; collecting information about
environmental activities taking place
throughout the agency; and reporting
environmental and other data to EPA
and other regulatory agencies.
Environmental Agencies (State,
Regional, EPA Headquarters). Your
facility's environmental communica-
tions outreach program should target
environmental agencies. Each regulato-
ry organization has offices and staff
dedicated to environmental issues.
These organizations are excellent
sources of technical support and guid-
ance on environmental programs.
Many facilities have established "part-
nerships" with environmental regulators
to meet and exceed their environmental
goals. It is important to know that regu-
latory agencies are often willing to sup-
port and work with cooperative Federal
facilities in solving difficult environ-
mental issues. These agencies also
highlight program successes and sup-
port for outreach programs
2. Identifying Information Needs
After you have identified the specific indi-
viduals and/or organizations who will be
part of your environmental outreach
efforts, you will need to determine the par-
ticular type(s) of information they need or
want The information needs or require-
ments of stakeholders are driven by statu-
tory requirements. Exhibit 6 presents an
Information Outreach Matrix that can help
you identify the types of information that
are often needed by stakeholders. This
exhibit also describes this outreach sup-
ports your program.
3. Selecting a Message and
Appropriate Level of Detail
for Outreach Materials
Once you have identified the stakeholders
and therr individual information needs,
you will need to determine what message
11
-------
to convey and the level of detail required
for each stakeholder group. When select-
ing your message, consider what each
stakeholder group wants to know about
your facility. Your message may address
the following questions:
What are the facility's environmental
and pollution prevention goals?
What are the facility's past and cur-
rent pollution prevention initiatives?
What has the facility accomplished in
terms of waste reduction and environ-
mental protection?
How can the community participate in
and benefit from the facility's pollu-
tion prevention activities?
It is also important to focus on the type
and amount of information that is needed
by each stakeholder group. Burdening
stakeholders with excessive data confuses
your message and forces them to sift
through information for desired content
Conversely, oversimplifying information
may not provide the audience with suffi-
cient detail to understand requirements or
activities specified in the materials.
Regulatory requirements and public
demand will often dictate information to
be made available to the public. Read the
requirements and available guidance care-
fully and include all of the appropriate
information, as well as other relevant
information.
4 Selecting Appropriate
Outreach Tools
A variety of tools can be used hi your
environmental outreach program. These
include public meetings, issue
forums/workshops, conferences, news
releases, media events, educational mate-
rials (e.g., fact sheets and brochures),
training, and hotlines. Your efforts will
reflect the resources and information
available at the facility level. Exhibit 7 is
a Communication Tools Matrix that can
assist in evaluating the potential strengths
and weaknesses of the numerous avail-
able outreach tools.
12
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DEVELOPMENT OF
TARGETED STRATEGIES
It is important for outreach efforts to be
focused. A sound approach is to tailor
your outreach efforts for each of your
stakeholder groups (e.g., facility staff,
community, Agency Headquarters, and
environmental agencies). Organizing
your outreach by stakeholder allows you
to send a specific message and informa-
tion to each audience. This section pro-
vides an overview of appropriate outreach
tools that can be used to improve commu-
nication with each facility stakeholder
group. Some outreach tools are more
appropriate for certain stakeholders.
Training is a good tool for increasing pol-
lution prevention awareness at a facility,
for example, but is inappropriate for
transmitting the results of environmental
projects to area neighborhoods.
OUTREACH WITHIN THE
FACILITY
Outreach within your facility should tar-
get the needs of your facility, including all
facility staff. The outreach program
should try to:
Increase overall awareness of environ-
mental issues and new facility pollu-
tion prevention activities
Increase success in the achievement
of environmental goals
Secure additional support for future
pollution prevention projects
Increase safety in the management of
toxic substances.
As you develop this part of your overall
environmental outreach program, identify
the facility staff members who will be the
primary target of your efforts, their roles
and responsibilities, and the environmen-
tal project information they want or need
to know. For example, you will want to
put together a concise and informative
presentation to your facility manager on
Your
specific objective in this case will be to
Section III: Developing an Environmental Outreach Program
-------
Exhibit 7 - Communication Tools
Outreach Tool
Strengths
Cautions
Public Meetings Good for conducting community relations.
Demonstrates openness and good neighbor policy.
Ability to address a widei variety of environmental concerns.
Forum for community questions, concerns and feedback.
1 Not well suited for providing in-depth
1 Takes a long time to organize.
Attendance can vary. Don't be
discouraged by a poor showing.
Attendees will vary greatly in
their knowledge of subject matter.
Material provided must be developed
for all to understand.
Issue Forums/ An excellent opportunity to share information and programs
Workshops/ with environmental coordinators at other Federal facilities.
Conferences Provides an opportunity to learn from others.
1 Takes a long time to organize.
Not a good method for quick
response to specific problems.
Good for providing a specific.
ic target audience. For,
release information^
Can be used
pollution pre
environm
Can be
Need to update and/or re-issue
on a regular basis.
Can be expensive to develop,
, and distribute.
News Releases
quoted or misinterpreted
future response.
Educational
Materials (e.g.,
fact sheets,
brochures)
e and/or re-issue
asis.
sive to produce
e.
