&EPA
United States
Environmental Protection
Agency
Pollution Prevention
and Toxics
(7407)
Spring/Summer 1996
EPA749-R-96-001b
Chemicals in the Environment
Public Access Information
Contents
EPA's Green Chemistry
Program
Common Sense Initiative,
Computers and Electronics
Sector
Environmentaf Technology
Initiative for Chemicals
Pollution Prevention Through
Technology Transfer
Environmentally Preferable
Products and the Role of
Federal Consumers
The Consumer Labeling
Initiative, Promoting
Household Product Safety
Voluntary Efforts in OPPT's
Existing Chemicals and
Chemical Testing Programs
Voluntary Use and Exposure
Information Project
The International Chemical
Screening Program
OPPT Tribal Action
Workgroup
Partnerships with State and
Tribal Organizations
Community Based
Environmetal Protection
Voluntary Electronic
Submissions
Right-to-Know.
A Mission for All
Developing Customer
Service Standards for the
Partnership Programs
Non-Regulatory Programs in the
Office of Pollution Prevention and Toxics (OPPT)
Michelle Price, Co-Chair, EPA Partnership Programs
Coordinating Committee
Over the last several years, an
important change has been taking
place in the Environmental
Protection Agency's (EPA)
national strategy for protecting
health and the environment. In
addition to traditional approaches
to environmental protection, such
as writing and enforcing
regulations, EPA is working with
small and large businesses,
citizen groups, and state and
local institutions to develop
cooperative nonregulatory
programs that benefit all parties
involved. This nonregulatory
approach fosters innovation in
preventing pollution, reduces
costs and increases the efficiency
of Agency operations.
This issue of Chemicals in the
Environment describes
nonregulatory programs within
OPPT and provides access to the
information products and
services associated with these
programs. EPA's Office of
Pollution Prevention and Toxics
(OPPT) administers programs on
toxic chemicals and spearheads the
Agency's effort to promote
pollution prevention. In
partnership programs such as the
Design for the Environment
Program, OPPT is encouraging
businesses to prevent pollution by
incorporating environmental
considerations into the design and
redesign of products and
processes. Through the 33/50
Program, OPPT is challenging
industries to reduce toxic
emissions of 17 target chemicals.
Through other programs, OPPT is
working with industry and other
countries to receive and publish
information on chemicals in a
timely and cost effective manner.
Though the end results of these
programs differ, together they
represent a new way of doing
business in accomplishing OPPT's
and the private sector's goals to
protect human health and the
(continued on page 2)
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Chemicals in the Environment
Spring/Summer 1996
Non-Regulatory Programs in OPPT (continued)
environment. In addition to the OPPT
information products and services described in
this issue, there is a document available which
describes most of EPA's voluntary pollution
prevention programs. This document is entitled,
"Partnerships In Preventing Pollution: A
Catalogue of the Agency's Partnership
Programs," and is available through the
Pollution Prevention Information Clearinghouse
at (202) 260-1023. The document was produced
by the Partnership Programs Coordinating
Committee (PPCC), the agency-wide workgroup
charged with coordinating the Agency's
pollution prevention partnership programs. The
mission of the PPCC is to increase public
awareness of the Agency's voluntary programs,
and to foster coordination among, and
continuing improvements in, all of our
partnership programs. For information about the
PPCC, contact Michelle Price of OPPT at (202)
260-3372.
EPA's Green Chemistry Program
Paul Anastas and Tracy Williamson, Economics, Exposure and Technology Division
Green Chemistry is the use of chemistry
for pollution prevention. More
specifically, green chemistry is the
design of chemical products and processes that
are more environmentally benign. Green
chemistry encompasses all aspects and types of
chemical processes that reduce negative impacts
to human health and the environment relative to
the current state of the art. By reducing or
eliminating the use or generation of toxic
substances associated with a particular synthesis
or process, chemists can greatly reduce risk to
human health and the environment. This new
approach to pollution prevention through the
environmentally-conscious design of chemical
products and processes is the central focus of the
Green Chemistry Program, an initiative under the
EPA Design for the Environment Program.
History
Shortly after the passage of the Pollution
Prevention Act of 1990, the Office of Pollution
Prevention and Toxics (OPPT) began to explore
the idea of developing new or improving existing
chemical products and processes to make them
less hazardous to human health and the
environment. In 1992, OPPT launched a model
research grants program called "Alternative
Synthetic Pathways for Pollution Prevention".
This program provided for the first time grants
for research projects that include pollution
prevention in the synthesis of chemicals. Since
that time, the Green Chemistry Program has built
many collaborations with other federal agencies,
industry, and academia to promote the use of
chemistry for pollution prevention through
completely voluntary, non-regulatory
partnerships.
• Goals
The goal of the Green Chemistry Program is to
foster the use of innovative chemical methods
that accomplish pollution prevention in both a
scientifically-sound and cost-effective manner.
The Green Chemistry Program recognizes and
promotes chemical methods that reduce or
eliminate the use or generation of toxic
substances during the design, manufacture, and
use of chemical products and processes and that
have broad application in industry. The program
supports research in the area of environmentally
benign chemistry, promotes partnerships with
industry in developing green chemistry
technologies, and works with other federal
agencies in building green chemistry principles
into their operations.
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Issue No. 3
Public Access Information
Current Green Chemistry Projects
The Green Chemistry Challenge. The Green
Chemistry Challenge was announced on March
16, 1995, by President Clinton as part of the
Reinventing Environmental Regulations Initiative
to "promote pollution prevention and industrial
ecology through a new EPA Design for the
Environment partnership with the chemical
industry". Design for the Environment
partnerships with industry can encourage changes
that both promote economic development and
benefit industry by helping find cost-effective
ways to prevent pollution. Green chemistry is
both a fundamental and cost-effective approach to
pollution prevention.
Through awards and grants programs, the Green
Chemistry Challenge is recognizing and
promoting the research, development, and
implementation of innovative green chemistry
approaches. On October 30, 1995, EPA
Administrator Carol Browner announced the
Green Chemistry Challenge Awards Program as
an opportunity for individuals, groups, and
organizations "to compete for Presidential awards
in. recognition of fundamental breakthroughs in
cleaner, cheaper, smarter chemistry." The Green
Chemistry Challenge Awards Program provides
national recognition for chemistry that
incorporates the principles of green chemistry
into chemical design, manufacture, and use.
SMART Review Program Concurrent to its
regulatory review of new chemical substances for
health and environmental risk, OPPT has begun
a non-regulatory initiative for assessing the
pollution potential associated not just with new
chemicals, but also with their manufacture. The
objective of the assessment is to identify the
source and type of chemicals of concern
associated with new chemicals, their
manufacture, and their use. The assessment then
focuses on how new chemicals or their
manufacture can be improved through the
implementation of one or more green chemical
approaches. All green chemical methods
identified by OPPT as potential solutions to
reducing the concerns associated with a new
chemical or its manufacture are suggested to
companies for their voluntary consideration.
Industry/University/Government Partnerships.
Fundamental research in green chemistry is
essential in providing industry with the
chemically-viable tools and methods necessary to
develop products and processes that are more
environmentally benign. Industry input in
fundamental green chemical research is important
to ensure that the tools and methods developed
are also economically viable. To accomplish this
goal, OPPT supports several
industry/university/government consortia
including the Emission Reduction Research
Center at the New Jersey Institute of Technology,
the Toxics Use Reduction Institute at the
University of Massachusetts, and the Center for
Process Analytical Chemistry at the University of
Washington.
Interagency Partnerships. OPPT has established
several partnerships with other agencies that are
also promoting pollution prevention through
green chemistry. In 1992, the National Science
Foundation and EPA signed a Memorandum of
Understanding to work cooperatively in
supporting basic green chemical research. To
date, several millions of dollars of support in the
form of grants have been made available for
green chemical research in the area of
"Environmentally Benign Chemical Synthesis
and Processing" and most recently, in the area of
"Technology for a Sustainable Development." In
addition, OPPT has established a partnership with
the Los Alamos National Laboratory also in
support of fundamental green chemical research.
