EPA-SAB-EEC-98-008
United States Science Advisory EPA-SAB-EEC-98-008 t-
Environmental Board July 1998
Protection Agency Washington DC
AN SAB REPORT: REVIEW
OF ORD'S POLLUTION
PREVENTION RESEARCH
STRATEGY
REVIEW OF THE OFFICE OF
RESEARCH AND DEVELOPMENT'S
DRAFT POLLUTION PREVENTION
RESEARCH STRATEGY BY THE
ENVIRONMENTAL ENGINEERING
COMMITTEE
U.S. Environmental Protection Agency
Region 5, Library {PL*12J>
77 West Jackson Boulevard, 12th Floor
Chicago. It. 60604-3590
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
July 14, 1998
PDA QAR PPP Qfl nn« tX OFFICE OF THE ADMINISTRATOR
EPA-SAB-bEC-98-008 V SCIENCE ADVISORY BOARD
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Subject: AN SAB Report: Review of ORD's Pollution Prevention
Research Strategy
Dear Ms. Browner:
At the request of the Office of Research and Development (ORD), the Pollution
Prevention Subcommittee of the Science Advisory Board's (SAB) Environmental
Engineering Committee's (EEC) conducted a review of the ORD's Pollution Prevention
Research Strategy. This research strategy was developed by ORD research
coordination teams in consultation with EPA's regulatory program offices. In brief, the
Pollution Prevention Subcommittee (PPS) was charged to comment on the strategy's
assessment of the current state-of-the-art and trends; the relationship of the ORD's
Strategic Plan to the strategy, vision, mission, and long-term goals; the scope and
priorities of the regulatory program; and the appropriateness of the project areas under
the goals (the detailed Charge is located in section 2.3 of the enclosed report).
The Subcommittee met on June 30-July 3, 1997 at the National Risk
Management Research Laboratory (NRMRL) in Cincinnati, Ohio. The results of that
review are summarized in this letter, and provided in detail in the enclosed report.
The EEC notes with pleasure ORD's progress in strategic planning. The 1996
ORD document Strategic Plan for the Office of Research and-Development (EPA,
1996), was critical to this transition. The 1997 draft Pollution Prevention Research
Strategy (EPA, 1997a) is one of the first documents the EEC has reviewed that takes
this process further.
The existence of a pollution prevention research strategy is, in itself,
commendable progress. In 1994, the EEC's strategic research planning commentary
(SAB, 1994) recommended development of a vision statement; a definition of a mission;
an assessment of strengths, weaknesses, external opportunities, and threats; and
identification of strategic initiatives and metrics of success. The EEC now recommends
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two advancements to the pro'cess of research strategy development — the involvement
of external organizations in the process and the transparent documentation of decisions
in the resulting research strategy.
The Subcommittee finds that the vision and mission statements for the research
strategy effectively capture the appropriate role of the ORD in pollution prevention and
also recognize the importance of making pollution prevention precepts and tools useful
to society. The strategic rationale for the ORD's program provides a clear basis for
delineating research priorities. The ORD considered pollution prevention needs in
national and internal strategies and in advice provided by advisory boards (e.g., SAB).
The end result of the research strategy development process appears reasonable. The
long-term goals developed for the research strategy are consistent with the mission
statement. Thus, if the long-term goals are thoroughly executed, significant advances
toward the stated vision will occur.
Goals I and II address the successful development and deployment of
technologies, products, tools, and methodologies targeted at high-priority health and
environmental problems. Goal III emphasizes ORD's role of supporting verification;
verification can potentially accelerate the use of pollution prevention products and
technologies. Goal IV recognizes that targeted social science research could foster
more rapid adoption of pollution prevention.
Implementation of the strategy is likely to produce results that will improve the
Agency's capacity in pollution prevention and reduce risks to human health and the
environment. Within the universe of research opportunities considered in the strategy,
the programs and projects highlighted are reasonable and largely justifiable. Strategic
planning for pollution prevention, however, is a dynamic process, and the strategy may
need revision as new information becomes available.
The strategy could be strengthened by documenting the decision process as well
as the product of those decisions. The EEC also has some concerns about how the
long-term goals translated into specific projects. Some of the research projects and
products walk a thin line between providing a useful product or service, one that would
not otherwise be available, and infringing on the domain of commercially viable products
and services. This is especially true in the area of software development. Inclusion of a
clear, written disclosure identifying the nature and types of technology products that the
ORD should or should not pursue would be invaluable as a guide.
Based on the Subcommittee's expertise and ORD briefings, the Subcommittee
concludes that the strategy is being successfully implemented. The projects being
undertaken in the pollution prevention field by the ORD address high-risk issues and
also build upon the core competencies and experiences of the ORD. However, there is
a concern that the level of resources provided to ORD seems inadequate for the
diversity and depth of the pollution prevention research activities planned.
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The Committee appreciates the opportunity to review the draft Pollution
Prevention Research Strategy and looks forward to a written response from the
Assistant Administrator of ORD.
Sincerely,
Joan M. Daisey, Char
Science Advisory Board
Dr. Ishwar P. Murarka, Past Chair
Environmental Engineering Committee
Science Advisory Board
Dr. Hilary I. Inyang, Chair
Environmental Engineering Committee
Science Advisory Board
(3JL$ C.
Dr. Calvin Cnien, Chair
Pollution Prevention Research Strategy
Subcommittee
Environmental Engineering Committee
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NOTICE
This report has been written as part of the activities of the Science Advisory
Board (SAB), a public advisory group providing extramural scientific information and
advice to the Administrator and other officials of the Environmental Protection Agency
(EPA). The Board is structured to provide balanced, expert assessment of scientific
matters related to problems facing the Agency. This report has not been reviewed for
approval by the Agency and, hence, the contents of this report do not necessarily
represent the views and policies of the EPA nor of other agencies in the Executive
Branch of the Federal government. In addition, the mention of trade names or
commercial products does not constitute a recommendation for use.
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ABSTRACT
At the request of the Office of Research and Development (ORD), the
Environmental Engineering Committee (EEC) of the Science Advisory Board (SAB)
reviewed the draft Pollution Prevention Research Strategy.
In general, implementation of the strategy is likely to produce results that will
improve the Agency's capacity in pollution prevention and reduce risks to human health
and the environment. The vision and mission statements for the research strategy
effectively capture the appropriate role of the ORD in pollution prevention and also
recognize the importance of making pollution prevention precepts and tools useful to
society. The strategic rationale for the ORD's program provides a clear basis for
delineating research priorities.
The programs and projects highlighted in the draft strategy are reasonable and
largely justifiable. The long-term goals developed for the research strategy are
consistent with the mission statement. Thus, if the long-term goals are thoroughly
executed, significant advances toward the stated vision will occur.
The strategy could be strengthened by documenting the decision process as well
as the product of those decisions, including the translation of long-term goals into
specific projects. Such documentation could improve the transparency of the process,
especially to stakeholders whose support the Agency needs to ensure the
implementation of effective pollution prevention programs which we expect will result
from the developed research strategy.