Allows
on
Allows imme
Provides maximl
Provides in-
Iitermation and can only affect a
group Of individuals.
Training
Good for promoting polluti6
sound environmental management" practicesTat the facility.
Time consuming.
Limited number of individuals can
be contacted in this manner.
Centralized Provides the ability to answer specific questions and
Hotlines concerns from all stakeholders.
Provides information on technical topics. Can be used
to publicize your successes.
Resource intensive (time and money
can be significant).
Quality assurance may be of concern.
Electronic/ E-mail .is a simple and effective method of communicating
Online with stakeholders.
Communication The Internet provides a powerful tool for identifying and
collecting information onioutreach activities being conducted
at other Federal facilities and in the private sector.
Allows the facility the ability to develop their own Home
Page f(om which they can distribute information on many
topics to a wide audience'.
Requires some expertise on
information systems.
May require the purchase of specific
hardware and software.
Requires periodic updates
and maintenance.
-------
provide the manager with sufficient
information to make decisions regarding
your program and highlight the successes
you have had in recent projects. You
should develop and submit to the facility
management an information status report
on pollution prevention activities and
their impact on waste generation and
environmental releases. You can use
pamphlets and briefing materials as tools
for visually presenting information to
complement a presentation.
Another area deserving special mention is
the need to inform all facility personnel
on the potential dangers from toxic chem-
icals. This is an important aspect of both
EPCRA and Executive Order 12856, and
every facility must develop a program to
address this outreach issue. Most facili-
ties should hold regular training classes to
educate facility personnel. Exhibit 8 pro-
vides an overview of some key stakehold-
ers within your facility, their environmen-
tal responsibilities, and potential outreach
goals and strategics.
OUTREACH TO THE
COMMUNITY
It is critical that the facility and communi-
ty define their relationship based on trust
and open communication concerning
environmental issues. Community out-
reach is an important tool for communi-
cating environmental goals, programs,
and successes to your surrounding com-
munity. Specific goals for this outreach
activity include:
Improving community relations
Establishing environmental creden-
tials
Fostering cooperation with local busi-
nesses, environmental groups, and
associations
Demonstrating a concern for environ-
mental justice issues
Complying with TRI requirements
* Soliciting input from the community
14
Promoting openness
Demonstrating tangible results to the
public
Making facility operations publicly
accountable under right-to-know require-
ments demonstrates the government's
commitment to being a good neighbor.
Right-to-know laws also help to disman-
tle the shroud of secrecy sometimes asso-
ciated with Federal government opera-
tions and to alleviate tensions between
Federal facilities and surrounding com-
munities. Community right-to-know laws
can be crucial in helping facilities
improve environmental quality because
they allow facilities to be accountable for
their waste management activities. Under
right-to-know provisions, the community
is entitled to access facility data on the
types and amounts of chemicals that are
used, generated, spilled, or shipped offsite
from the facility.
The right-to-know provisions of EPCRA
and Executive Order 12856 encourage the
dissemination of information between a
facility and the public. Facility staff
should view community outreach as a
beneficial foundation of good public rela-
tions as well as a means to reassure the
public that your facility is protecting the
environment. Right-to-know is an activi-
ty that recognizes that the Federal govern-
ment serves the community. With time,
the public will not merely expect informa-
tion from industry or the government on
environmental progress, but will begin to
welcome it Federal facilities should
jump on the bandwagon early.
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Exhibit 8 - Facility Outreach Strategies
Individual
Stakeholder
Environmental
Responsibilities
Outreach Goal
Outreach Strategy
Facility Manager
Determines facility's
environmental budget.
Grants approval for all :
environmental projects.
Acts as spokesperson for
facility.
Provide sufficient information
to make decisions regarding
environmental program.
Highlight successes in recent
projects.
Use briefing materials to support
individualized presentations on
environmental programs.
Use status reports during regular-
ly scheduled staff meetings to
keep informed.
Provide with mass media
materials like pamphlets for use
by manager.
Shop Managers
Ensures proper rnj
ment of hazard^fr^te^s^\5^|^^r^^y^g^^J--5?
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Use training and educational
^, materials as the primary means to
ifjlement these efforts with an
*A mental hotline if resources
anagers with periodic
resher materials to
ployees (i.e., train-
Logistics and
Transportation
Offices
Har^j^^Fdo,ds->VV^ :J;^ l^ll
mat^lsf^^s^::f~Cp:ry;4|^p
Follow^fivtfe^gntalr Ssl^'Si;
| and educational
as the primary means to
Facility
Personnel
and educational
as the primary means to
implement these efforts with, an
^hvironmental hotline if resources
permit.
Provide periodic updates/refresher
materials and account for new
employees.
pprt-pt-o-v; -\ T ;- ; ;;;;:
15
-------
tools in that language to ensure effective
communication.
Knowing the demographics of the com-
munity will also enable you to identify
any particular environmental justice/equi-
ty concerns. A review of environmental
justice issues will determine whether cer-
tain groups (for instance, lower income
and minority communities) have been dis-
proportionaUy affected by environmental
pollution. If this analysis reveals an envi-
ronmental justice issue, appropriate steps
(including environmental outreach) can
be taken to address the issue. Your out-
reach program should inform the affected
population that the Federal government
recognizes potential problems and is
actively taking steps to address the issue.