Los Alamos is currently researching and
developing alternative solvents for pollution
prevention.
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Chemicals in the Environment
Spring/Summer 1996
EPA's Green Chemistry Program (continued)
Green Chemistry Curriculum Development.
One factor that can greatly speed the
incorporation of pollution prevention into
industrial manufacturing processes is addressing
pollution prevention issues in academic chemistry
curricula as well as in professional training
courses. In order for pollution prevention to
become a standard in industry, it is imperative
that chemists be educated about pollution
prevention concepts during both their academic
and professional training. To accomplish this
goal, OPPT supports a variety of educational
efforts that include the development
of materials and courses to assist in the training
of professional chemists in industry and
education of students in academia. Consequently,
the chemical industry is discovering that when
their professional chemists are knowledgeable
about pollution prevention concepts, they are able
to identify, develop, and implement effective
pollution prevention technologies.
For more information, contact Paul T. Anastas
at 202-260-2659 or
anastas.paul@epamail. epa.gov.
EPA's Common Sense Initiative,
Computers and Electronics Sector
Dave Jones, EPA Region 9 and Esther Tepper, Chemical Control Division
The Common Sense Initiative (CSI) is a
major new EPA initiative designed to
find innovative approaches to improve
environmental protection. The Computers and
Electronics Subcommittee, one of six CSI
industral sectors, is charged with finding
cleaner, cheaper, and smarter approaches to
environmental protection in the computers and
electronics industry. The subcommittee will
examine a wide range of topics, including
regulations, pollution prevention, reporting,
compliance, permitting, and environmental
technology.
The subcommittee consists of 26 members
appointed by the EPA Administrator to
incorporate the viewpoints of industry,
government, environmental, environmental
justice, academic, and labor leaders. The
subcommittee co-leads are the Assistant
Administrator for Prevention, Pesticides, and
Toxic Substances and the
Regional Administrators
from EPA Regions one
and nine.
Subcommittee Issues and Workgroups
During the first two meetings of the Computers
and Electronics Sector Subcommittee in March
and April of 1995, members identified, clarified,
and discussed problems or issues with the
existing environmental regulatory or
management structure. Folio wing these
discussions, subcommittee members established
three workgroups to address selected issues and
to explore opportunities for resolving them
through common sense, innovation, and
flexibility, with the overarching aim of achieving
a cleaner environment at less cost. The
workgroups are focusing on the following three
areas:
1) Identifying ways to overcome barriers to
pollution prevention and recycling in the
computers and electronics industry-
> Address issues associated with managing
end-of-life (EOL) electronic equipment.
Activities include developing household
collection pilots; investigating regulatory
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Issue No. 3
Public Access Information
Chemicals in the Environment: Public Access
Information is published by EPA's Office of Pollution
Prevention and Toxics (OPPT) to increase public
access to and awareness of information on toxic
chemicats and pollution prevention available through
OPPT.
This:resource is also accessible through the World
Wide Web at http://www.epa.gov It is located under
EPA Offices, Regions, and taborafories/Office of
Prevention, Pesticides and Toxics (submenu: Toxic
SubstancesyChemicals in the Environment: Public
Access Information.
(Note that the location may change in the Summer of
1996 due to changes in the Web Site)
Advisory Board
Project Manager. Georgianne McDonald
Editor/Publisher: Chuck Freeman
Internet: freeman.ctiaries@epamail.epa.gov
OPPT Divisional Representatives:
David Di Fiore, CCD
Dart Fort, EETD
Odelia Funke, MO
Ruth Heikkinen, EAD (for
PPD)
Ted Jones, CSRAD
Mike McDonell,
EAD
Joe Merenda,
HERD,
Dense Kearns,
CMD
Mailing Address:
Chemicals in the Environment: Public Access
Information
U.S. EPA (7407)
401MSWSW
Washington, DC 20460
barriers to cathode ray tube (CRT) recycling;
holding a conference on managing EOL
electronic equipment; and, in conjunction with
the conference, establishing an independent
roundtable to serve as an information
clearinghouse on and a forum for addressing
issues involving management of EOL electronic
equipment.
»• Investigate regulatory barriers to
pollution prevention and recycling in the
manufacturing process. Analyze possible
regulatory barriers to use of closed-loop,
zero-discharge wastewater recycling
processes hi the computers and electronics
industry.
2) Developing flexible, performance-based
alternative approaches for environmental
management in the computers and electronics
industry-
> Develop a more flexible system of
environmental protection for facilities that
demonstrate superior performance.
Describe the vision, goals, objectives, and
conceptual components of a facility-based
system of environmental protection that
provides more flexibility than the current
"command and control" regulatory
structure.
> Initiate a CSI sector-based pilot program
to test components of the alternative
system: Solicit proposals from computers
and electronics facilities to pilot test
different components of the alternative
system.
3) Developing streamlined and easily
accessible reporting and information systems
that meet the data needs of industry,
government, and communities-
> Consolidate and integrate the reporting
requirements that facilities must meet to
assure that they are prepared to repsond
to emergencies such as chemical spills or
releases. Pilot a comprehensive,
electronically linked, simplified, and easily
accessible emergency response system that
meets the needs of industry, government,
and the community.
> Develop a Combined Uniform Report for
the Environment (CURE): Compile a
summary of reporting requirements for the
Computers and Electronics Sector. Work
with ongoing efforts by the state of Texas to
develop a streamlined, relevant, and easily
accessible reporting information access
system that meets the needs of industry,
government, and communities.
For more information on the Computers and
Electronics Sector of the Common Sense
Initiative, contact Regina Bushong at (202) 260-
3797.
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Chemicals in the Environment
Spring/Summer 1996
Environmental Technology Initiative for Chemicals: Reducing Risk and
the Barriers to Innovation
David Di Fiore, Chemical Control Division
For many years frustration has plagued
both the manufacturers of new chemicals
and the risk management gatekeepers in
EPA's New Chemicals Program (NCP).
Manufacturers are frustrated because EPA
regulates "new" chemicals (those not yet in
manufacture in the U.S.) when similar
substances, commonly referred to as "existing
chemicals" are not controlled. Existing
chemicals are chemicals that were in commerce
when the Toxic Substances Control Act came
into being and, therefore, were not subject to
new chemical review. Manufacturers have
labeled this situation "new chemical bias" and
claim that it represents a significant, sometimes
insurmountable, barrier to the commercialization
of new chemicals.
On the flip side, the EPA risk managers in the
New Chemicals Program are frustrated because
chemical manufacturers do not apply the same
controls on existing chemicals as are required
for new chemicals, even though the existing
chemical typically forms the toxicological basis
for the Agency's risk findings. This dissimilarity
in treatment may even occur when the new and
existing chemicals are manufactured In the same
plant.
The frustrations of manufacturers and risk
managers converge in instances where a new
chemical is safer than similar existing
chemicals—the result of an innovation in
chemistry or technology— and yet still presents
risks that should be controlled. The NCP
gatekeepers do not want to erect a barrier to the
introduction of a safer new chemical and at the
same time must ensure that adequate controls are
in place to protect human health and the
environment.
Recognizing these frustrations, the New
Chemicals Program has launched a project
designed to reduce risk and the barriers to the
development, introduction and use of safer
chemicals and technologies. Known as the
Environmental Technology Initiative (ETI) for
Chemicals, this project has the following goals:
• Promote risk reduction within industry
sectors by encouraging innovation—in
chemistry, production technologies,
handling/ disposal practices—for all
chemicals, both new and existing;
• Offer industry the opportunity to work
with EPA to explore new, non-
traditional ways to manage risks;
• Refine EPA's understanding of the
toxicity and risks associated with
selected chemicals and use categories;
and
• Develop an information management
infrastructure to enhance EPA's ability to
identify risk reduction opportunities.
The ETI for Chemicals should help relieve
industry and Agency frustrations through risk
management outcomes like these:
• Manufacturers agree to change the
physical nature of a class of chemicals
from a powder or other respirable form
(something that can be inhaled) to a non-
respirable one (e.g., pellet or slurry),
thereby eliminating the potential for
inhalation exposure and the need for
traditional regulatory controls.