Keywords: pollution prevention, research strategy,
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U.S. ENVIRONMENTAL PROTECTION AGENCY
Science Advisory Board
Environmental Engineering Committee
Pollution Prevention Subcommittee
CHAIR
Dr. Calvin C. Chien, Corporate Remediation, DuPont Company, Wilmington, DE
REVIEWERS
Dr. Stephen L. Brown, Risks of Radiation and Chemical Compounds, Oakland, CA
Dr. Edgar Berkey, Concurrent Technologies Corporation, Pittsburgh, PA
Ms. Lois N. Epstein, P.E., Environmental Defense Fund, Washington, DC
Mr. Terry Foecke, Waste Reduction Institute, St. Paul, MN
Dr. Nina Bergan French, SKY+, Oakland, CA
Dr. James H. Johnson, Jr., School of Engineering and Computer Science, Howard
University, Washington, DC
Dr. Wayne Kachel, MELE Associates, Brooks AFB, TX
Dr. Richard Kimerle, St. Louis, MO
Dr. Michael J. McFarland, Utah State University, Department of Civil and Environmental
Engineering, Logan, UT
Dr. Robert B. Pojasek, Cambridge Environmental, Inc., Cambridge, MA
Dr. Rita Schenck, Eco Sense, West Rutland, VT
SCIENCE ADVISORY BOARD STAFF
Mrs. Kathleen W. Conway, Designated Federal Officer, U.S. EPA, Science Advisory
Board (1400), 401 M Street, SW, Washington, DC 20460
Mrs. Dorothy M. Clark, Management Assistant, U.S. EPA, Science Advisory Board
(1400), 401 M Street, SW, Washington, DC 20460
in
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U.S. ENVIRONMENTAL PROTECTION AGENCY
Science Advisory Board
Participants in the June 30-July 3,1997 Meeting of the
Environmental Engineering Committee
EEC CHAIR
Dr. Ishwar P. Murarka, Electric Power Research Institute, Palo Alto, CA1
EEC MEMBERS
Dr. Edgar Berkey, Concurrent Technologies Corporation, Pittsburgh, PA
Dr. Calvin C. Chien, Corporate Remediation, DuPont Company, Wilmington, DE
Dr. Nina Bergan French, SKY+, Oakland, CA
Dr. Hilary I. Inyang, University of Massachusetts, Lowell, MA
Dr. James H. Johnson, Jr., Howard University, Washington, DC
Dr. Jo Ann Lighty, University of Utah, Salt Lake City, UT
Dr. John P. Maney, Environmental Measurements Assessment, Hamilton, MA
Ms. Lynne Preslo, Earth Tech, Long Beach, CA
Dr. Wm. Randall Seeker, Energy & Environmental Research Corp., Irvine, CA
MEMBERS OF OTHER SAB COMMITTEES
Dr. Stephen L. Brown, Risks of Radiation and Chemical Compounds, Oakland, CA
Dr. Richard Kimerle, St. Louis, MO
SAB CONSULTANTS AND INVITED PARTICIPANTS
Ms. Lois N. Epstein, P.E., Environmental Defense Fund, Washington, DC
Mr. Terry Foecke, Waste Reduction Institute, St. Paul, MN
Dr. Wayne Kachel, MELE Associates, Brooks AFB, TX
Dr. Michael J. McFarland, Utah State University, Logan, UT
Dr. William Pease, Environmental Defense Fund, Oakland, CA
Subsequent to the public meeting, Dr.- Hilary I. Inyang replaced Dr. Muraka as Chair of the EEC.
iv
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Dr. Frederick G. Pohland, Department of Civil and Environmental Engineering,
University of Pittsburgh, Pittsburgh, PA
Dr. Robert B. Pojasek, Cambridge Environmental Inc., Cambridge, MA
Dr. Rita Schenck, Eco Sense, West Rutland, VT
Dr. Nga Iran, Johns Hopkins University, Baltimore, MD
Dr. Lauren Zeise, California Environmental Protection Agency, Berkeley, CA
Science Advisory Board Staff
Mrs. Kathleen W. Conway, Designated Federal Officer, U.S. EPA, Science Advisory
Board (1400), 401 M Street, SW, Washington, DC 20460
Mrs. Dorothy M. Clark, Management Assistant, U.S. EPA, Science Advisory Board
(1400), 401 M Street, SW, Washington, DC 20460
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TABLE OF CONTENTS
1 EXECUTIVE SUMMARY 1
1.1 Generic Comments on Research Strategy Development 1
1.2 Specific Comments on the Draft Pollution Prevention Research Strategy . 1
2 INTRODUCTION 3
2.1 Background of the Review 3
2.2 Description of the Document Reviewed 3
2.3 Charge for the Review 4
3 RESPONSE TO THE CHARGE 6
3.1 Question 1 6
3.1.1 Future direction 7
3.1.2 Short-term focus 7
3.1.3 Tools and initiatives 7
3.2 Question 2 8
3.2.1 Priorities and Role 9
3.2.2 Clarification and assumptions 9
3.2.3 Connection to priorities 10
3.2.4 Use of Analytical Techniques and Product Design Tools 11
3.2.5 Summary Comments 12
3.3 Question 3 12
3.4 Question 4 15
3.5 Question 5 16
3.6 Question 6 ' 19
3.6.1 Assumed Mapping of Projects to Goal II 19
3.6.2 Tables Illustrating a Ranking Process 20
3.7 Question 7 21
3.8 Question 8 22
4 CONCLUSIONS 24
APPENDIX A - RANKED RESEARCH AREAS A-1
APPENDIX B - MATERIALS REVIEWED B-1
GLOSSARY G-1
REFERENCES R-1
VI
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1 EXECUTIVE SUMMARY
The EEC has commented on the substance of the draft Pollution Prevention
Research Strategy and recommended generic improvements on its development.
1.1 Generic Comments on Research Strategy Development
A research strategy should document the process by which it was developed.
Ideally, if all of the people involved with creating the strategy left and a new team was
formed, the research strategy document would allow the new team to see not only what
decisions were made, but also how and why they were made. Secondly, a research
strategy should identify who is working in which areas, both inside and outside EPA.
Mapping needs against what is currently being researched will identify gaps (and
potential areas for collaboration). The gaps are opportunities for the EPA. Such
analysis also adds credence to ORD's need for expertise in the research areas. Thirdly,
the strategy should address EPA's role in the research area(s)-not just ORD's.
1.2 Specific Comments on the Draft Pollution Prevention Research Strategy
. In response to the Charge, the EEC finds that, overall, the draft research strategy
correctly describes the current state of pollution prevention. The EEC suggests that
EPA consider additional time frames. The activities that are selected to satisfy short-
term needs should continue to be picked within a framework that is structured to
address issues that could emerge in the long term. Such a framework should be
flexible enough to accomodate changes in program directions.
The vision and mission statements for the research strategy are excellent. The
vision statement is:
Scientifically based pollution prevention research and development
products will be used routinely by communities, industries, governments,
and other stakeholders for improved environmental decision making on
high-risk human health and environmental problems and as part of a move
toward sustainable development in the 21st century.
The mission statement is:
To advance scientific research and develop cost-effective tools, methods,
technologies, and approaches which expand the availability and use of
pollution prevention by both the public and private sectors.
The vision and mission statements clearly present the appropriate role of the
ORD in pollution prevention. Because the four long-term goals developed for the
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research strategy are consistent with the mission statement, if the long-term goals are
thoroughly executed, significant advances toward the stated vision will occur.
The draft strategy recognizes the importance of making pollution prevention
precepts and tools useful to society. Research in this field requires more than just the
development of technologies to achieve progress. Relevant social, economic, and
behavioral factors are also important components in this process. In places, however,
the draft strategy emphasizes technology without fully embracing the need to integrate
economics, technology, social science, etc., with environmental performance.
The strategic rationale presented in the draft research provides a clear basis for
delineating research priorities. The ORD considered pollution prevention needs in
national and internal strategies, and in advice provided by advisory boards (including
the SAB). The end result appears reasonable, and until recently, this was sufficient for
a successful strategy. However, professional expectations for research strategy
development now include documentation and transparency of process. The process
through which the current research strategy was developed is not documented and
transparent; by current standards, this is a serious weakness in the strategy.
To improve the strategy, the EEC specifically recommends that the next attempt
explicitly apply relevant and mutually independent criteria in a more formal and
quantitative process to set priorities among potential areas of pollution prevention
research. Of the six criteria identified in the strategy (p. 11-13), the EEC finds three to
be appropriate. These three criteria are:
a) Address high-risk human health or environmental problems;
b) Respond to needs of stakeholders; and
c) Fill important research and development gaps not being addressed by
others.
The EEC expects that more than three criteria will be needed to distinguish the
priority of potential research areas. Other possible criteria include:
a) The probability of success;
b) Reversibility of negative impacts;
c) Impact of waiting;
d) Effectiveness of research in addressing the need; and
e) Availability of human, facility, and funding resources to meet user needs.
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2 INTRODUCTION
2.1 Background of the Review
In 1996, the U.S. Environmental Protection Agency (EPA) Office of
Research and Development (ORD) published its Strategic Plan for the Office of
Research and Development. That plan, and the more recent 7997 Update to ORD's
Strategic Plan (EPA, 1997b), include two priority long-term goals addressing pollution
prevention:
a) To provide common sense and cost-effective approaches for preventing
and managing risks; and
b) To provide leadership and encourage others to participate in identifying
emerging environmental issues, characterizing the risks associated with
these issues, and developing ways of preventing or reducing these risks.