It should include a public meeting during
which residents can voice their concerns
and have specific questions answered.
Just as you did for your outreach efforts at
the facility level, you will need to develop
& specific outreach program for the sur-.
rounding community. The community
environmental outreach program can be
complicated by the diverse set of individ-
ual stakeholders and their distinct and
sometimes conflicting concerns. Once
you have identified the individual stake-
holders and their concerns, you will need
to develop an environmental outreach tool
and a strategy for reaching that goal.
Exhibit 9 provides a community outreach
strategy matrix to help in this effort.
Keep in mind that facility and community
concerns differ greatly. You will need to
"take the pulse" of the community before
developing your own strategy.
COMMUNICATION WITH
AGENCY HEADQUARTERS
Unlike the outreach plan that you devel-
op for your community (which must be
built upon the needs of a diverse set of
individual stakeholders), the outreach
plan developed for your Agency
Headquarters should be designed around
the specific information needs of its orga-
nization. The Headquarters' information
our Community , , /
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needs stem from Federal and State legal
and regulatory requirements. These are
often modified and passed on to individ-
ual facih'ties in the form of Agency
Directives or other guidance. Therefore,
the most important questions to ask are
the following:
What types of information does my
Agency require?
Why do they need this information?
Is there a required format for submit-
ting this information?
To what office or department do I
need to send the information?
What additional information should
I submit?
The environmental reporting require-
ments vary for each agency. However,
most agencies will require environmental
compliance reports (including Notice of
Violation information), pollution preven-
tion progress reports, budget requests,
and environmental project plans for the
coming year. Data that demonstrate suc-
cess in reaching environmental goals and
that can be combined with data from
other facilities in your agency are impor-
tant to Headquarters. By examining the
data, Headquarters personnel will be
able to determine whether the informa-
tion is both complete and understand-
able. If questions arise concerning the
data, then you should initiate discussions
to clarify the issues.
After you have made a thorough list of
the information needs of your Agency,
you will need to identify how this infor-
mation should be presented. In certain
cases, Headquarters will have already
determined the format. In these
instances, try to closely follow the
instructions/forms provided. Although
completing this type of information
request can be tedious, if it is done accu-
rately, completely, and timely, you will
create a reputation as a facility where
environmental protection is given a high
priority. This reputation may help you
obtain the funding needed for future
environmental projects or result in your
facility being selected by the Agency to
16
Section III: Developing an Environmental Outreach Program
-------
Exhibits - Community Outreach Strategies
individual
Stakeholder
Environmental Concerns
Outreach Goal
Outreach Strategy
Elected The overall health and
Officials safety of all residents.
Provide sufficient (yet not
overly technical) information
on facility compliance, goals,
and future plans.
1 Provide regular briefings on general environmen-
tal compliance and improvements. Use materials
for small group meetings. Also, use high-profile
media events, such as a facility walk-through.
Local
Government
Compliance and results in
pollution prevention
goals.
Verify compliance and goal
achievement.
1 Use issue forums and briefings to communicate
needed information. Materials should present
factual information in a direct and clear manner.
Community
Associations
Pollution releases to their Demonstrate openness and
neighborhood. : willingness to address their
Use public meetings, hotlines, and educational
material to communicate your outreach goals.
Environmental
Groups
Compliance with environ-
mental laws,
prevention, and
range plans.
d public meetings on specific problems
" ins for addressing these problems.
juts with meaningful facts and
Local
Businesses
General Public
Safety of pei
business g
compliance!
mental I;
nd conferences to exchange
s.
'meetings to discuss progress.
;^4ฎSl^^^^ocal businesses-
^^.C'^^^S^.^'^-*'^:^^'^
rating procedure for
environmental issues.
possible. Use news
news and achievement
Theei
children
protection. X1
x
','bring a variety of educational
for their age.
ifith fun and educational.
Health and safety ofy;; ^y\j
residents. X^i^:"
Environmental pollution'. -^
^ ,.v^.,,^^^. flyers and other outreach material
;.^%sl|&r|ries, town halls, and other government
A Willing Partner
As a means to cooperate with environmental agencies and
demonstrate environmental leadership, Westover AFB in
Massachusetts volunteered to host a pollution prevention
opportunity assessment course sponsored by EPA Region I
The course was attended by environmental officials from
numerous facilities located in EPA Region I.
Assistance From Headquarters
The Department of the Interior's Office of Environmental Policy
and Compliance (PEP) has developed a series of 30 pollution
prevention fact sheets designed to promote source reduction
and recycling in the Department's bureaus and facilities operat-
ing on Federal lands. Each fact sheet identifies pollution pre-
vention and waste minimization techniques for a specific opera-
tion or activity, such as metal working, landscaping,
laboratories, and vehicle maintenance.
-------
pilot new environmental programs and
technologies.