(continued on page 12)
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Issue No. 3
Public Access Information
Pollution Prevention Through Technology Transfer
Bill Waugh, Chemical Screening and Risk Assessment Division
The Office of Pollution Prevention and
Toxics (OPPT) has developed a variety
of analytical methods to support the
evaluation of potential risks and benefits of
chemicals. These methods include computer
modeling techniques, quantitative structure
activity relationships, automated exposure
assessment methods, and other related
methods.
Scientists evaluating the
risks of chemicals often lack
important data necessary to
characterize potential risks
of chemical substances. The
methods developed by EPA,
together with tools
developed by others, can be
used to calculate or estimate important chemical,
physical, or biological characteristics of a
chemical, based on the chemical's structure.
These methods provide critical information that
would otherwise be unavailable to scientists
evaluating the health and environmental risks of
new or existing chemical substances.
The methods help scientists understand how
chemicals move through the environment and
how people or the environment might be
exposed to such chemicals. The methods help
scientists predict the potential of a chemical to
cause certain health and/or environmental effects
(i.e. toxicity to the human nervous system,
toxicity to aquatic organisms). Other methods
help determine if people could be exposed to a
chemical of concern through drinking water or
through the air we breathe, and the magnitude of
such exposure. This information helps
scientists estimate the potential for and
magnitude of human or environmental risks
posed by individual chemicals (if any). The
methods assist in the comparison of risks
between chemicals and help identify safer
substitutes for use in commercial and/or
consumer products. The methods also help
identify chemicals of concern for laboratory
testing and for further scientific analyses.
OPPT believes these analytical methods can be
highly valuable to the private sector, state and
regional governments, and
environmental organizations in
day-to-day operations. In 1995
and 1996 OPPT and Eastman
Kodak Company worked
together on a pilot project to
evaluate the utility of our
methods to Kodak operations.
Kodak found EPA's analytical
methods very useful, enhancing processes
already in place to guide the company's research
and development efforts. EPA's methods helped
Kodak to anticipate problematic waste streams
from new synthetic pathways (procedures for
making chemicals) and to focus resources on
chemicals least likely to result in potential health
and environmental risk. Kodak's comments on
the collaboration include the following
statements:
"At the outset, we realized that
participation in the technical exchange
program could help the Health and
Environment Laboratories advance an
important goal: to provide product
development scientists with an early
assessment of the potential health and
environmental effects from chemicals
being considered for use in new product
designs or reformulations."
"...these methods, if applied early
enough in a chemical or product
development cycle, can have an
(continued on page 12)
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Chemicals in the Environment
Spring/Summer 1996
Environmentally Preferable Products and the Role of
Federal Consumers
Eun-Sook Goidel, Pollution Prevention Division
The concept of "green" products and
services certainly is a familiar one to
most consumers. Many have seen
products on grocery shelves touting the
products' environmental virtues. The prevalence
of environmental claims on the products is both
an indication of increased awareness on the part
of consumers about the integral role they can
play in improving the environment through their
purchasing patterns and an indication of
manufacturers' recognition that differentiating
their products on the basis of environmental
attributes can serve as a competitive advantage.
By demanding certain products, consumers can
send a clear signal to the manufacturers about
their preferences for those products and services
that pose fewer burdens on the environment.
By leveraging their purchasing power,
consumers are voting with their pocketbooks,
directly affecting manufacturers' bottom lines.
"Consumers" include anyone in the private or
public sector that buys goods and services,
including individuals, institutions (e.g.,
universities, hospitals, all levels of government)
and companies.
However, despite the heightened consumer
awareness and interest expressed through
various consumer polls, the market for "green"
products remains a niche market. The potential
for improving the environment through demand-
driven policies has until now been little used.
As the single largest consumer of goods and
services, expending over $200 billion annually,
the Federal government can play a unique role in
leveraging and jump starting the market for
"green" products. The fact that paper with
recovered materials content has become the
norm is an example of how purchases of such
goods by the Federal government made it more
widely acceptable and available. This was the
rationale behind the Executive Order on Federal
Acquisition, Recycling and Waste Prevention
(E.G. 1287) signed by President Clinton in
October, 1993. This Executive Order requires
Executive agencies to give preference, among
other things, to the purchase of products and
services which are "environmentally preferable."
By "environmentally preferable" the Executive
Order means those "products or services that
have a lesser or reduced effect on human health
and the environment when compared with
competing products or services that serve the
same purpose". The U.S. Environmental
Protection Agency (US EPA) was tasked with
giving further meaning to this definition.
Last fall, EPA Office of Pollution Prevention
and Toxics published a Proposed Guidance on
the Acquisition of Environmentally Preferable
Products and Services (60 F.R. 50722,
September 29, 1995). This represented a
culmination of lengthy discussions with key
stakeholders, including major Federal
purchasing agencies (such as the Department of
Defense, the General Services Administration,
Department of Energy, etc.), manufacturers,
trade associations, and environmental
organizations about what "environmental
preferability" means within the context of
Federal purchasing. The Federal government
is like any other consumer in the sense that it
buys many products that are similar to those
individual consumers buy (but in much larger
quantities), such as cleaning products, food
goods, automobiles, etc., there are significant
differences as well, both in terms of what and
how it buys. The most important difference
perhaps is that individual consumers in the
private sector are not governed by the complex
8
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Issue No. 3
Public Access Information
set of laws and regulations (put in place to
ensure wise use of tax payers' dollars) that the
Federal government must follow when making
purchases. The Guidance was developed with
these similarities and differences in mind.
EPA's Guidance serves as a broad framework
within which Federal agencies can initiate
efforts to make more environmentally preferable
purchasing decisions. It lays out a series of
principles that are intended to guide Federal
purchasers as they consider environmental
preferability in their acquisition decisions.
These guiding principles include:
* Consideration of environmental
preferability should begin early in the
acquisition process and be rooted in the
ethic of pollution prevention:
* A product or service's environmental
preferability is a function of multiple
attributes:
> Environmental preferability should
reflect life-cycle considerations of
products and services to the extent
feasible;
> Environmental preferability should be
tailored to local conditions where
appropriate.
Through voluntary pilot projects, EPA, in
cooperation with other Executive agencies, is
applying these principles to specific acquisitions
and developing guidance for certain product
categories. Currently underway are pilot
projects on cleaners and construction. Other
pilots are in the planning stages. While the
Guidance is aimed at public and private policy-
makers, the product guidances are intended to be
more detailed, practical and "user friendly" for
use by procurement and contracting officers.
These pilot projects will serve as important
testing grounds for how the Federal
government can take a leadership role in
protecting the environment through the decisions
it makes about the products and services it
purchases.
The Executive Order and OPPT's program
discussed in this article are geared towards
changing what and how the Federal government
buys the products and services it uses. However,
given the changes taking place hi the Federal
acquisition process whereby more and more
Federal consumers will be allowed to buy
directly off the shelf, the line between private
and public sector market place will become
increasingly blurred. Recognizing the potential
spill-over effect into the private market place,
manufacturers and their trade associations have
been particularly interested in the issues
associated with environmental preferability.
And the discussions begun during the
development of the Guidance will likely
continue. This is desirable given the complex
and dynamic nature of the issues associated with
environmental preferability. For example, as
technology and scientific knowledge advances,
the definition of what is environmentally
preferable will have to evolve to reflect these
changes as well. As these discussions continue,
EPA's responsibility is to ensure that key
stakeholders are engaged and that the debate
furthers the goal of achieving environmental
improvement using consumers' purchasing
power.
To obtain a brochure and guidance document on
the Environmentally Preferable Products
Program, contact EPA's Pollution Prevention
Information Clearinghouse at (202) 260-1023.
Additional information products will be made
available through the clearinghouse in the future.