The SAB's Research Strategies Advisory Committee (RSAC) reviewed a draft of
ORD's strategic plan (SAB, 1996) and commented that:
The general sense of RSAC was that the Plan represents a monumental
undertaking and an important step forward. We congratulate ORD and EPA for
producing a well-written document that responds to advice given to the Agency
by other external review groups, such as the SAB and the National Academy of
Sciences. The Plan clearly states the vision and mission of ORD, articulates the
principles underlying EPA research, delineates long and short-term research
goals, and presents criteria for priority setting. The existence of the Plan,
coupled with the desire of the Agency, and specifically ORD management, to
implement it, will provide ORD with much needed guidance for setting its
immediate and future research agenda.
Based on these goals noted above, the ORD formed Research Coordination
Teams (RCTs) to coordinate the research program across the ORD and with ORD's
clients. The RCTs are organized by media (i.e., air, waste, water, toxics/pesticides,
multi-media). The RCTs developed a series of research strategies in different areas,
which are being reviewed by the SAB as they become available. The research
strategies elaborate on the directions in the strategic plan and provide a framework to
guide investments in research and development over the next five years.
2.2 Description of the Document Reviewed
The ORD's External Review Draft: Pollution Prevention Research Strategy, May
30, 1997, characterizes the state-of-the art of pollution prevention and considers where
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the EPA can play a meaningful role. Based on internal and external discussions, the
ORD has identified the following pollution prevention themes:
a) Life-cycle assessment (LCA) and costing research to provide the scientific
basis for comparing alternative risk management approaches;
b) Techniques to measure pollution prevention effectiveness and verify the
performance of pollution prevention strategies;
c) Pollution prevention approaches for the agricultural sector;
d) Pollution prevention approaches to reduce greenhouse gases, including
alternative energy (renewable) sources; and
e) Pollution prevention approaches for targeted industries.
In addition to these themes, the ORD developed the following six priority-setting
criteria to drive choices in research:
a) Address high-risk human health or environmental problems;
b) Respond to the needs of stakeholders;
c) Fill important research and development gaps not being addressed by'
others;
d) Produce multimedia solutions that have wide applicability;
e) Apply knowledge, experience, and capabilities that reside within the ORD;
and
f) Leverage resources with other organizations.
2.3 Charge for the Review
The ORD asked the EEC to comment upon the following eight questions:
a) Is the research strategy on target in describing the current state of
pollution prevention, where it should be focused in the near term, and
where it needs to be directed in the future (i.e., sustainable development)?
b) Does the strategic review and program scoping provide a clear sense of
priorities and identify the role for ORD's pollution prevention research
effort? Does it support the opportunities for pollution prevention research
and development described in Chapter 3.0? Have any opportunities for
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ORD research in pollution prevention been missed, and, if so, what are
they?
c) Are the four long-term goals consistent with the mission of the research
strategy, and, if thoroughly executed, will they effectively achieve the
stated vision? If not, what improvements or changes are recommended?
d) Are the prioritization criteria listed in Chapter 2.0 of the research strategy
thorough and will they permit rational and reasoned decision making on
which projects should be pursued as part of a more detailed research and
development implementation plan? If not, what needs to be done?
e) Are the research and development activities and project areas presented
under each of the four long-term goals generally understandable and
achievable? If not, what suggestions do you have for improvements?
f) Are the project areas described under Long-Term Goal II (Technologies
and Approaches) appropriate for the broad scope of the research
strategy? If not, what changes do you recommend?
g) Is the breadth and extent of Long-Term Goal IV (Social Science)' sufficient
to advance economic, social, and behavioral issues that enhance or limit
the acceptance of pollution prevention?
f) Overall, does the research strategy support the position stated in the ORD
strategic plan that pollution prevention (along with new technology) is one
of six high-priority research areas that should be pursued? Is it supportive
of a risk-based approach or is a stronger argument needed?
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3 RESPONSE TO THE CHARGE
Separate from its comments on the specific contents of Pollution Prevention
Research Strategy, the EEC recommends that the considerations below be included in
developing a research strategy.
Firstly, the strategy should document what decisions were made and how.
Ideally, if all of the people involved with creating the strategy left and a new team was
formed, the research strategy document should allow the new team to see not only what
decisions were made, but how and why they were made.
Although the direct and indirect benefits associated with some of the research
areas (e.g., agriculture, global warming) may be difficult to quantify, these research
areas are extremely important and should be addressed. Research issues that seem to
be characterized by elevated risks should be identified and possible measures
determined for addressing each type of risk.
Secondly, the strategy should identify who is (or should be) working in which
areas, both inside and outside EPA. Mapping what needs to be done against what is
currently being researched will identify gaps (and potential areas for collaboration). The
gaps analysis will identify opportunities for the EPA and also contributes credence to
ORD's need for expertise in the research area.
Thirdly, the strategy should address EPA's role in the various pollution prevention
research areas, be it leadership or otherwise. A clarification of the EPA's role will help
set the course of the overall strategy.
Fourthly, the strategy may be linked with the efforts that EPA has expended in
the area of environmental management system development (such as, ISO 14000).
These management principles would help improve the implementation of the strategy
and make the research results more useful.
3.1 Question 1
Is the research strategy on target in describing the current state of pollution
prevention, where it should be focused in the near term, and where it needs to be
directed in the future (i.e., sustainable development)?
Overall, the research strategy is on target in describing the current state of
pollution prevention. However, the EEC suggests both redirecting the strategy to better
meet future research needs responsive to a sustainable development paradigm, and
modifying the strategy to better meet short-term needs.
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3.1.1 Future direction
The EPA is correct in recognizing that the future of pollution prevention is at a
crossroads. Considering this situation, a more aggressive and accelerated research
effort would be indicated in order to extend pollution prevention into the 21st century.
From the Subcommittee's assessment, a longer-term research program that addresses
sustainability development aspects has the potential of being fruitful. The EEC
recommends that the EPA take an aggressive stance regarding the importance of
pollution prevention in sustainable development and demonstrate how pollution
prevention tools now under development can provide a path toward sustainability.
3.1.2 Short-term focus
The strategy states that "all of the low-hanging fruits have been picked." The
EEC disagrees.. There are still many small and medium-sized firms and government
agencies that have under-emphasized pollution prevention. The justifiable effort on
long-term pollution prevention programs should not necessarily mean neglect of
technical support programs for small and medium sized firms and agencies. The Office
of Pollution Prevention and Toxics (OPPT) in EPA's Office of Prevention, Pesticides,
and Toxic Substances has funded many technical assistance programs educating firms
about pollution prevention. However, OPPT's programs have generally served larger
firms, leaving the smallest firms in need of pollution prevention guidance. Clearly, more
can be done to encourage pollution prevention in smaller industrial and governmental
organizations.
Seemingly overlooked in the strategy is the recycling of mixed solid waste.
Although the technology currently exists to implement technologies like recycling and
composting, their full potential has not been realized.
3.1.3 Tools and initiatives
Companies taking a systems approach to pollution prevention find a variety of
tools to be useful, including those for process characterization, problem solving, and
decision making. These tools are common to quality management programs in these
same companies. EPA should encourage the use of problem solving and decision
making tools for both their internal work and in publications that are developed to help
targeted industries and smaller firms seek continual improvements in their pollution
prevention programs and as a path for achieving sustainability in their operations. A
series of articles on these tools appeared in the journal, Pollution Prevention Review.
Identification of appropriate initiatives will be easier when EPA has improved its
understanding of the research needs.- The following activities may advance that
understanding:
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a) Stakeholder definition and polling: To determine whether the research
strategy is on target, a larger set of stakeholders should be contacted to
assess the needs that cannot be met with current tools. The National
Pollution Prevention Roundtable and the American Institute for Pollution
Prevention can help EPA identify potential stakeholders. The National
Institute of Standards and Technology (NIST) has 90 centers which also
provide technical assistance to small and mid-sized firms and small
business development centers.