If the Agency does not prescribe a partic-
ular format for the information, you have
an important decision to make. What is
the best method or tool to use to present
the information? An important factor in
this decision is knowing why the Agency
wants this information and what Agency
personnel are going to do with it For
example, they may want to demonstrate
compliance to high-level Agency officials
or the achievement of environmental
goals. They may want to compile it with
information from other facilities into a
Report to Congress. The information
may be used to satisfy an EPA require-
ment or for public relations material.
Knowing the types of information needed
by your Agency is the most crucial piece
of information in developing an environ-
mental outreach program for your
Agency Headquarters.
Keep in mind that communication is a
two-way street. There will be times when
you will need feedback from the agency
or technical assistance. Thus, it is impor-
tant to establish a personal rapport with
the appropriate Headquarters staff mem-
bers. Remember that there may be more
than one person you will need to commu-
nicate with in this regard. Try to under-
stand their needs and develop solid per-
sonal relationships.
COMMUNICATION WITH
ENVIRONMENTAL AGENCIES
(STATE, REGIONAL, EPA)
Outreach efforts to the environmental reg-
ulatory agencies can have significant
effects on your environmental program.
Developing an outreach plan for these
organizations should be a high priority for
you and your staff. As with your
Headquarters organization, your outreach
efforts should be developed by closely
examining the information needs of the
target organization. In addition, coopera-
tion and communication with these regu-
latory agencies will help you develop a
nducied csoperatJvehF by gP&arid
i towards agency goafs.
$.*ฃ fiif~
-------
IV. PUTTING THE PIECES TOGETHER:
IMPLEMENTING YOUR OUTREACH
PROGRAM
FEDERAL FACILITY
ENVIRONMENTAL
OUTREACH GUIDE
Your environmental outreach activities
are a tool for collecting and distributing
information concerning your environmen-
tal program. As such, your program
should define an approach that meets the
specific communication needs of your
facility. You should consider the environ-
mental requirements and goals of your
program in developing your outreach pro-
gram. That is, your program should focus
on cpmmunicating your facility's environ-
mental goals, describing pollution preven-
tion activities, and collecting needed
information to support your programs.
An environmental outreach program is
only valuable if it includes a schedule of
and budget resources for specific action
items for outreach activities. In addition,
your program should also identify specif-
ic communication activities.
To develop and implement your outreach
program, EPA recommends that facilities
develop formal communication strategies
as an integral part of their environmental
programs. This means that faculties
should identify and document outreach
activities that will support on-going envi-
ronmental programs. To do this, EPA
suggests that you undertake the following
five steps:
Step 1. Identify Issues
Federal facilities should develop an envi-
ronmental baseline and a pollution preven-
tion strategy as required under Executive
Order 12856. This baseline should quanti-
fy and describe any environmental releas-
es of toxic materials associated with facili-
ty operations. EPA encourages facilities
to include all environmental impacts in
this baselining effort.
Step 2. Goal Setting
Using your facility's environmental plan,
identify specific environmental goals that
the facility will pursue through its envi-
ronmental program. These goals can
include source reduction, recycling, com-
pliance, and remediation. These goals
should be consistent with Federal envi-
ronmental regulations, Executive Order
requirements, state requirements, and
Agency goals.
Step 3. Identify Environmental
Projects
The goals that you set for your facility
should reflect the direction that you, facil-
ity staff, Agency Headquarters, and the
community want to take with the environ-
mental program over the short- and long-
term. As part of the planning process,
you should use your goals to identify and
implement specific support activities that
will help you accomplish these goals.
Step 4. Identify Communication and
Outreach Activities
A subset of the environmental projects
that you identify should be specific out-
reach and communication activities that
will support or transfer the results of your
environmental programs. Your environ-
mental outreach activities should consider
the following factors:
Target audience
Outreach tool to be used
Staff who will perform or support the
outreach activity
Budgeting needs for conducting out-
reach activities
Schedule for performing the outreach
, activities.
Your outreach program ultimately should
be an integral part of your facility envi-
ronmental plan or action items.
Step 5. Conduct Outreach Activities
Your ultimate goal in this process is to
conduct outreach activities that effectively
communicate your message to all stake-
19
-------
holder groups. As such, the final step in
this process is to ensure that outreach
activities are accomplished. You may find
that these activities may require modifica-
tions or changes over time. Be flexible
and use outreach and communication
activities as a support activity for other
environmental programs and projects.
As the facility coordinator, you can docu-
ment needed outreach activities in a for-
mal strategy or as an addition to your
annual plan. Either way, you should have
a clearly defined program that specifies
action items, resources required, and pro-
posed schedules. Now you face the real
challenge of implementing your outreach
program by establishing newsletters,
developing press releases, participating in
cooperative efforts, and spreading the
wotd about the environment, your pro-
gram, and its accomplishments.
CONCLUSION
Environmental outreachsetting pollu-
tion prevention goals and communicating
pollution prevention achievementshas
become a critical element in the operation
of both private and public sector facilities.
Conducting environmental outreach activ-
ities can help your facility meet the
requirements set forth in Executive Order
12856, EPCRA, and other regulations.