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Chemicals in the Environment
Spring/Summer 1996
The Consumer Labeling Initiative, Promoting Household Product Safety
Mary Dominiak, Chemical Control Division
DANGER
TOXIC
VAPORS
On March 22, 1996, EPA's Office of
Prevention, Pesticides, and Toxic
Substances (OPPTS) announced the start
of the Consumer Labeling Initiative (CLI), a
voluntary program designed to find ways to
improve the labels on household chemical
products by making essential health, safe use, and
environmental information easier for consumers to
find, understand, and use. Between March and
September 1996, EPA will
conduct research
cooperatively with other
Federal and State
agencies, with industry
partners, and with other
interested groups to learn directly from consumers
what problems or dissatisfactions they have with
current labels, and how those labels might be
improved from the consumer's perspective. EPA
will use this research to form recommendations to
the EPA Administrator for future action to
implement label changes.
The CLI is a pilot project focusing on three
principal product categories: indoor household
pesticides, particularly insecticides; outdoor lawn
and garden pesticides; and household hard surface
cleaners, including disinfectant and antimicrobial
(for example, mold and mildew remover)
products. EPA currently regulates the labeling on
pesticide products, including disinfectants. EPA's
pesticide labeling regulations were originally
developed for professional applicators working in
agricultural settings, however, and do not
distinguish between agricultural products and ones
intended for consumer home and garden use. This
means that the labels often contain technical
information and language that is not easily
understood.
A number of industry partners are working
together with EPA and the Task Force in
designing the project research and formulating
possible solutions. These partners include the
Clorox Company, Procter & Gamble, Reckitt
&Coleman (the manufacturers of Lysol®
products), SC Johnson, the Solaris Group (a unit
of Monsanto Corporation which owns the Ortho®,
Round-Up®, and Green Sweep® product lines),
the Chemical Specialties Manufacturers
Association, the Chemical Producers and
Distributors Association, and Responsible Industry
for a Sound Environment. In addition to EPA, the
Task Force includes representatives from the
Consumer Product Safety Commission (CPSC),
the Food and Drug Administration (FDA), the
Federal Trade Commission (FTC), the Vermont
Agency of Natural Resources, the California
Office of Environmental Health and Hazard
Assessment, the American Association of Pest
Control Officials, and the Forum on State and
Tribal Toxics Actions (see page 17).
The research this summer will include one-on-one
interviews with consumers in six cities around the
country. Individuals and groups have also been
-^ invited to submit
comments and ideas, and
to participate in the
research process. In
September, the EPA staff,
together with the Task
Force members and the industry partners, will
present a report to the EPA Administrator
summarizing what has been learned, and EPA
staff will make recommendations for additional
action to implement label improvement ideas.
If you would like to submit comments or ideas,
you can send them to: OPPT Document Control
Officer (7407), AR-139 - Consumer Labeling
Initiative, Environmental Protection Agency, 401
M Street, SW, Washington, DC 20460. All
comments and all reports prepared during the
project will be placed in this record and will be
available for public review. If you have questions
on the project, you can call Mary F. Dominiak,
CLI Task Force Co-Chair, at (202) 260-3068.
CAUTION
AVOID SKIN
CONTACT
10
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Issue No. 3
Public Access Information
Voluntary Efforts in OPPT's Existing Chemicals and
Chemical Testing Programs
Deborah Williams & Dave Williams, Chemical Control Division
Over the past several years, OPPT has
increased its efforts to use non-
regulatory and voluntary approaches as
tools of first choice in its Risk Management 2
(RM2) and Chemical Testing Programs. Much
of the success realized in this area builds on
the chemical industry's own public
commitment to proactive, voluntary
product stewardship programs such as the
Chemical Manufacturers Association's
"Responsible Care" program. These
types of voluntary industry programs
represent a fundamentally different approach
to corporate responsibility for health and
environmental matters.
Risk Management 2
Based on an initial screening in Risk Management
1 (RM1, another component of the Existing
Chemicals Program), some chemicals are targeted
for further assessment. In OPPT's RM2 Program,
chemicals are further analyzed and investigated,
and options are developed to address any concerns
identified. After RM2 analyses, if risk
management is appropriate, OPPT implements one
or more options designed to reduce or eliminate
risks. These options may be regulatory, non-
regulatory or a combination of both. Whether or
not a voluntary approach is pursued depends on
several factors: the relative willingness of an
industry to engage in a voluntary activity; the
ability to leverage other groups to promote an
option or to assume some of the burden for
generating or disseminating information, and the
status of other EPA or government activities that
could affect a risk management decision.
In recent years, the RM2 Program has moved
away from regulatory approaches that relied on
Section 6 of TSCA as its primary tool of choice to
control chemical exposure. Instead, creative uses
of non-traditional tools - such as establishing
partnerships between local, state and federal
governments, promoting safer chemical
substitutes, developing product stewardship
agreements, developing information products,
disseminating information to customers,
conducting outreach activities and providing
local communities with the information and
tools they need to become better
environmental stewards - have become very
effective risk management tools for OPPT.
Chemical Testing
OPPT's Chemical Testing Program pursues
opportunities for voluntary testing agreements to
fill data needs before it uses its testing authority
under TSCA Section 4. This benefits EPA,
because the resources required to develop
voluntary product stewardship-related agreements
are far fewer than those needed to issue a test rule
under TSCA Section 4. Voluntary testing
agreements afford greater flexibility than the
regulatory process. Benefits for the industry
participants include the opportunity to negotiate
the appropriate testing and how it will be
conducted. Examples of voluntary agreements
with industry range in complexity from simple
testing agreements to comprehensive programs
that encompass testing efforts and complementary
product stewardship programs. These product
stewardship programs may include pollution
prevention and other types of risk reduction
activities. In some cases, a product stewardship
program agreement is captured by way of a formal
"Memorandum of Understanding" (MOU)
between EPA and one or more chemical
companies.
Product Stewardship
Product stewardship is a risk management tool
used by both theTesting and RM2 Programs. The
voluntary submission of periodic (generally
11
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Chemicals in the Environment
Spring/Summer 1996
annual) reports to EPA is a key feature of many of
the product stewardship program agreements
OPPT has entered to date. The initial reports
provide a baseline — information which serves as
a yardstick for assessing future activities.
Subsequent reports contain a description of the
activities undertaken and the improvements
realized under the company's product stewardship
efforts. Another important feature of some of the
voluntary agreements negotiated to date is an
industry commitment to design and implement
their product stewardship programs in a manner
that helps ensure the protection of health and the
environment for all people, regardless of race,
ethnic background, or socioeconomic status.
OPPT has commended several chemical
companies for their strong leadership, foresight,
and commitment to develop and implement
voluntary product stewardship programs. OPPT's
Existing Chemicals and Chemical Testing
Programs will continue to use voluntary
approaches as well as other innovative chemical
testing and risk management approaches as OPPT
strives to create meaningful partnerships with
industry and others (e.g., communities, local
governments, etc.) to pursue efforts to protect
human health and the environment.
For information on EPA's risk assessment and risk
management process on chemicals, see the Winter
1995/96 Issue of Chemicals in the Environment.
For more information on the Existing Chemicals
Voluntary Programs, contact Deborah Williams at
(202)260-1734
(Internet: Williams. deborah@epamail. epa. gov).
Environmental Techonolgy Initiative for Chemicals (continued)
Rather than confirm a likely human health
effect through additional toxicity testing,
EPA and an industry consortium agree to
allocate resources differently—either for
research and development on innovative
control technologies to reduce
occupational exposures, or to create a fund
to expand the use of these technologies.
A company develops a safer way to
synthesize a class of chemicals,
reducing toxicity vis-a-vis existing
products, and enhances its product
stewardship program to ensure safe and
effective use; in return, EPA eliminates a
potential barrier to commercialization of
the product line by adopting a voluntary
approach to risk management.
For more information, contact either Mary
Cushmac (202-260-4443) or David Di Fiore (202-
260-3374), chairs of the ETI for Chemicals work
group.
Pollution Prevention Through Technology
immediate and positive impact on programs to
reduce the potential hazards from commercial
manufacturing operations."