Other stakeholders are citizen groups and nongovernmental organizations
involved in the EPA Common Sense Initiative (EPA, 1997c). Moreover,
the American Institute for Pollution Prevention tracks a large number of
trade and professional associations that have shown interest in pollution
prevention. Finally, the Department of Defense and the Department of
Energy have active pollution prevention programs and could be potential
collaborators or clients.
b) Needs analysis: One approach to strategic planning is to conduct a
needs analysis by targeting a point in the future (e.g., 5 or 10 years) and
determining what is required to get there. The gap between current
circumstances and the point envisioned in the planning process can reveal
research needs, A focus group of knowledgeable pollution prevention
experts could be convened to brainstorm about the gaps and needs.
Such a group should include EPA and external representatives and could
be facilitated by use of the Internet.
c) Relationship between manufacturing and pollution prevention: Much
research has been conducted on just-in-time source reduction (i.e., the
elimination of all wastes from all business practices), agile manufacturing,
manufacturing resources planning, preventive maintenance, and a variety
of related topics. What was learned about source reduction and waste
reduction? With some research, could some of these lessons be
embraced within the pollution prevention context? What other research
needs existing in these fields would improve the effectiveness of EPA's
research program on pollution prevention? The EEC recommends that
the EPA attempt to answer these questions during the next year while
preparing the first annual update of its plan.
3.2 Question 2
Does the strategic review and program scoping (Chapter 2.0) provide a clear
sense of priorities and identify the role for the ORD's pollution prevention
research effort? Does it support the opportunities for pollution prevention
research and development described in the Chapter 3.0 program description?
8
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Have opportunities for ORD research in pollution prevention been missed, and, if
so, what are they?
3.2.1 Priorities and Role
The strategic review and program scoping presented in the draft research
strategy provides a clear basis for delineating research priorities. The ORD considered
pollution prevention needs in national and internal strategies, and in advice provided by
advisory boards (including the SAB). The end result appears reasonable. Professional
expectations for research strategy development now include documentation and
transparency of process. The process through which the current research strategy was
developed is not adequately documented and transparent. This is a weakness in the
strategy development process, not the resulting strategy.
Section 3.4 presents and addresses criteria used to rank areas of potential
research. Both sections 3.2.1 and 3.4 recommend a more formal and quantitative
process for priority setting. Here, the EEC recommends that individual projects be
ranked using a balance of three criteria, called "project review critiera". These are:
a) Effectiveness of research to reduce pollution, protect human health, and
protect the environment, i.e., sufficiency of the research with respect to
meeting the needs of the users seeking to achieve source reduction and
protect human health and the environment; '
b) Implemention capacity of the staff at the NRMRL, i.e., ability to meet
user needs; and
c) Resource constraints at NRMRL, i.e., adequacy of available resources
to meet user needs
3.2.2 Clarification and assumptions
Sustainability is not an overall guiding principle for the strategy, but rather a goal
to be achieved eventually. As a result, the strategy focuses almost exclusively on
environmental performance and does not embrace the necessity of integrating
economics, technology, social science, etc., with environmental performance.
The introductory paragraph to the strategy defines pollution prevention not only
as a broad area, but one whose "...breadth...pose[s] a significant challenge." This is
true only if pollution prevention is considered to be something special or separate.
However, if pollution prevention is defined as those activities that achieve environmental
protection by looking at causes rather than at symptoms and effects, then pollution
prevention is simply a technology, and EPA has a long history of addressing technology
issues.
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Strategies commonly define the problem fairly early in the process. However,
there is an implied problem definition toward the end of this research strategy. Leaving
the definition to the interpretation of the reader is risky, and suggests that the Agency
should be more precise. Hence EPA could define the problem as, "more pollution
prevention technologies, and more information about pollution prevention technologies,
are needed." This definition also suggests a need to address the resistance to change
that may currently be a factor in the slow pace at which industry is adopting pollution
prevention technologies. A more convincing case needs to be made (possibly in
business terms) that a move to pollution prevention is good for business.
Therefore, the strategy may be overemphasizing development of more
technology and supporting tools and underemphasizing the significance of making
pollution prevention a normal part of doing business. If barriers to implementation need
to be overcome, social science research may be helpful in identifying and evaluating
applicable approaches.
3.2.3 Connection to priorities
In the research strategy development process, EPA will want to demonstrate how
the research activities selected relate to the problem definition. A good, transparent
evaluative methodology is likely to yield results that are defensible within the contraints
of the program. To illustrate such an evaluative process, the Subcommittee has
developed an easily understandable summary table. Because differrent organizations
Illustrative Table 1: Relationship of Problem Definition to Project Review Criteria
Activities * *
Linking nsk assessment and pollution
prevention tools
Improving environmental engineering
economics and cost tools
Improving the utility of LCAs
Developing process simulation tools
Developing pollution prevention
progress measurement
methodologies
Developing impact assessment tools
Providing decision support tools for
MSW management
Developing improved selection tools
for surface treatment
"Project review criteria " **
Effectiveness in Leading to Source
Reduction
Indirectly effective by providing persuasion and
setting pnonties
High, once in place and verified.
Low because of limitations of the analysis.
Excellent, especially when fully integrated with
other, more familiar applications.
Marginal; mostly useful to agencies.
Supports persuasion only.
Minimal; heavy recycling focus.
Good, although can also lead to other treatment
reductions.
Implementing
Capacity
Difficult linkage to
make; many
partners required.
Good, on both sides.
Good for NRMRL,
poor for most users.
Good on both sides.
Low; very difficult
proposition.
OK for NRMRL, not
for user
OK
Excellent because of
experience.
Cost
High
Medium
High
High
High
Very high-
Medium
Medium
' Activities for illustrative table were selected from EPA's Strategy, pages 18-21.
** Project Review Criteria were selected from section 3.2.1 of this report.
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may evaluate the same activities somewhat differently, the specific details of the
evaluation are less important than the transparency and documentation.
The above table illustrates how EPA could relate a problem definition to the
"project review critieria." To generate this table, the EEC used:
a) The problem definition suggested in Section 3.2.2, "more pollution
prevention technologies, and more information about pollution prevention
technologies, are needed."
b) The "project review criteria" suggested in Section 3.2.1.
3.2.4 Use of Analytical Techniques and Product Design Tools
The EEC recommends that the Agency increase the use of decision-making tools
in the pollution prevention program. The draft strategy introduces decision-making tools
throughout, but leaves out some important analytical techniques that have gained
widespread usage. Two examples of these tools are Pareto analysis (rank ordering)
and cause-and-effect diagrams (root cause analysis). The use of these tools (including
those listed in the Strategy) is likely to enhance the acceptability of the decisions made.
Such acceptance is generally easier when the evaluation factors and criteria are clear
from the start. As a result, decision-making tools help both the researcher and the user.
Because there is an apparent plateau in the acceptance of pollution prevention
technologies by the regulated community, EPA may need to consider research in
marketing and on the diffusion of technological innovations to improve the transfer of
their information to the "middle innovators" - those companies that lag the early
innovators in the adoption of new technologies because they require more proof that the
change will be favorable to them. EPA may need to identify firms of this type and target
some for technology information and demonstration. Similar firms may then be
convinced to follow. Consideration should be given to the selection of industry
segments and the regional structure of the industry. For this approach to be successful,
EPA must consider altering both the means by which it transmits information and its
content. The focus can no longer be solely on the environmental manager, and the
emphasis cannot be on environmental damages and "pollution prevention". There must
be a decided business tone to the information. A rationale for determining the costs and
benefits of improving the company's operations should be made using activity-based
costing principles. Means for integrating clean technology practices into core business
functions need to be investigated. Advances in social science research areas, such as
organizational behavior and behavioral decision-making should be adapted for in-house
use. Also, knowledge gaps identified should be targeted for research focus.
In addition to analytical tools for decision-making, the Research Strategy should
seek to enhance the use of product design tools. Currently, there is a generation of
product design tools that allow designers to consider environmental externalities and
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various life cycle considerations in materials selection. Another approach within this
context is designed for dis-assembly and recycling.
The EEC recommends that EPA consider P2 technology as "technology that
achieves environmental protection by altering causes rather than managing symptoms".
These technologies may be divided into two subsets as follows:
a) Technology that improves the efficiency and effectiveness of materials use
enough to be considered to be commercially viable due to the potential for
significant cost savings; and
b) New technology that is needed to provide an answer to an unacceptable
release to the environment and that existing technologies provide
insufficient cost savings to make it commercially viable.
In the former case, EPA may work with technology developers as translators
between the regulatory and business worlds and support these technology developers
by providing technology verification. In the latter case, EPA may wish to take a more
active role in the technology development process.