The true benefit of environmental out-
reach, however, is in creating a flow of
information to all stakeholders so that
they can understand and support your
facility's environmental goals and pro-
grams. Developing and implementing an
effective environmental outreach program
will help enhance your facility's relation-
ships with its staff, Agency Headquarters,
environmental agencies, and surrounding
community by informing them of your
plans and their respective roles. In addi-
tion, a well-designed environmental out-
reach program can showcase your facility
as a environmental leader to each of these
stakeholder groups. Environmental out-
reach is simply "the right thing to do."
20
Section IV: Putting the Pieces Together: Implementing Your Outreach Program
-------
APPENDICES
Appendix A Executive Order 12856 (Sections that are quoted in
main body of text are highlighted).
FEDERAL FACILITY
ENVIRONMENTAL
OUTREACH GUIDE
21
-------
-------
THE EXECUTIVE ORDER
Federal Register
Vol. 58, No. 150
Friday, August 6,1993
41981
Presidential Documents
Title 3
The President
Executive Order 12856 of August 3, 1993
Federal Compliance With Right-to-Know Laws and Pollution
Prevention Requirements
WHEREAS, the Emergency Planning and Community Right-to-Know Act
of 1986 (42 U.S.C. 11001-11050) (EPCRA) established programs to provide the
public with; important information on the hazardous and toxic chemicals in their
communities, and established emergency planning and notification requirements
to protect the public in the event of a release of extremely hazardous substances;
WHEREAS, the Federal Government should be a good neighbor to local communi-
ties by becoming a leader in providing information to the public concerning toxic
and hazardous chemicals and extremely hazardous substances at Federal facilities,
and in planning for and preventing harm to the public through the planned or
unplanned releases of chemicals;
WHEREAS, the Pollution Prevention Act of 1990 (42 U.S.C. 13101-13109) (PPA)
established that it is the national policy of the United States that whenever feasible,
pollution should be prevented or reduced at the source, that pollution that cannot
be prevented should be recycled in an environmentally safe manner; that pollution
that cannot be prevented or recycled should be treated in an environmentally safe
manner; and that disposal or other release into the environment should be em-
ployed only as a last resort and should be conducted in an environmentally safe
manner;
WHEREAS, the PPA required the Administrator of the Environmental Protection
Agency (EPA) to promote source reduction practices in other agencies;
WHEREAS, the Federal Government should become a leader in the field of pollu-
tion prevention through the management of its facilities, its acquisition practices,
and in supporting the development of innovative pollution prevention programs
and technologies;
WHEREAS, the environmental, energy, and economic benefits of energy and wa-
ter use reductions are very significant; the scope of innovative pollution prevention
programs must be broad to adequately address the highest-risk environmental
problems and to take full advantage of technological opportunities in sectors other
than industrial manufacturing; the Energy Policy Act of 1992 (Public Law 102-486
of October 24,1992) requires the Secretary of Energy to work with other Federal
agencies to significantly reduce the use of energy and reduce the related environ-
mental Impacts by promoting use of energy efficiency and renewable energy tech-
nologies; and
WHEREAS, as the largest single consumer in the Nation, the Federal Government
has the opportunity to realize significant economic as well as environmental ben-
efits of pollution prevention;
AND IN ORDER TO:
Ensure that all Federal agencies conduct their facility management and acquisition
activities so that, to the maximum extent practicable, the quantity of toxic chemi-
cals entering any wastestream, including any releases to the environment, is re-
duced as expeditiously as possible through source reduction; that waste that is
generated is recycled to the maximum extent practicable; and that any wastes
remaining are stored, treated or disposed of in a manner protective of public
health and the environment;
-------
41982 Federal Register / Vol. 58, No. 150 / Friday, August 6,1993 / Presidential Documents
Require Federal agencies to report in a public manner toxic chemicals entering
any wastestream from their facilities, including any releases to the environment,
and to improve local emergency planning, response, and accident notification; and
Help encourage markets for clean technologies and safe alternatives to extremely
hazardous substances or toxic chemicals through revisions to specifications and
standards, the acquisition and procurement process, and the testing of innovative
pollution prevention technologies at Federal facilities or in acquisitions;
NOW THEREFORE, by the authority vested in me as President by the Constitu-
tion and the laws of the United Slates of America, including the EPCRA, the PPA,
and section 301 of title 5, United States Code, it is hereby ordered as follows:
Section 1. Applicability.
1-101. As delineated below, the head of each Federal agency is responsible for
ensuring that all necessary actions are taken for the prevention of pollution with
respect to that agency's activities and facilities, and for ensuring that agency's
compliance with pollution prevention and emergency planning and community
right-to-know provisions established pursuant to all implementing regulations is-
sued pursuant to EPCRA and PPA.
1 102. Except as otherwise noted, this order is applicable to all Federal agencies
that either own or operate a "facility" as that term is defined in section 329(4) of
EPCRA, if such facility meets the threshold requirements set forth in EPCRA for
compliance as modified by section 3-304(b) of this order ("covered facilities").
Except as provided in section 1-103 and section 1-104 below, each Federal agency
must apply all of the provisions of this order to each of its covered facilities,
including those facilities which are subject, independent of this order, to the
provisions of EPCRA and PPA (e.g., certain Government-owned/contractor-oper-
ated facilities (GOCO's), for chemicals meeting EPCRA thresholds). This order
does not apply to Federal agency facilities outside the customs territory of the
United States, such as United States diplomatic and consular missions abroad.