"The methodologies supplied by the Agency
allowed those chemicals with the greatest
potential hazard to be eliminated from further
consideration at a point in time when the
economic impact of the decision was minimal. By
applying the methods early in the development
cycle, we were able to avoid unnecessary
expenditures on product formulations for which
appropriate alternatives were available or could be
Transfer (continued)
developed."OPPT is evaluating how best to share
these methodologies with other companies and
organizations. OPPT is considering ways to
improve the utility of the methodologies and
working with companies and other organizations
to more broadly disseminate the methods.
For more information on the technology transfer,
call Bill Waugh (202) 260-3489. For information
on Chemical structure activity relationships, see
the Winter 1995/96 issue of Chemicals in the
Environment, page 7.
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Issue No. 3
Public Access Information
Voluntary Use and Exposure Information Project
Greg Macek, Economics, Exposure and Technology Division
The Voluntary Use and Exposure
Information project is a program
developed jointly by EPA and industry.
It provides a method for
chemical manufacturers to
voluntarily send use and
exposure information to OPPT
for the chemicals entering
EPA's Existing Chemicals risk
management screening assessment (RM1).
The program started in the fall of 1992 when the
Chemical Manufacturers Association (CMA) and
the Synthetic Organic Chemical Manufacturers
Association (SOCMA) asked OPPT what the
chemical industry could do to help strengthen
OPPT's Existing Chemicals Program. OPPT
explained that accurate use and exposure
information was not readily available and that
better information in this area was a key need. A
joint industry/OPPT workgroup was formed to
address this need and work on this program.
More recently, other significant trade group
stakeholders including the American Petroleum
Institute (API) and the Chemical Specialties
Manufacturers Association (CSMA) have
participated in the further development of this
project.
In this program, manufacturers and importers
voluntarily report the following information for
chemicals that is needed to assess chemical
exposures:
production volume
site location
% of production volume for a given use
environmental releases that occur to
different media
worker exposure - (e.g. number of
workers by job category, personal
protective equipment worn, monitoring
data)
>• industrial and consumer uses
Chemicals selected for this project so far have
been of concern because of the potential toxicity.
For example, some are believed to be persistent
in the environment, and some have been potential
carginogens.
Upon receipt of data on use and exposure from
manufacturers and importers, EPA prepares a
screening level exposure assessment. Submitters
have an opportunity to comment on the
assessments EPA develops. During EPA's
review of a chemical, submitters have further
opportunity to provide input.
Through this program EPA gets exposure data
faster and avoids resorting to contentious
regulation. Chemical manufacturers become
aware of chemicals EPA is concerned about and
can help ensure accurate assessments of chemical
risks.
Use of this program for transferring data to EPA
has been successfully tested in a pilot and two
rounds of information gathering covering 45
chemicals. EPA received enough information to
proceed with the development of 17 use and
exposure profiles covering 22 of the chemicals.
Fifteen chemicals have been selected for the next
round of data collection which began in May
1996.
For more information, contact Greg Macek at
(202) 260-9597
Internet: macek.greg@epoma.il.epa.gov.
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Chemicals in the Environment
Spring/Summer 1996
The International Chemical Screening Program
Ralph Northrop, Chemical Control Division
Since the 1970s, member countries of the
Organization for Economic Cooperation
and Development (OECD) have been
working together to address issues on chemical
safety. One of the major problems is that of
evaluating the tens of thousands of chemicals
already in commerce known as "existing
chemicals." OECD members decided to focus
on the chemicals having the highest worldwide
production, and to collect for each one a
standard minimum set of data. OECD would
then use the data to screen these "high-
production-volume" (HPV) chemicals for their
potential risks to man and the environment. By
1990, the United States and 13 other OECD
member countries were ready to start a voluntary
international testing program to develop the data
set for the first group of chemicals.
This basic level of testing and other information
devised by the OECD is called the Screening
Information Data Set, or SIDS. The SIDS
includes information on the identity of the
chemical, its physical and chemical properties,
uses, sources and extent of exposure,
environmental fate (for example, whether it
degrades quickly and how it might be distributed
throughout the environment), and limited
toxicity data for humans and the environment.
The SIDS is not intended to describe the
chemical thoroughly, but to provide enough
information to assign a
priority for further study.
HPV chemicals are those
with a production volume of 22 million
pounds (10,000 metric tons) per year hi one
member country or 2.2 million pounds per
year in two or more member countries. The
1995 HPV list of 2,550 chemicals combines
the European Union's (EU) HPV list and
the updated HPV lists from non-EU OECD
member countries like the United States and
Japan.
Once sponsor countries
have selected chemicals from the HPV List, they
collect data; prepare SIDS Dossiers
(standardized summaries of the available
information) and Testing Plans (for chemicals
lacking some of the SIDS data); circulate SIDS
Dossiers and Testing Plans to other countries for
review and approval; review and comment on
the documents prepared by other countries; carry
out SIDS testing and add the new data to the
Dossier; and prepare a SIDS Initial Assessment
Report (SIAR). OECD review of SIARs (at
SIDS Initial Assessment Meetings, or SIAMs)
determines whether chemicals have a low
priority for further work or whether further
(Post-SIDS) testing or analysis of more detailed
exposure information is needed.
The SIDS program benefits many parties in the
following ways:
- Directs international efforts and resources
toward the chemicals of greatest potential
risk;
- Improves environmental protection and human
health as existing chemicals are
investigated more effectively;
-Reduces duplication of testing by chemical
companies to fulfill various national and
regional requirements;
- Reduces national financial costs of testing as a
result of increased international
cooperation in testing;
- Reduces use of animals in testing;
- Increases mutual understanding of national
procedures for assessing chemicals, with
eventual agreement on methods;
- Makes widely available chemical data and
initial assessments;
- Provides greater flexibility for companies that
might otherwise be subject to government-
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Issue No. 3
Public Access Information
imposed testing;
-Increases information resources for countries
having less sophisticated chemical safety
programs.
Nearly 300 chemicals are undergoing data
collection, testing and assessment in the OECD
SIDS framework; each year, about 50 more
chemicals enter the process. So far around 500
tests have been undertaken under the auspices of
the 18 countries now taking part. Testing is
done by standard methods in order to ensure that
the results are mutually acceptable among
Member countries. The results of the SIDS
program are available to all countries through
the International Registry of Potentially Toxic
Chemicals (IRPTC) and the International Pro-
gram for Chemical Safety (IPCS).
EPA and OPPT have played a major leadership
role in developing and implementing the OECD
SIDS program, initially meeting with various
U.S. federal agencies, the chemical industry, and
environmental groups to sort out differences and
develop support for the effort. Voluntary
cooperation of the industry and its umbrella
organizations is critical to the success of the
program. As the official U.S. SIDS Contact
Point, OPPT coordinates U.S. contributions to
the program. OPPT now incorporates OECD
SIDS activities and products into its Existing
Chemical Program, reviews all SIDS
assessments as part of its own Risk Management
process, and adds SIDS chemicals to its Master
Testing List.
If you would like more information about the
SIDS program, please contact Karen Boswell,
Chemical Control Division (7405), OPPT,
Environmental Protection Agency, 401 M Street,
S.W., Washington, D.C. 20460; telephone, (202)
260-1635; fax, (202) 260-8850;
Internet: boswell.karen@epamail.epa.gov.
Screening Information on the Internet
The public can access reports developed under the Screening Information Data Sets (SIDS)
Program, Voluntary Use and Exposure Information Project (VUEIP) and EPA risk management
process through the following information access points:
EPA's World Wide Web Server:
httptfwww. epa. gov
click on-
EPA Offices, Regions and Laboratories/
Office of Prevention Pesticides and Toxic Substances/
International Screening Information Data Sets
Toxic Substances Control Act Assistance Information Service:
(202) 554-1404
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Chemicals in the Environment
Spring/Summer 1996
OPPT Tribal Action Workgroup
Kathy Hogan, Tribal Coordinator, Office of Pollution Prevention and Toxics
The Office of Pollution Prevention and
Toxics (OPPT) Tribal Action Workgroup
is initiating activity to improve OPPT's
understanding of Tribal environmental issues so
that we can better relate OPPT activity to Tribal
concerns. A related activity of the Workgroup is
to improve OPPT's communication with Tribes.