3.2.5 Summary Comments
Some industries and organizations are both pioneers and proud practitioners of
pollution prevention. However, many more industries and organizations would benefit
from learning that pollution prevention makes good business sense. The draft pollution
prevention research strategy does not address this need.
Here is an opportunity for the NRMRL and ORD to design a persuasive
educational program to promote use of pollution prevention. Such an effort may
usefully combine several risk reduction options: pollution prevention technologies,
economic incentives, communication, education, and environmental management
systems. One approach would be to collect and describe successful pollution
prevention case histories illustrating the links between product life cycle assessment
(LCA), full-cost accounting, and specific pollution prevention technologies that reduce
chemical emissions. Such a program could assist companies in analyzing true
environmental cost across the product life cycle, with the result that commitments to
pollution prevention and sustainability might take on greater significance. Examples can
be found in successful sustainability programs in European countries and associated
industries.
3.3 Question 3
Are the four long-term goals consistent with the mission of the research strategy,
and, if thoroughly executed, will they effectively achieve the stated vision? If not,
what improvements or changes are recommended?
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The vision and mission statements for the research strategy clearly articulate and
emphasize sufficiently the appropriate role of the ORD in pollution prevention. The
mission statement is:
To advance scientific research and develop cost-effective tools, methods,
technologies, and approaches which expand the availability and use of
pollution prevention by both the public and private sectors.
The vision statement is:
Scientifically based pollution prevention research and development
products will be used routinely by communities, industries, governments,
and other stakeholders for improved environmental decision making on
high-risk human health and environmental problems and as part of a move
toward sustainable development in the 21st century.
These statements recognize the importance of making pollution prevention
precepts and tools useful to society. They also recognize that research in this field
requires more, than just the development of technologies to achieve progress. The
development of tools and methods, as well as the resolution of relevant social,
economic, and behavioral factors are important components of this process.
The four long-term goals developed for the research strategy are
a) ORD will develop, test, and provide tools and methodologies which
improve individual and organizational decision making related so as
to reduce or eliminate emissions, effluents, and wastes from
products, processes, and activities.
b) ORD will develop and test pollution prevention technologies and
approaches which are applicable across economic sectors, and evaluate
products, technologies and approaches which are targetedd at preventing
high-priority human health and environmental problems in support of the
Agency's regulatory and compliance programs.
c) As part of its Environmental Technology Verification (ETV) Program, ORD
will serve as a catalyzing organization to propel into the marketplace the
most promising commercial-ready pollution prevention products and
technologies from both the public and private sectors.
d) Through its extramural grants program, ORD will sponsor
economic, social, and behavioral research to improve decision
making and foster the adoption of pollution prevention by the public
and private sectors at all levels.
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These four long-term goals are consistent with the mission statement. They
address the successful development and deployment of technologies, products, tools,
and methodologies targeted at high-priority health and environmental problems (Goals
a) and b). Additionally, the goals place the ORD in a key role of supporting verification
that can potentially accelerate the use of pollution prevention products and technologies
(Goal c)). Finally, the need to conduct targeted research on social area to foster more
rapid adoption of pollution prevention is recognized (Goal d)).
Thus, if the long-term goats are thoroughly executed, significant advances toward
the stated vision will occur. This will depend in part, on the activities and products that
ORD targets within multi-year programs with the resources that are limited.
Considering that factors such as commercialization potential, costs, and needs could be
used as criteria for selecting projects, the EEC recommends that ORD prepare a clear,
written statement identifying the nature and types of technology products that the ORD
plans to pursue. This may be a useful guide to ORD with respect to determining which
of the products and activities are better suited to industry considering the Agency's
limited resources.
On the whole, the definition and on-going execution of Goals I and II appear to
be proceeding well. However, the absence of a clear budget statement showing where
money is being spent to-support the strategy hinders the EEC's evaluation of whether
resources are being appropriately applied and/or sought. Similarly, a clear delineation
of how each element of the strategy is addressing the identified needs would be useful
in understanding whether omissions in the strategy exist.
The EEC finds that the projects being undertaken in the pollution prevention field
by the ORD address high-risk issues. Additionally, the projects build upon the core
competencies and experiences of the ORD. With respect to the general objectives, the
EEC finds that there is a desireable overlap between the Environmental Technology
Verification Program (ETV) and the evolving pollution prevention activities of the
Agency. The specifics of the programs may differ, but both address the issue of
technology performance effectiveness. The Committee suggests that as pollution
prevention activities are developed, aspects that lend themselves to coverage within the
ETV program should be identified for possible action.
The EEC's greatest concern is the lack of implementation of Goal d). Activities
undertaken to date are not linked with the overall strategy, and there appears to be no
accountable plan underway to rectify this situation. The field of social and behavioral
research is not one of ORD's historic strengths, and specialized expertise in this area
will be required to appropriately define its dimensions. A number of investigators in
academe are already working on various social science aspects of pollution prevention.
For resource conservation purposes, it may be wise for the Agency to adapt the results
of external investigations (refine and/or improve them if necessary) to its use. For this
strategy to succeed, efforts on Goal d) must be linked with the rest of the strategy. The
EEC suggests that ORD develop in-house expertise on this topic, and in the meantime
14
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seek outside assistance in the social and behavioral areas to define a reasonable and
useful program. Failing that, the EEC concludes that this particular goal is being given
short shrift, in spite of its potential importance.
3.4 Question 4
Are the prioritization criteria listed in Chapter 2.0 of the research strategy
thorough and will they permit rational and reasoned decision making on which
projects should be pursued as part of a more detailed research and development
plan? If not, what needs to be done?
The six prioritization criteria listed in Chapter 2.0 of the research strategy are:
a) Addresses high-risk human health or environmental problems;
b) Responds to needs of stakeholders;
c) Fills important research and development gaps not being addressed by
others;
d) Produces multimedia solutions that have wide applicability;
e) Applies knowledge, experience, and capabilities that reside within the
ORD;
f) Leverages resources with other organizations.
It does appear that some of the criteria are not distinct enough. While this may
not be a problem with respect to general analysis, it will make it difficult to employ
analytical techniques that require mutual exclusivity among evaluation factors for
addressing options within the EPA research strategy. Such analytical techniques
usually require that both the options and criteria be refined to make it more possible to
rate and rank them. The criteria are discussed below.
a) Addresses high-risk human health or environmental problems - This
criterion is proper because it is consistent with EPA's mission, the ORD
strategy, and NRMRL's mission. To be fully defensible, the
implementation of this criterion must be transparent and documented.
b) Responds to needs of stakeholders - This criterion is proper and can be
implemented by identifying and engaging the stakeholder community to
catalogue their needs.
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c) Fills important research and development gaps not being addressed
by others - This criterion is proper because of EPA's mission. Currently,
the strategy does not document the selection of gaps to be filled. To be
fully defensible, the implementation of this criterion must be transparent
and documented. Amongst other things, a survey of the research being
performed by others is needed to identify gaps.
d) Produces multimedia solutions that have wide applicability - The
validity of this criterion is not clear because it is not independent of and
could conflict with the first criterion. Reducing a large risk, even in a single
medium, is more beneficial than reducing a smaller multi-media risk.
While impacting more than one medium is revealing, but not critical; this
criterion should not be used without caution.
e) Applies knowledge, experience, and capabilities that reside within
the ORD - This criterion should not be used because whether or not the
ORD has expertise is a management decision, not a scientific criterion.
f) Leverages resources with other organizations - This criterion should
not be used because it relates to implementation, not to evaluation .
Other criteria that could be applied are:
a) The probability of success, because it is important to maximize risk
reduction;
b) The probability of promoting prevention and reducing the need for
"reactive" research at a later date; and
c) The probability that the problem will get worse if unattended for the
present.
3.5 Question 5
Are the research and development activities and project areas presented under
each of the four long-term goals generally understandable and achievable? If
not, what suggestions do you have for improvements?