1-103. Nothing in this order alters the obligations which GOCO's and Government
corporation facilities have under EPCRA and PPA independent of this order or
subjects such facilities to EPCRA or PPA if they are otherwise excluded. However,
consistent with section 1-104 below, each Federal agency shall include the releases
and transfers from all such facilities when meeting all of the Federal agency's
responsibilities under this order.
1-104. To facilitate compliance with this order, each Federal agency shall provide,
in all future contracts between the agency and its relevant contractors, for the
contractor to supply to the Federal agency all information the Federal agency
deems necessary for it to comply with this order. In addition, to the extent that
compliance with this order is made more difficult due to lack of information from
existing contractors, Federal agencies shall take practical steps to obtain the infor-
mation needed to comply with this order from such contractors.
Sec. 2-2. Definitions.
2-201. All definitions found in EPCRA and PPA and implementing regulations are
incorporated in this order by reference, with the following exception: for the
purposes of this order, the term "person", as defined in section 329(7) of EPCRA,
also includes Federal agencies.
2-202. Federal agency means an Executive agency, as defined in 5 U.S.C. 105. For
the purpose of this order, military departments, as defined in 5 U.S.C 102, are
covered under the auspices of the Department of Defense.
2-203. Pollution Prevention means "source reduction," as defined in the PPA, and
other practices that reduce or eliminate the creation of pollutants through: (a)
increased efficiency in the use of raw materials, energy, water, or other resources;
or (b) protection of natural resources by conservation.
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Federal Register / Vol. 58, No. 150 / Friday, August 6,1993 / Presidential Documents 41983
2-204. GOCO means a Government-owned/contractor-operated facility which is
owned by the Federal Government but all or portions of which are operated by
private contractors.
2-205. Administrator means the Administrator of the EPA.
2-206. Toxic Chemical means a substance on the list described in section 313(c) of
EPCRA.
2-207. toxic Pollutants. For the purposes of section 3-302(a) of this order, the
term "toxic pollutants" shall include, but is not necessarily limited to, those
chemicals at a Federal facility subject to the provisions of section 313 of EPCRA
as of December 1,1993. Federal agencies also may choose to include releases and
transfers of other chemicals, such as "extremely hazardous chemicals" as de-
fined in section 329(3) of EPCRA, hazardous wastes as defined under the Re-
source Conservation and Recovery Act of 1976 (42 U.S.C 6901-6986) (RCRA), or
hazardous air pollutants under the Clean Air Act Amendments (42 U.S.C. 7403-
7626); however, for the purposes of establishing the agency's baseline under 3-
302(c), such "other chemicals" are in addition to (not instead of) the section 313
chemicals. The term "toxic pollutants" does not include hazardous waste subject
to remedial action generated prior to the date of this order.
Sec. 3-3. Implementation.
3-301. Federal Agency Strategy. Within 12 months of the date of this order, the
head of each Federal agency must develop a written pollution prevention strat-
egy to achieve the requirements specified in sections 3-302 through 3-305 of this
order for that agency. A copy thereof shall be provided to the Administrator.
Federal agencies are encouraged to involve the public in developing the required
strategies under this order and in monitoring their subsequent progress in meet-
ing the requirements of this order. The strategy shall include, but shall not be
limited to, the following elements:
(a) A pollution prevention policy statement, developed by each Federal agency,
designating principal responsibilities for development, implementation, and evalu-
ation of the strategy. The statement shall reflect the Federal agency's commit-
ment to incorporate pollution prevention through source reduction in facility
management and acquisition, and it shall identify an individual responsible for
coordinating the Federal agency's efforts in this area.
(b) A commitment to utilize pollution prevention through source reduction,
where practicable, as the primary means of achieving and maintaining compli-
ance with all applicable Federal, State, and local environmental requirements.
3-302. Toxic Chemical Reduction Goals, (a) The head of each Federal agency
subject, to this order shall ensure that the agency develops voluntary goals to
reduce the agency's total releases of toxic chemicals to the environment and off-
site transfers of ouch toxic chemicals for treatment and disposal from facilities
covered by this order by 50 percent by December 31, 1999. To the maximum
extent practicable, such reductions shall be achieved by implementation of source
reduction practices.
(b) The baseline for measuring reductions for purposes of achieving the 50
percent reduction goal for each Federal agency shall be the first year in which
releases of toxic chemicals to the environment and off-site transfers of such
chemicals for treatment and disposal are publicly reported. The baseline amount
as to which the 50 percent reduction goal applies shall be the aggregate amount
of toxic chemicals reported in the baseline year for all of that Federal agency's
facilities meeting the threshold applicability requirements set forth in section 1-
102 of this order. In no event shall the baseline be later than the 1994 reporting
year.