In coordination with our Regional counterparts,
we are planning OPPT's first direct mailing to
Tribes about the work, products, and services of
OPPT. We will use the mailing as an opportunity
to underscore the connection between the work of
OPPT and its relationship to Tribal EPA
Agreements (TEAs). Supporting these agreements
is a priority initiative of the EPA's American
Indian Environmental Office. TEAs provide the
primary vehicle for Tribes to communicate their
self-determined list of environmental priorities to
the Agency.
The basis of all OPPT Tribal Action Workgroup
activity is the Agency's Indian Policy, as
announced in 1984, and then reconfirmed with an
additional implementation Action Plan by the
Administrator in 1994. The Workgroup has
placed these and other basic Tribal documents on
the OPPT's internal Electronic Bulletin Board as
a tool to advance staff training in Tribal matters.
The active support of staff training and improved
communication with Tribes are two of the
important goals set forth in the Administrator's
1994 Action Plan.
The Agency works to help build Tribal capacity
and, wherever possible, supports the exercise of
Tribal sovereignty and self-determination.
Through participation in biweekly teleconferences
with the Agency's National Indian Workgroup,
and the National Indian Law Workgroup, OPPT
Tribal Action Workgroup members are kept
informed of current Tribal issues and report any
essential information to management for response.
Workgroup members also participate in various
activities with the Forum on State and Tribal
Toxics Action's State and Tribal Enhancement
Program (see page 17).
As a separate initiative, the Workgroup Chair has
collected virtually all existing Tribal Constitutions
in a project to assist Tribes in building an
important information resource capacity. Tribal
Constitutions, along with treaties, agreements,
codes, and ordinances, define the legal parameters
of Tribal sovereignty. Currently, many Tribes are
revising and strengthening their Constitutions.
Creating an electronic version of some 500+
Constitutions and using a state-of-the-art search
engine will help Tribes conduct research in
revising their Constitutions. The collection will
serve as an important addition to basic Tribal
documentation. The partnership organized for this
project includes the Department of Energy, the
National Congress of American Indians (208
tribes), the Mne Sose Coalition (26 Tribes), the
Fourth World Documentation Project of the
Center for World Indigenous People, the National
Indian Law Library, the Tribal Law and
Government Center of the University of Kansas
Law School, the University of Arizona Library,
the Spirits of the Land Foundation, the EPA's
American Indian Environmental Office and Tribal
Operations Committee, and others.
For more information on Tribal Programs within
OPPT, contact Kathy Hogan, the OPPT Tribal
Coordinator, at (202) 260-9349 (Internet:
hogan.kathy@epamail.epa.gov).
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Issue No. 3
Public Access Information
Partnerships with State and Tribal Organizations
Darlene Harrod, Environmental Assistance Division
In an effort to ensure that EPA toxic and
pollution prevention programs are
responsive to state and tribal concerns,
EPA's Office of Pollution Prevention and
Toxics (OPPT) and Office of Enforcement and
Compliance Assurance formed the Forum on
State and Tribal Toxics Action (FOSTTA).
Since April 1991, EPA, the states, and tribes
have been working together to forge a
cooperative relationship to incorporate state
views into important elements of EPA's
programs. Today, FOSTTA is composed of a
group of about 35 state and tribal environmental
officials and convenes three times each year in
the Washington, DC, area to exchange
information and provide feedback to EPA
management and staff.
FOSTTA currently consists of four
issue-specific projects and two workgroups. In
brief, the projects and workgroups do the
following:
The Chemical Management Project evaluates the
use of information on existing and new
chemicals and how this information can be
accessed by various organizations and the
general public.
The Lead Project reviews initiatives within the
national lead program, such as the development
of training, accreditation and certification
requirements for lead abatement professionals.
The State and Tribal Enhancement Project
focuses on getting community, state, and tribal
input on environmental protection initiatives.
The Toxics Release Inventory (TRI) Project
entails working together to ensure the best way
to make information collected under TRI
available to the public and how EPA can help
state programs serve their constituents.
The Environmental Justice and Pollution
Prevention Workgroups discuss current issues
and initiatives in their areas to ensure that these
considerations are incorporated into the work of
each of the four FOSTTA projects.
Through FOSTTA, the states and tribes have
provided constructive comments and
suggestions to EPA on issues considered in all
of these projects and workgroups, as well as on
major initiatives, including state access to
Confidential Business Information and OPPT's
pilot effort to develop tools and approaches
useful in communities, and the Baltimore
Community-Based Environmental Project.
For more information, please contact Darlene
Harrod, EPA's FOSTTA Coordinator, at
202-260-6904.
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Chemicals in the Environment
Spring/Summer 1996
Community Based Environmental Protection-
Protecting People and Places
Christine Augustyniak, Deputy Director, Environmental Assistance Division
Community based environmental
protection is a refocussing of the
Agency's work so that we respond not
only to legislative and executive mandates but
also to the actual needs of specific places. When
'real' people think of their environment they
don't necessarily think of it the way we at EPA
Headquarters do; issues are not air issues as
distinct from water or solid waste or toxic
chemicals issues. What concerns people is the
interaction of these traditional EPA issues with
everyday concerns; such as trash collection,
quality of public parks, etc.; that are not matters
which EPA addresses.
Although EPA will continue to have a role in
promulgating regulations and in setting national
standards, and the Office of Pollution Prevention
and Toxics (OPPT) has and will continue to
have the role of minimizing or preventing risks
associated with exposure to toxic substances, it
is also important that we contribute what we can
to local efforts to implement holistic, place-
based, environmental protection. How will we
do this?
In May of 1995, the Office of Prevention
Pesticides and Toxic Substances (OPPTS) laid
out a strategy for its role in place-based
environmental protection [OPPTS is the Office
within EPA that manages OPPT and the Office
of Pesticides Programs (OPP)].
This strategy was based on a recognition of five
factors:
1.OPPTS has a large and unique collection of
information about chemicals. This information
includes toxic substances and pesticides data in
addition to the Toxic Release Inventory (TRI)
which collects and releases to the public
information about emissions of high concern
chemicals to the air, water, and land.
2.OPPTS has a variety of technical guidance and
analytical tools for gathering data and assessing
the risks and benefits of industrial chemicals and
pesticides.
3.The statutes which OPPTS implements allow
us the flexibility to develop chemical
management strategies that take into account
local environmental and economic needs.
4.The statutes which OPPTS implements deal
with all areas of the environment together, rather
than separately, such as addressing pollution to
air, water and land. This makes us good
partners.
5.OPPTS currently participates directly in
several place-based management projects.
Participating in these projects, which include
projects in the Great Lakes and Chesapeake Bay
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Issue No. 3
Public Access Information
as well as Lead Environmental Justice Pilot
Grants, has given us experience in place-based
projects which can be transferred to new
projects.
Given these five factors, OPPTS concluded that
the most important short-term contribution we at
headquarters could make was to develop a
catalogue of tools- including databases and
analytic methods, which could be used in place-
based projects. This compendium of
information is what we refer to as the 'Catalogue
of Tools'.
EPA Offices in Washington are not alone in this
re-focussing. The regions have been instructed
by Deputy Administrator Fred Hansen to devote
20 percent or their resources to direct
participation in community-based projects,
which is to say working with the stakeholders in
the state and local governments as well as with
community groups.
All of the Headquarters offices have been asked
to develop strategies to support the regions in
their place-based activities. Other offices,
including the Office of Water and the Office of
Research and Development, have also assembled
databases and methodologies into toolboxes.
The OPPTS catalogue consists of a variety of
types of tools. Some are reports and hotline
numbers, which though available elsewhere are
included for easy reference. Some are the
databases and analytic methods used in OPPTS
assessments which will allow others to perform
customized, place-based, analyses. For
example, in the annual data release under the
Toxics Release Inventory (TRI)
Program (OPPT issues some
standard reports, such as total
emissions by state), using the
TRI data would allow a
community to focus on
emissions of particular
interest- perhaps air emissions
of heavy metals in a particular county. This
kind of analysis can help a community set
priorities and determine on which
environmental problems it should focus
attention. Analysis may reveal that fewer heavy
metals are emitted to the air than previously
suspected- perhaps in this community there is a
different issue which deserves priority.