The four long-term goals in the Pollution Prevention Research Strategy are:
a)(l) Developing testing tools and methodologies
b)(l) Developing and evaluating technologies and approaches
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c)(lll) Verifying the performance of cleaner products, technologies, and
approaches
*
d)(IV) Conducting research which addresses the economic, social, and
behavioral aspects of pollution prevention
In general, all four long-term goals address relevant areas in which the ORD
could potentially make a significant research contribution in pollution prevention and risk
management. Although each long-term goal is understandable within the general
context of the strategy, it is difficult to assess whether or not the ORD can achieve these
goals. Unfortunately, the resources provided for implementing the planned activities
appear inadequate. Understanding the process and the criteria used by the ORD to
identify the long-term goals would help determine whether or not a) the four long-term
goals are indeed the most important goals for ORD to be pursuing, and b) the ORD has
identified the expertise necessary for achieving each of the long-term goals. In this
context, ORD should review EPA's internal resources for group decision-making
because use of a guided process would improve transparency and documentation.
a) Long-Term Goal I - The draft strategy identified life cycle assessment
(LCA), process simulation and cost/benefit analysis as the primary tools
for improved individual and organizational pollution prevention decision
making. Moreover, the ORD has recognized the need to integrate these
pollution prevention decision-making tools with risk assessment
methodologies to develop decision-making approaches that include
meaningful estimates of the costs and benefits associated with pollution
prevention options.
It is clear from the description of Long-Term Goal I that the ORD has done
a commendable job in identifying the technical needs required for
improving the pollution prevention decision-making tools. However, given
the uncertainty associated with the ORD's capability to identify and
evaluate many of the nontechnical issues impacting pollution prevention
decisions (e.g..social and behavioral factors, training, education),
achieving this goal is unlikely. We recommend that the ORD develop a
rational framework, employing expertise outside of the agency, if
necessary, to define the nontechnical data needs that will allow a more
comprehensive approach to pollution prevention decision tool and
methodology development.
b) Long-Term Goal II - ORD plans to develop and test pollution prevention
technologies across various economic sectors. It is unclear whether or
not this is the most cost-effective approach to develop, test, and
disseminate pollution prevention technologies that can reduce human
health and environmental risks. Major concerns are whether the ORD has
the necessary in-house capabilities or has developed the mechanism to
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but not be limited to, the social, behavioral, and cultural impediments to
pollution prevention. The EEC suggests that the ORD evaluate the
administrative/contractual options to acquire the required expertise in
these nontechnical areas. There is a sense of urgency since acquiring
pertinent proposals in pollution prevention from external organizations will
require development of unambiguous research criteria in the nontechnical
issues impacting pollution prevention.
3.6 Question 6
Are the project areas described under Long-Term Goal II (Technologies and
Approaches) appropriate for the broad scope of the research strategy? If not,
what changes do you recommend?
The EEC finds it difficult to map the objectives described under this goal to
projects. The charge question requests commentary on the appropriateness of projects
currently funded through pollution prevention, but this seems to be more of an
implementation question than a strategic question. For the EEC to properly address the
question, it would need to know the rationale behind the decisions, the allocation of EPA
research dollars, and the process EPA uses to determine when to use the EPA or
contract personnel. Absent that information, the EEC has made some assumptions and
responded as follows.
3.6.1 Assumed Mapping of Projects to Goal II
The EEC's best understanding of mapping projects to this Goal follows:
a) Air Pollution Prevention and Control Division
1) Ambient Air Pollutants; coating and cleaning operations, medium-
and small-sized industries with high-risk problems
2) Global Climate Change; intelligent process controls, TEWI
alternatives
3) Indoor Air Pollutants; products used indoors (consumer products
and building materials)
b) University Grants Program and SBIR Program
1) Fundamental science research
2) Pre-competitive engineering research
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acquire the necessary expertise to define the process and product testing
criteria and how the results of such testing might be evaluated and
prioritized. The EEC recommends that the ORD develop a framework to
identify the technical and nontechnical expertise that are appropriate for
pollution prevention technology development and testing. In addition,
some of the principles associated with pollution prevention also appear in
environmental management systems. The ISO 14000 is one such
example. The Subcommittee recommends that EPA review and, perhaps,
adopt those elements of ISO 14000 (or similar systems) that may enhance
implementation of EPA's program. The brevity of this report precludes an
in depth discussion of all the elements of environmental management
systems.
Based on those results, the EEC suggests that the ORD either re-define
the scope of Long-Term Goal II to include only those pollution prevention
economic sectors in which the ORD has experience or capability, or
develop a mechanism to acquire the needed expertise to address the
pollution prevention needs of a broader array of stakeholders.
c) Long-Term Goal III - The ORD plans to focus on facilitating the transfer of
the most promising pollution prevention products and technologies into the
marketplace. The strategy did not identify the criteria the ORD will use to
define a promising pollution prevention technology or the metrics to be
employed to gauge whether a technology/product is commercially
ready.Moreover, it is unclear how the pollution prevention decision-making
tool development (Long-Term Goal I) will be integrated into the ORD's
decision of what constitutes a commercially ready pollution prevention
alternative.
The EEC recommends that the ORD develop specific criteria to evaluate
the commercial readiness of pollution prevention products. The
mechanism used to develop the criteria should be well documented so
that the criteria can be objectively applied to a wide range of pollution
prevention technologies and products. Finally, the EEC suggests that the
ORD develop a framework to evaluate whether the Environment
Technology Verification Program can serve as a potential marketing tool
for industrial/commercial partners who choose to invest resources in this
program.
d) Long-Term Goal IV - This goal represents perhaps the most difficult
challenge for the ORD with regard to pollution prevention program
implementation. The ORD's internal expertise (engineers and scientists)
may be incapable of formulating the correct questions that must be
addressed regarding the nontechnical issues critical to implementing the
pollution prevention program. These nontechnical issues would include,
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c) Separations Technologies (projects involve sorption and membrane
methods for metals and VOCs)
1) Pervaporation for VOC recovery and predictive software
2) VOC recovery from paint spray booths using Temperature Swing
Adsorption (with SERDP funding)
3) Adsorption for metals recovery
(i) Low cost materials (lignins, derivitized lignins) for lead,
copper, nickel, and other adsorbents for metal finishing
metals
(ii) Electrochemically enhanced adsorption
(iii) Ion exchange membrane development, and hybrid
processes for the removal of lead
d) Green engineering for chemical synthesis oxidation with
photocatalysis
1) Small-scale chemical synthesis; hydrogen from water; amino acids
from methane and ammonia
2) Detoxification of water, air; bacteria destruction
3.6.2 Tables Illustrating a Ranking Process
As an illustration only, a member of the Subcommittee prepared the table
presented in Appendix A, which could be used to rank projects for their applicability to a
goal. The first three columns of the table table summarize the pollution prevention
research activities presented at the meeting. The fourth column is provided for ranking
and a final column for additional comments.
Just to illustrate the difficulty of reproducing the results produced by the Agency,
the EEC conducted a limited re-evaluation and ranking of the projects targeting the
stated goals and objectives finding. The finding that very few of the projects ranked
highly in the Agency's program ranked as high during the evaluation.
Nonetheless, criteria should be better clarified and the language tightened so that
others can completely understand the prioritization decisions made by the Agency
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Also, the distinction between Objectives A and B seemed unclear, and which
projects are applicable to Objective C is vague. In revising the strategy, EPA may wish
to distinguish more clearly between (a) projects and strategies that satisfy long-term
research goals and (b) projects that satisfy short-term program office needs. The
concept of core competencies may be valuable when addressing this issue.
3.7 Question 7
Is the breadth and extent of the Long-Term Goal IV (Social Science) sufficient to
advance economic, social, and behavioral issues that enhance or limit the
acceptance of pollution prevention?
Long-Term Goal IV reads: "Through its extramural grants program, ORD will
sponsor economic, social, and behavioral research to improve decision making and
foster the adoption of pollution prevention by the public and private sectors at all levels."
In both its written documents and in oral discussion, ORD staff have made it
clear that they understand that technology'development (i.e., the primary outcomes of
Long-Term Goals I, II, and III) is not enough to achieve actual implementation of
pollution prevention. Readily available and cost-effective pollution prevention
technology enables implementation of pollution prevention. However, the vast majority
of pollution prevention gain in industry and in society at large does not require improved
technology but the conscious decision on the part of the participants to change their
behavior and engage in certain activities, coupled with the will and resources to follow
through.