(c) Alternatively, a Federal agency may choose to achieve a 50 percent reduc-
tion goal for toxic pollutants. In such event, the Federal agency shall delineate
the scope of its reduction program in the written pollution prevention strategy
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41984 Federal Register / Vol. 58, No. 150 / Friday, August 6,1993 / Presidential Documents
that is required by section 3-301 of this order. The baseline for measuring reduc-
tions for purposes of achieving the 50 percent reduction requirement for each
Federal agency shall be the first year in which releases of toxic pollutants to the
environment and off-site transfers of such chemicals for treatment and disposal are
publicly reported for each of that Federal agency's facilities encompassed by
section 3-301. In no event shall the baseline year be later than the 1994 reporting
year. The baseline amount as to which the 50 percent reduction goal applies shall
be the aggregate amount of toxic pollutants reported by the agency in the baseline
year. For any toxic pollutants included by the agency in determining its baseline
under this section, in addition to toxic chemicals under EPCRA, the agency shall
report on such toxic pollutants annually under the provisions of section 3-304 of
this order, if practicable, or through an agency report that is made available to the
public.
(d) The head of each Federal agency shall ensure that each of its covered facilities
develops a written pollution prevention plan no later than the end of 1995, which
sets forth the facility's contribution to the goal established in section 3-302(a) of
this order. Federal agencies shall conduct assessments of their facilities as neces-
sary to ensure development of such plans and of the facilities' pollution prevention
programs.
3-303. Acquisition and Procurement Goals, (a) Each Federal agency shall establish a
plan and goals for eliminating or reducing the unnecessary acquisition by that
agency of products containing extremely hazardous substances or toxic chemicals.
Similarly, each Federal agency shall establish a plan and goal for voluntarily
reducing its' own manufacturing, processing, and use of extremely hazardous
substances and toxic chemicals. Priorities shall be developed by Federal agencies,
in coordination with EPA, for implementing this section.
(b) Within 24 months of the date of this order, the Department of Defense (DOD)
and the General Services Administration (GSA), and other agencies, as appropri-
ate, shall review their agency's standardized documents, including specifications
and standards, and identify opportunities to eliminate or reduce the use by their
agency of extremely hazardous substances and toxic chemicals, consistent with the
safety and reliability requirements of their agency mission. The EPA shall assist
agencies in meeting the requirements of this section, including identifying substi-
tutes and setting priorities for these reviews. By 1999, DOD, GSA and other
affected agencies shall make all appropriate revisions to these specifications and
standards.
(c) Any revisions to the Federal Acquisition Regulation (FAR) necessary to
implement this order shall be made within 24 months of the date of this order.
(d) Federal agencies are encouraged to develop and test innovative pollution
prevention technologies at their facilities in order to encourage the development of
strong markets for such technologies. Partnerships should be encouraged between
industry, Federal agencies, Government laboratories, academia, and others to
assess and deploy innovative environmental technologies for domestic use and for
markets abroad.
3-304. Toxics Release Inventory/Pollution Prevention Act Reporting, (a) The head of
each Federal agency shall comply with the provisions set forth in section 313 of
EPCRA, section 6607 of PPA, all implementing regulations, and future amend-
ments to these authorities, in light of applicable guidance as provided by EPA.
(b) The head of each Federal agency shall comply with these provisions without
regard to the Standard Industrial Classification (SIC) delineations that apply to
the Federal agency's facilities, and such reports shall be for all releases, transfers,
and wastes at such Federal agency's facility without regard to the SIC code of the
activity leading to the release, transfer, or waste. All other existing statutory or
regulatory limitations or exemptions on the application of EPCRA section 313 shall
apply to the reporting requirements set forth in section 3-304(a) of this order.
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(c) The first year of compliance shall be no later than for the 1994 calendar year
with reports due on or before July 1,1995
3-305. Emergency Planning and Community Right-to-Know Reporting Responsibilities.
The head of each Federal agency shall comply with the provisions set forth in sections
301 through 312 of EPCRA, all implementing regulations, and future amendments to
these authorities in light of any applicable guidance as provided by EPA. Effective
dates for compliance shall be: (a) With respect to the provisions of section 302 of
EPCRA emergency planning notification shall be made no later than 7 months after
the date of this order.
(b) With respect to the provisions of section 303 of EPCRA all information neces-
sary for the applicable Local Emergency Planning Committee (LEPC's) to prepare or
revise local Emergency Response Plans shall be provided no later than 1 year after the
date of this order.
(c) To the extent that a facility is required to maintain Material Safety Data Sheets
under any provisions of law or Executive order, information required under section
311 of EPCRA shall be submitted no later than 1 year after the date of this order, and
the first year of compliance with section 312 shall be no later than the 1994 calendar
year, with reports due on or before March 1,1995.
(d) The provisions of section 304 of EPCRA shall be effective beginning January 1,
1994. i
(e) These compliance dates are not intended to delay implementation of earlier
timetables already agreed to by Federal agencies and are inapplicable to the extent
they interfere with those timetables.
Sec. 4-4. Agency Coordination.
4-401. By February 1, 1994, the Administrator shall convene an interagency Task
Force composed of the Administrator, the Secretaries of Commerce, Defense, and
Energy, the Administrator of General Services, the Administrator of the Office of
Procurement Policy in the Office of Management and Budget, and such other agency
officials as deemed appropriate based upon lists of potential participants submitted to
the Administrator pursuant to this section by the agency head. Each agency head may
designate other senior agency officials to act in his/her stead, where appropriate. The
Task Force will assist the agency heads in the implementation of the activities re-
quired under this order.
