&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)

-------
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.

-------
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.

-------
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

-------
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.

-------
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)

-------
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)

-------
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

-------
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.

-------
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

-------
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

-------
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.

-------
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.
                                          13

-------
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-
                                          14

-------
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
                                         15,

-------
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).
                                            16

-------
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.
                                         17,

-------
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
                                          18

-------
 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.
                                          19

-------
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
                                         20

-------
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
                                          21

-------
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
                                          22

-------
 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
                                          23

-------
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
                                         24

-------
 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
                                          25,

-------