With that in mind, it is hard to understand why all of the ORD's efforts oriented
toward fostering pollution prevention implementation are funded through extramural
grants. Extramural grants for basic science may lead to advances in knowledge but
may not be adequate for tackling identified practical problems, especially in a direct
fashion. This is especially true of grants funded in concert with the National Science
Foundation, with its institutional bias against applications research. It is unlikely that
such an approach will accomplish Long-Term Goal IV, and, indeed, ORD staff have
indicated that proposals oriented
To better understand the factors that control pollution prevention decisions, ORD
should develop in-house social science capability, either through professional
development of current staff or through hiring staff that already has the necessary social
science credentials. An effort should also be made to interact with other agencies and
institutions that fund and/or conduct research on issues that relate to pollution
prevention. Having in-house talent will ensure that the critical role that the EPA can
play in pollution prevention implementation is guided by current best understanding of
the factors that affect decision-making behavior.
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Although the Committee recognizes that research advances that push the
frontiers of social science, management, economics, etc., can generate techniques that
may be adapted to use in the long-term, some resources within the modified extramural
grant program should focus on developing an understanding of the social, behavioral,
and economic factors that control pollution prevention decision making. The language
in the requests for proposal should clearly indicate an increase in orientation towards
real-world implementation of pollution prevention strategies. Options include managing
the grants program in-house or working with the NIST. These modifications to the
grants program would better ensure that the funded research evaluates practical
obstacles to pollution prevention implementation.
3.8 Question 8
Overall, does the research strategy support the position stated in the ORD
strategic plan that pollution prevention (along with new technology) is one of six
high-priority research areas that should be pursued? Is it supportive of a risk-
based approach or is a stronger argument needed?
Some of the primary features of the ORD's plan are that it:
a) Is founded in risk assessment principles, focusing its research and
development in the areas of greatest risks to people and the environment;
b) Has strong commitments to using extramural grants and utilization of the
peer-review process; and
c) Is designed to meet today's technical needs while positioning itself to aid
in resolving the environmental problems of tomorrow.
Of the six high-priority research needs present to support the ORD's vision,
mission, and long-term goals, pollution prevention and new technologies for
environmental protection are of paramount importance. In general, the linkages
between the strategy and the challenge of the sixth ORD high-priority research topic on
pollution prevention is clear. Furthermore, the vision statement enhances the
importance of the pollution prevention program, putting it in the context of the larger,
more long-term needs of sustainable development into the 21st century.
The strategy has a strong component consistent with and supportive of the risk-
based approach. Risks to human health and the environment can result when exposure
or stressors reach known toxicological or effects levels. The pollution prevention
program is aimed at technologies and approaches that can prevent and reduce the
formation and release of toxic pollutants that are of high risks to both human health and
the environment. In addition to developing specific exposure reducing technologies
(e.g., separations of metals and organic compounds in process streams, alternatives to
ozone-depleting chemicals, alternatives in the coatings and cleaning industries to
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reduce VOCs and HAPs, chemicals to improve indoor air quality), tools are being
developed in LCA and economic analysis to better evaluate the effectiveness of
technology programs in reducing releases and exposure.
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4 CONCLUSIONS
At the request of the Office of Research and Development (ORD), the
Environmental Engineering Committee (EEC) of the Science Advisory Board (SAB)
conducted a review of the Pollution Prevention Research Strategy. The EEC's Pollution
Prevention Subcommittee prepared this report of the EEC's findings and
recommendations. In brief, the EEC was charged to comment on the strategy's
assessment of the current state-of-the-art and trends; the relationship of the ORD's
Strategic Plan to the strategy, vision, mission, and long-term goals; the scope and
priorities of the program; and the appropriateness of the project areas under the goals.
The EEC also offered some generic advice about research strategy development.
The Office of Research and Development (ORD) requested that the Science
Advisory Board (SAB) review research strategies developed by ORD research
coordination teams in consultation with the reulatory program offices. The
Environmental Engineering Committee (EEC) and a specially established multi-
disciplinary Subcommittee reviewed the Pollution Prevention Research Strategy at a
public meeting held June 30-July 3, 1997 at the National Risk Management Research
Laboratory in Cincinnati, Ohio.
The EEC notes with pleasure ORD's progress in strategic planning. The 1996
ORD document, Strategic Plan for the Office of Research and Development (EPA,
1996), was critical to this transition. The 1997 draft Pollution Prevention Research
Strategy (EPA, 1997a) is one of the first documents the EEC has reviewed that takes
this process further.
The existence of a pollution prevention research strategy is, in itself,
commendable progress. In 1994, the EEC's strategic research planning commentary
(SAB, 1994) recommended development of a vision statement; a definition of a mission;
an assessment of strengths, weaknesses, external opportunities, and threats; and
identification of strategic initiatives and metrics of success. The EEC now recommends
two advancements to the process of research strategy development-the involvement of
external organizations in the process and the transparent documentation of decisions in
the resulting research strategy.
The Subcommittee finds that the vision and mission statements for the research
strategy effectively capture the appropriate role of the ORD in pollution prevention and
also recognize the importance of making pollution prevention precepts and tools useful
to society. The strategic rationale for the ORD's program provides a clear basis for
delineating research priorities. The ORD considered pollution prevention needs in
national and internal strategies and in advice provided by advisory boards (e.g., SAB).
The end result of the research strategy development process appears reasonable. The
long-term goals developed for the research strategy are consistent with the mission
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statement. Thus, if the long-term goals are thoroughly executed, significant advances
toward the stated vision will occur.
Goals I and II address the successful development and deployment of
technologies, products, tools, and methodologies targeted at high-priority health and
environmental problems. Goal III emphasizes ORD's role of supporting verification;
verification can potentially accelerate the use of pollution prevention products and
technologies. Goal IV recognizes that targeted social science research could foster
more rapid adoption of pollution prevention.
Implementation of the strategy is likely to produce results that will improve the
Agency's capacity in pollution prevention and reduce risks to human health and the
environment. Within the universe of research opportunities considered in the strategy,
the programs and projects highlighted are reasonable and largely justifiable. Strategic
planning for pollution prevention, however, is a dynamic process, and the strategy may
need revision as new information becomes available.
The strategy could be strengthened by documenting the decision process as well
as the product of those decisions. The EEC also has some concerns about how the
long-term goals translated into specific projects. Some of the research projects and
products walk a thin line between providing a useful product or service, one that would
not otherwise be available, and infringing on the domain of commercially viable products
and services. This is especially true in the area of software development. Inclusion of a
clear, written disclosure identifying the nature and types of technology products that the
ORD should or should not pursue would be invaluable as a guide.
Based on the Subcommittee's expertise and ORD briefings, the Subcommittee
concludes that the strategy is being successfully implemented. The projects being
undertaken in the pollution prevention field by the ORD address high-risk issues and
also build upon the core competencies and experiences of the ORD. However, there is
a concern that the level of resources provided to ORD seems inadequate for the
diversity and depth of the pollution prevention research activities planned.
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APPENDIX A - RANKED RESEARCH AREAS
Table A: Retrospective Ranking of Research Areas
for Applicability to Goal ll/ Objective A
Research
Activity
Area
Science for
pollution
prevention.
Engineering for
pollution
prevention.
Measurement,
assessment,
and feedback
techniques for
pollution
prevention.
Project Area/
Research Activity
Supporting fundamental
research on science
Developing and testing
improved oxidation
pathways/
photocatalysis- based
oxidation for chemical
synthesis
Supporting pre-
competrtive engineenng
research
Supporting prevention-
related evaluation
research/LCA Systems
Analysis
Developing intelligent
controls for process
operations / fuzzy logic,
etc.
Program Area
Green chemistry
Program /
University Grants
Program
Separation
Technologies
University Grants
Program
Systems Analysis
Branch
Global climate
change
Applicability to
Goal Il/Objective A*
High. Good program to
help meet objectives
Medium-Applications
suggested are small-scale
synthesis of H2 from water,
and detoxification of
bacteria in water Does
this really have broad
enough applicability?
High, but not sure this is
best done exclusively in
University Grants Program.
In-house research could
significantly contribute.
Not obvious how it fits into
this goal. But high
applicability to overall
goals.
Medium Strategic plan
says this is to predict
performance of intelligent
controls in pollution
prevention applications,
thereby preventing
releases and increasing
energy efficiency.
Other Comments
See general comment about
University Grants Program
Not sure that applicability is broad
enough to make this a
pollution prevention technology.