How far are we in implementing this strategy?
At present we have a draft Catalogue of Tools
and are evaluating opportunities to field-test the
document and answer the question, "Does it
serve the need we have designed it to serve?"
After completing a number of field tests the
catalogue will be revised to incorporate what we
have learned. We will also be assessing how our
tools should be linked with the tools being
assembled by other EPA programs. After all, in
a community, toxic substance issues are not
discrete from other issues. Once revisions are
complete we will be making the catalogue
widely available- enabling communities to have
more information and consequently more
involvement in determining the characteristics of
their own environment.
For more information about Community-based
Environmental Protection, contact Christine
Augustyniak at (202) 260-1024.
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Chemicals in the Environment
Spring/Summer 1996
Voluntary Electronic Submissions,
Increasing Efficiency in the Information Age
Gerry Brown, Information Management Division
The Toxic Substances Control Act (TSCA)
requires industry to submit information and
studies, and conduct testing for existing
chemical substances under Sections 4 and 8.
Under normal TSCA reporting conditions,
OPPT receives approximately 1500 submissions
each year, based on existing statutory and
regulatory requirements; each submission
represents on average between three and four
studies. In addition, OPPT can initiate specific
data (study) call-ins. For example, the
Interagency Testing Committee established
under TSCA identifies chemicals for which
member agencies have concerns and need
additional information. OPPT writes rules under
TSCA 8(d) that require companies to submit
copies of any studies they have conducted for
these chemicals.
When OPPT receives a study under TSCA, we
log it into our system, then duplicate and
distribute it to government scientists for review
and analysis. We also have a process to briefly
define the study and its findings, using indexing
terms to categorize the study and its results. This
summary information is made available through
the TSCA Test Submissions (TSCATS)
database [see Chemicals in the Environment,
Summer 1995, page 4], which is available online
for use by government officials and the general
public. It is only a pointer system to the large
volume of unpublished studies, however. OPPT
also microfiches the studies; full texts are
available on paper or microfiche through the
National Technical Information Service (NTIS).
TSCATS now includes information on over
80,000 studies; industry estimates that these
studies represent an investment in excess of $7
billion. The test information indexed in this
database can be very useful for government and
industry, and is of interest to many other parties
as well. Handling, indexing and retrieving this
unpublished information accurately and in a
timely manner has become increasingly difficult
and expensive. OPPT realizes that it would be
far more efficient if these data were transmitted
and managed electronically. We have been
working with industry officials who share our
interest in reducing the amount of paper and
streamlining our process.
The first pilot effort was led by industry, in
response to a data call-in for chemicals
(siloxanes) identified by the Interagency Testing
Committee (ITC). Based on requirements
defined by industry, the ITC, and OPPT staff,
industry developed a model software application
for submitting summary data on computer
diskette, in addition to the usual paper copies of
the tests themselves. Following that pilot effort,
OPPT has continued to work with industry
representatives from interested companies and
industry associations to take this effort further.
The Chemical Manufacturers Association
(CMA), the Synthetic Organic Chemical
Manufacturers Association (SOCMA), and the
Chemical Industry Data Exchange (CIDX) are
interested in pursuing electronic submittal of full
text (including charts and tables) as well as the
summary or indexed information.
Following the pilot effort for siloxanes under
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Issue No. 3
Public Access Information
TSCA 8(d), OPPT worked with CMA to define
the most important summary information
elements (study abstracts and index information
that mirrors what is in TSCATS). CMA
designed and produced a cover sheet for
voluntary submittal of this information under
TSCA 4 and 8. We expect this next pilot to
begin in mid-1996. The cover sheet will
expedite the processing, review, and public
availability of test information; it will reduce
database errors. Savings will be realized in
reduced process and data management costs for
OPPT; reduced human resource costs, with
index terms and abstracts aiding in scientific
retrieval, screening and review; considerably
cheaper and quicker access to summary
information; and improved quality through
standardized format and terms. This is a first
step to familiarize companies with standard
requirements and concepts of electronic
commerce for TSCA data. OPPT and CMA will
evaluate it to determine if anticipated savings in
time and money, and improvements in quality
and availability are realized. We hope it will
initiate a process that will result in full-text
submittal of test data under TSCA Sections 4
and 8.
In addition to the cover sheet pilot, OPPT is
exploring other voluntary electronic submission
pilots. Current efforts include:
• Putting the CMA cover sheet on the
Internet, to develop an interactive, on-
line means to complete and transfer the
information to EPA and to the TSCATS
database.
• Working with industry to conduct one or
two additional efforts to collect TSCA
8(d) data on chemicals identified by the
ITC. As with the siloxanes project, these
efforts have an additional component.
Studies are not simply submitted by
individual companies; data on the ITC-
designated chemicals are collected and
consolidated by industry into a single
database; it includes information
about individual studies, which can also
be cross-referenced.
• Piloting the submission of an entire study
in one or more electronic formats. OPPT
is pursuing the transfer of full texts with
one or two companies via floppy disk or
CD ROM or mag cartridge.
As we pursue these voluntary pilot efforts,
OPPT and industry participants want to address
generic issues, such as how to include
documents with confidential business
information in an electronic process. OPPT
needs to reach key players in industsry and other
groups who have an interest in or knowledge
about electronic commerce. This includes
skeptics. Therefore OPPT is sponsoring an effort
to assess the overall interest in and support for
electronic submission of TSCA data. An
independent consultant has been identifying
stakeholders and discussing issues and
possibilities with them. As a result of this effort,
OPPT expects to convene a series of meetings to
discuss issues and concerns, define possibilities,
and to monitor OPPT progress with the various
pilots. Ultimately we are seeking a consensus to
establish principles and processes for electronic
submission of TSCA data.
We believe that electronic submission of data
would bring benefits for the Agency, industry
and others who are interested in environmental
data. Electronic transfer of TSCA studies,
inlcuding the test summaries, would help insure
that industry, government, and other users
understand the findings similarly— or that
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Chemicals in the Environment
Spring/Summer 1996
differences are identified and discussed. While
there are still skeptics in industry, many
recognize the advantages in terms of their own
internal data management and the efficiency of
data transfer to EPA. It seems that the greatest
potential benefit to industry is the cost savings
that might be realized by avoiding unnecessary
expenditures for duplicate studies. Timely
availability and a better characterization of
studies in TSCATS could help companies
narrow the number and range of studies they
need to characterize a particular chemical.
Participants hi this voluntary effort believe that
we also realize intangible benefits by building
cooperative relations and developing joint
projects.
Electronic commerce will provide benefits for
all of us, including the public, by improving the
timeliness, completeness, accuracy, availability,
accessibility, and understandability of
environmental information.
Right-to-Know: A Mission for All
John Chelen, The Unison Institute
When the Emergency Planning and Community
Right-to-Know Act of 1986 (Title HI of the
Superfund Amendments and Reauthorization
Act) was passed, an extraordinary framework
for community involvement in pollution
prevention and emergency preparedness was
created. Ordinary citizens would be
empowered through the use of data that had
been previously available only to a privileged
few.
However, EPCRA also marked a sea change in
thinking about how, hi general, government
data should be shared. Additionally, with the
explosive growth in the Internet and the World
Wide Web, our expectations of what
government agencies should be doing also has
changed. We now have every expectation that
government should actively seek out ways to
communicate with the public and encourage
their use of information.
What is RTK?
At its heart, "Right-To-Know" (RTK) refers to
more than the provision of information about
potentially dangerous activities. Although the
original advocates who helped pass EPCRA
relied upon a rationale that was built upon the
fears of another Bhopal, RTK is a much more
fundamental right. Reporters and investigators
call for RTK for many kinds of issues,
including election campaign finance data,
government procurement information, budget
and expenditures, and agency rulemaking.