4-402. Federal agencies subject to the requirements of this order shall submit annual
progress reports to the Administrator beginning on October 1,1995. These reports all
include a description of the progress that the agency has made in complying with all
aspects of this order, including the pollution reductions requirements. This reporting
requirement shall expire after the report due on October 1,2001.
4-403. Technical Advice. Upon request and to the extent practicable, the Administra-
tor shall provide technical advice and assistance to Federal agencies in order to foster
full compliance with this order. In addition, to the extent practicable, all Federal
agencies subject to this order shall provide technical assistance, if requested, to
LEPC's in their development of emergency response plans and in fulfillment of their
community right-to-know and risk reduction responsibilities.
4404. Federal agencies shall place high priority on obtaining funding and resources
needed for implementing all aspects of this order, including the pollution prevention
strategies, plans, and assessments required by this order, by identifying, requesting,
and allocating funds through line-item or direct funding requests. Federal agencies
shall make such requests as required in the Federal Agency Pollution Prevention and
Abatement Planning Process and through agency budget requests as outlined in
Office of Management and Budget (OMB) Circulars A-106 and A-ll, respectively.
Federal agencies should apply to the maximum extent practicable, a life cycle analysis
and total cost accounting principles to all projects needed to meet the requirements of
this order.
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4-405. Federal Government Environmental! Challenge Program. The Adminis-
trator shall establish a "Federal Government Environmental Challenge Pro-
gram" to recognize outstanding environmental management performance in
Federal agencies and facilities. The program shall consist of two components
that challenge Federal agencies; (a) to agree to a code of environmental prin-
ciples to be developed by EPA, in cooperation with other agencies, that empha-
sizes pollution prevention, sustainable development and state of-the-art environ-
mental management programs, and (b) to submit applications to EPA for indi-
vidual Federal agency facilities for recognition as "Model Installations." The
program shall also include a means for recognizing individual Federal employ-
ees who demonstrate outstanding leadership in pollution prevention.
Sec 5-5. Compliance,
5-501. By December 31,1993, the head of each Federal agency shall provide the
Administrator with a preliminary list of facilities that potentially meet the
requirements for reporting under the threshold provisions of EPCRA, PPA, and
this order.
5-502. The head of each Federal agency is responsible for ensuring that such
agency take all necessary actions to prevent pollution in accordance with this
order, and for that agency's compliance with the provisions of EPCRA and PPA.
Compliance with EPCRA and PPA means compliance with the same substantive,
procedural, and other statutory and regulatory requirements that would apply
to a private person. Nothing in this order shall be construed as making the
provisions of sections 325 and 326 of EPCRA applicable to any Federal agency
or facility, except to the extent that such Federal agency or facility would
independently be subject to such provisions. EPA shall consult with Federal
agencies, if requested, to determine the applicability of this order to particular
agency facilities.
5-503. Each Federal agency subject to this order shall conduct internal reviews
and audits, and take such other steps, as may be necessary to monitor compli-
ance with sections 3-304 and 3-305 of this order.
5-504. The Administrator, in consultation with the heads of Federal agencies,
may conduct such reviews and inspections as may be necessary to monitor
compliance with sections 3-304 and 3-305 of this order. Except as excluded
under section 6-601 of this order, all Federal agencies are encouraged to cooper-
ate fully with the efforts of the Administrator to ensure compliance with sections
3-304 and 3-305 of this order.
5-505. Federal agencies are further encouraged to comply with all state and local
right-to-know and pollution prevention requirements to the extent that compli-
ance with such laws and requirements is not otherwise already mandated.
5-506. Whenever the Administrator notifies a Federal agency that it is not in
compliance with an applicable provision of this order, the Federal agency shall
achieve compliance as promptly as is practicable.
5-507. The EPA shall report annually to tho President on Federal agency compli-
ance with the provisions of section 3-304 of this order.
5-508. To the extent permitted by law and unless such documentation is withheld
pursuant to section 6-601 of this order, the public shall be afforded ready access
to all strategies, plans, and reports required to be prepared by Federal agencies
under this order by the agency preparing the strategy, plan, or report. When the
reports are submitted to EPA, EPA shall compile the strategies, plans, and
reports and make them publicly available as well. Federal agencies are encour-
aged to provide such strategies, plans, and reports to the State and local authori-
ties where their facilities are located for an additional point of access to the
public.
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[FR Doc/ 93-19069
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Sec. 6-6. Exemption.
6-601. In the interest of national security, the head of a Federal agency may request
from the President an exemption from complying with the provisions of any or all
aspects of this order for particular Federal agency facilities, provided that the proce-
dures set forth in section 120(j)(l) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (42 U.S.C. 9620(j)(D), are
followed. To the maximum extent practicable, and without compromising national
security, ail Federal agencies shall strive to comply with the purposes, goals, and
implementation steps set forth in this order.
Sec. 7-7. General Provisions.
7-701. Nothing in this order shall create any right or benefit, substantive or proce-
dural, enforceable by a party against the United States, its agencies or instrumentali-
ties, its officers or employees, or any other person.
THE WHITE HOUSE,
August 3,1993.
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