What is the relative priority of this
project?
Be careful not to trade health and
safety for pollution prevention.
What is the relative priority of this
task in relation to other pollution
prevention tasks? How is this sub-
objective different from Objective
B?
Doesn't it belong under Long-Term
Goal III?
Weak relation to pollution
prevention. Stated objective
(developing) is different from
project description (predicting
performance). Is this project
limited to combustion applications?
Objective A = Research, design, and assess environmentally benign industrial
process and manufacturing methods.
A-1
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APPENDIX B - MATERIALS REVIEWED
The following materials were available to the Environmental Engineering
Committee for use in the review of the Pollution Prevention Research Strategy. They
can be found in the FACA file for the June 30-July 3, 1997 Environmental Engineering
Committee meeting.
1. Material for the SAB Conference Call on June 13, 1997
a) Agenda (1 page)
b) Visuals for ORD Strategy Plan (4 pages)
c) Visuals for Pollution Prevention Research Strategy (16 pages)
d) Visuals for Waste Research Strategy (13 pages)
2. Memorandum dated May 30, 1997 from the Assistant Laboratory Director
of the National Risk Management Research Laboratory to Kathleen
Conway
a) Attachment 1, Questions for the SAB on the Pollution Prevention
Research Strategy
b) Attachment 2, Tentative Agenda for the Pollution Prevention
Research Strategy Science Advisory Board Review
c) External Review Draft Pollution Prevention Research Strategy
d) Note to Kathleen Conway from Jon Herrmann
3. 1997 Update to ORD's Strategic Plan
4. Pollution Prevention Research Strategy,
SAB Briefing for the External Review Draft, June 30, 1997
Pollution Prevention Research, Sustainable Technology Division
a) Development and Demonstration of Cost-Effective Decision-
Making Tools
b) Environmental Improvement Toolbox
c) P2P: A Measurement Methodology for Pollution Prevention
Progress
d) A "Mark I" Measurement Methodology for Pollution Prevention
Progress Occurring as a Result of Product Design Decisions
5. P2 Research Strategy Science Advisory Board Review, Preventive
Technologies and Approaches
6. Progress Tools for P2: Separations Technologies Green
Chemistry and Engineering
7. The 1997 Joint STAR Program RFAs
B-1
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8. Pollution Prevention Technologies and Approaches
9. EPA's Environmental Technology Verification Program
10. 1995 U.S. EPA Science to Achieve Results (STAR) Research Grant
Awards by Selected Topics
v
11. EPA Small Business Innovation Research Phase I FY/97 Program
Solicitation No. D700001M1, 1995 ETI-SBIR Phase III
12. Pollution Prevention Status Report, Pollution Prevention Technologies for
Emissions Assessment and Management, April 1997
B-2
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CAGE
CSI
EPA
EEC
ETV
FACA
FUZZY LOGIC
HAPs
LCA
LONG TERM
GOAL I
LONG TERM
GOAL II
LONG TERM
GOAL III
GLOSSARY
Coatings Alternative Guide. This computerized guide was
developed on an EPA contract to provide information on low
emitting alternative coating technology to coatings users and
technical assistance provides. It is available through the EPA
Internet site - http://earth2.epa.gov/search
EPA's Common Sense Initiative. Regularly updated information
on CSI can be obtained through the EPA home page in the
Internet http://www.EPA.gov
U.S. Environmental Protection Agency
Environmental Engineering Committee of the EPA Science
Advisory Board
EPA's Environmental Technology Verification Program
Federal Advisory Committee Act
Fuzzy Logic This mathematical theory was invented in 1964 by
Professor Lotfi Zadeh at DC Berkeley. Conventional logic divides
the world into black and white, yes and no. Fuzzy Logic deals in
shades of gray. The use of Fuzzy Logic helps computers handle
artificial intelligence tasks and complex subjects.
Hazardous Air Pollutants under the Clean Air Act
Life Cyle Assessment
Developing testing tools and methodologies
Developing and evaluating technologies and approaches
Verifying the performance of cleaner products, technologies, and
approaches
G-1
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LONG TERM
GOAL IV
MISSION
NIST
NRMRL
OBJECTIVES
OPPT
ORD
P2
POLLUTION
PREVENTION
Conducting research which addresses the economic, social, and
behavioral aspects of pollution prevention
To advance scientific research and develop cost-effective tools,
methods, technologies, and approaches which expand the
availability and use of pollution prevention by both the public and
private sectors. (ORD May 1997)
National Institute of Standards and Technology (Dept. Of
Commerce)
ORD's National Risk Management Research Laboratory
(as defined in the May 30, 1997 strategy) For Long-Term Goal I,
Objective A is," Develop and test user-friendly tools and
methodologies for improved decision making." For Long-Term
Goal II, Objective A is, "Research, design, and assess novel and
advanced environmentally benign approaches for industrial
processing and manufacturing." Objective B is, "Develop and test
technologies and approaches targeted as specific environmental
problems." Objective C is, "Demonstrate and evaluate pollution
prevention in support of Agency and Program Office priorities."
For Long-Term Goal III, Objective A is, "Build a high-quality and
efficient program to verify the performance characteristics of
pollution prevention products and technologies." For Long-Term
Goal IV, Objective A is, "Develop and integrated social science
and socioeconomic information and research products into
environmental decision making."
Office of Pollution Prevention and Toxics at the EPA
Office of Research and Development at the EPA
Pollution Prevention
"source reduction" (EPA) environmental sustainability including
pollution prevention (National Commission on the Environment)
G-2
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PRIORITY
SETTING
CRITERIA
PROGRAM
OFFICES
SAB
SAGE
SBIR
SERDP
(In the draft strategy)
a)
b)
c)
Addresses high-risk human health or environmental
problems
Responds to needs of stakeholders
STAR
Fills important research and development gaps not being
addressed by others
d) Produces multimedia solutions that have wide applicability
e) Applies knowledge, experience, and capabilities that reside
within the ORD
f) Leverages resources with other organizations. (ORD May
1997)
EPA regulatory offices including: the Office of Air and Radiation,
the Office of Prevention, Pesticides, and Toxic Substances, and
the Office of Solid Waste and Emergency Response, and the
Office of Water.
Science Advisory Board, a FACA Committee at EPA
Solvent Alternatives Guide. This computer search tool helps
solvent users and technical assistance providers find alternatives
to solvents that have regulated emissions. It is available through
the EPA Internet site - http://earth2.epa.gov/search
EPA Small Business Innovation Research Program
Strategic Environmental research and Development Program.
This multi agency program is funded through the Department of
Defense. Besides having the full cooperation of the U.S. EPA
other agencies are also actively involved including: NIST,
Department of Interior, National Institute of Health, U.S. Geological
Survey and NASA.
U.S. EPA Science to Achieve Results (STAR) Research Grant
Program
G-3
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TEWI Total Equivalent Warming Impact
VISION To advance scientific research and develop cost-effective tools,
methods, technologies, and approaches which expand the
availability and use of pollution prevention by both the public and
private sectors. (ORD May 1997)
VOCs Volatile Organic Chemicals
G-4
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REFERENCES
SAB. 1994. Environmental Engineering Committee, Strategic Research Planning
Commentary, Science Advisory Board, USEPA, Washington, DC(EPA-SAB-
EEC-COM-94-004).
SAB. 1996. Research Strategies Advisory Committee, Review of the "Strategic Plan
for the Office of Research and Development, Science Advisory Board, USEPA,
Washington, DC (EPA-SAB-RSAC-LTR-96-004).
EPA. 1996. Strategic Plan for the Office of Research and Development (EPA/600/R-
96/059), USEPA, Office of Research and Development, Washington, DC.
EPA. 1997a. External Review Draft: Pollution Prevention Research Strategy, USEPA,
Office of Research and Development, Washington, DC.
EPA. 1997b. 1997 Update to ORD's Strategic Plan (EPA/600/R-97/015), USEPA,
Office of Research and Development, Washington, DC.
EPA. 1997c. Common Sense Initiative Council, USEPA, Washington, DC. Updated
information can be found through the EPA Home Page (http://www.EPA.gov) or
directly at (http://www.epa.gov/ooaujeag/csi/council/index.htm).
R-1
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Chicago, IL 60604-3590
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