From this perspective, RTK is founded upon a
concern for fundamental fairness.
Government should not act without the explicit
consent of the governed. Unless the voter is
aware of the rationale and basis for a decision,
that voter is not fully franchised. This means
that RTK is a fundamental aspect of "Due
Process." Unless adequate information is
made available, any process, and any resultant
decisions, are inherently unfair.
When we consider environmental protection,
it's easy to understand how RTK applies. If
facilities are permitted to emit toxic waste, then
the public is entitled to know how much waste
is emitted and what the effects of those toxics
may be. If a facility is to be located hi a
community, the community is entitled to know
what risks are associated with that facility.
If we look at other government programs, then
we can see that RTK should apply there as
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Issue No. 3
Public Access Information
well. If the government is spending money,
RTK applies so that we know who receives the
money, what they are providing, and how well
they have done the job. Similarly, a
legislator's voting record and list of campaign
contributors must be known.
Implementing RTK
At its heart, RTK is accomplished by collecting
information and then re-distributing it,
typically by a government agency. However,
RTK is more. RTK data must be
comprehensive — we need access to national
data. In order for the people hi a community to
understand what is going on hi their own home
town, they need to be able to see what is going
on in other similar communities. Moreover,
RTK data must be put hi perspective by
providing other data that complete the picture.
Toxics data alone is valuable, but it is even
more valuable when combined with census and
health data.
The technology selected for providing RTK
data is also important. Modern computer
technology makes distribution of the data over
computer networks ideal, especially since the
data are likely to be quite large. However,
some people do not have or can not use
computers, and need the information distributed
on paper. Therefore RTK data require a range
of distribution methods, from high-tech
Internet Web pages, paper reports, and direct
technical assistance.
processes encourage citizens to become
informed and involved.
False arguments about RTK
Some people have argued that RTK programs
are "regulatory, top-down" or
"command-and-control" approaches, where the
strong arm of government forces industry to
comply with complex regulations. Nothing
could be further from the truth. A typical
regulatory approach might involve putting
further limits on emissions or forcing polluters
to buy more pollution control equipment.
Alternatively, having polluters provide RTK
information on the potential harm they are
inflicting on others is not a
"command-and-control" approach. In fact, it
is close to a pure "laissez-faire" market-driven
approach. Citizens are free to take any steps
they wish. Any corrective action is left up to
the marketplace. Citizens are free to decide
which products to buy, which companies' stock
to purchase, which Congressman they wish to
vote for, and which businesses they want to
have hi then" communities.
Arguments are also made that RTK would
infringe on secrets that polluters have a valid
right to keep, either those involving business
secrets or national security. However, RTK
laws are designed to provide information on
potential public harm without divulging
legitimate intellectual property or military
secrets. We have yet to witness or document
any major case in which secrets were
Finally, government has to encourage the improperly divulged.
actual use of the information. We need to
know how people hi our local communities can The Future
put the information to use and encourage that
process. We have to make sure that local
reporters can research and develop stories, that
zoning and planning agencies can include the
data in then" own decisions, that local
industrial plants can track their own behavior,
and that our regulatory and permitting
We are seeing other federal agencies, and states
and local government as well, embrace RTK.
Our elected officials know that RTK makes
good politics - it engenders trust and
participation by the electorate. The U.S.
Departments of Housing and Urban
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Chemicals in the Environment
Spring/Summer 1996
Development, Energy, and others, are moving
to expand their RTK efforts. The Office of
Management and Budget is working to help
provide access to more information through
the Internet and is encouraging efforts to
coordinate and link federal data. There is
literally a race on by various agencies to see
who can provide the best service to the public
through the Internet.
Nonetheless, if we want substantive RTK
information, we will have to continue the
struggle to make it meaningful. We must urge
EPA to make RTK a key part of all ongoing
regulatory programs. We need EPA to
encourage every program office to actively
encourage the use of its information by the
general public. We must highlight the brave
steps that some offices take, especially when it
entails risk to them that then* own flaws and
mistakes might be made visible. We need to
make sure government employees,
congressmen, and industry representatives are
supported and rewarded when they take steps to
meet RTK challenges.
We also have to encourage industry to act
proactively on its own behalf. The leadership
of major industrial firms have acknowledged
that RTK information has been useful to them
and made them aware of ways to save money.
They also acknowledge that the burdens of an
RTK reporting program are much less, and
inherently provide more flexibility, than prior
regulatory approaches. We need to help them
encourage other firms to embrace RTK
techniques and voluntarily support new RTK
initiatives. We need to encourage industry to
work with government, environmental
advocates, the media, and academia, to fulfill
the promise of RTK.
Developing Customer Service Standards for the Partnership Programs
Darlene Harrod, Environmental Assistance Division
Executive Order 12862, Setting Customer
Service Standards, directs all executive
departments and agencies to establish and
implement customer service standards to ensure
that the Federal Government provides the
highest quality service possible to the American
people. At the U.S. Environmental Protection
Agency (EPA), workgroups were formed to
develop and implement standards for the
following core processes: Permitting; Pesticide
Registration; Research and Demonstration
Grants; Rulemaking; Public Access; State,
Tribal, and Local Program Grants; Enforcement
Inspections and Compliance Assistance; and
Partnership Programs.
Programs such as Waste Wise, Water Alliances
for Voluntary Efficiency (WAVE), Green
Lights, 33/50, Climate Wise, and the Pesticide
Environmental Stewardship Program promote
partnerships with large and small businesses and
other organizations to create opportunities for
demonstrating environmental protection
leadership. These efforts complement
traditional, regulatory approaches to
environmental protection by emphasizing
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Issue No. 3
Public Access Information
pollution prevention, common sense, flexibility,
and economic performance. EPA publicly
recognizes participants and their successes in
enhancing environmental quality and public
health. The development of customer service
standards will be a continuous process to
strengthen our partnership programs Primary
customers of the Partnership Programs are the
large manufacturing and service firms; small and
large businesses; hotels and motels; nonprofit
organizations; utilities; agricultural
organizations; and local, state, and municipal
agencies.
The draft Customer Service Standards
Workgroup for Partnership Programs developed
the draft standards listed below.
1) We will always treat our customers with
professional courtesy and respect.
2) We will proactively provide our customers
accurate, up-to-date, and reliable information,
products, and services, including high quality
documents and publications.
3) We will actively listen to our customers'
concerns and needs regarding our services and
will develop technical assistance services, where
possible, designed to address those needs and
concerns.
4) We will ensure that inquiries will be referred
to the right office and individual in EPA, or
beyond EPA, if appropriate. We will encourage
customers to report back on unsuccessful
referrals.
5) We will respond as expeditiously as possible
to inquiries for information.
6) We will strive to make information available
through various channels, including electronic
media, faxes, and intermediaries such as state
assistance organizations, trade associations, and
state agencies.
7) We will recognize and publicly acknowledge
the accomplishments of our customers who
achieve success in voluntary programs.
8) We will make every effort to streamline and
make customer reporting requirements as
practical and least burdensome as possible.
EPA is collecting internal and external
comments before finalizing the standards. The
comments will be reviewed, and changes will be
incorporated into the draft final standards. Next
year, emphasis will be placed on developing and
distributing a customer satisfaction survey for
EPA's external customers.
If you would like to submit comments on the
standards, please send them to Darlene Harrod
no later than July 8,1996, to U.S. EPA, Mail
Code 7408,401 M Street, SW, Washington, DC
20460 (telephone:202-260-6904; e-mail:
harrod.darlene@epamail.epa.gov; fax: 202-260-
2219).
As referenced in the introduction, the
Pollution Prevention Information
Clearinghouse (PPIC) has available a
document entitled "Partnerships in
Preventing Pollution: A Catalogue of the
Agency' s Partnership Programs". To
order a copy of the Catalogue or a fact
sheet which includes contact telephone
numbers for each of EPA's 28 partnership
programs, call the PPIC at (202) 260-
1023.
Also visit EPA's Partners for the
Environment home page at
http://www.epa. gov.partners
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