6411
United States
Environmental Protection
Agency
Communications And
Public Affairs
(A-107)
21Z-1021
August 1991
The Next
Environmental Policy:
Preventing Pollution
.S. Environmental Protection Agency
:~':ion 5, Library (P'-i^i)
-• / West Jackson C:: • : i Pth t\*n
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The Next Environmental Policy:
Preventing Pollution
William K. Reilly
William K. Reilly is the Administrator of the United
States Environmental Protection Agency.
"Meet the malady on its way."
Persius, Satires, Book 3
For the United States to make as much environ-
mental progress in the next twenty years as it
has in the last twenty, we need to adopt a bold
new approach to environmental policy—and a strong
new ethic of environmental stewardship. Simply put,
we have to work much harder to prevent pollution
before it occurs; cleaning it up after the fact is no
longer good enough.
Environmental protection has been an American
success story—perhaps the premier public policy suc-
cess of the past two decades. Since the celebration of
the first Earth Day in April, 1970, the United States
has substantially curbed air and water pollution, cle-
aned up much of the accumulated arrears of past gen-
erations, and altered forever the meaning of doing
business in an environmentally conscientious society.
Our environmental commitments of twenty years ago
established precedents now being followed by the rest
of the world.
But the quest for environmental quality has turned
out to be far more complex than we supposed two de-
cades ago. Our discovery of new environmental di-
lemmas has more than kept pace with our ability to
solve old ones. The techniques that we have been us-
ing to protect the environment, as effective as they
have been in the past, now need to be augmented
with innovative new strategies.
The State of the Environment
The closing decade of the 20th century is an appro-
priate time for the United States to reevaluate how
we think about and deal with environmental
problems. Environmental issues have again surged to
the top of the nation's agenda. Business leaders, citi-
zen activists, politicians, and consumers alike have ex-
pressed renewed concern for the quality of life and
the future of the planet. When the Wirthlin Group
asked respondents in a recent poll to name the coun-
try's top concern, the environment was one of the
three issues most often cited. The poll also found that
the proportion of Americans who think of themselves
as environmental activists doubled during the past
decade. More than half of the respondents reported
changing their behavior because of concerns about
the environment. Reflecting this heightened level of
public concern, President Bush and Congress worked
together last year to enact a stringent and far-reach-
ing new Clean Air Act—serving notice that the 1990s
will indeed be the "Decade of the Environment."
At this crucial juncture, the environmental "glass"
can be seen as either half-full or half-empty. Last
year, in its twentieth annual report, the President's
Council on Environmental Quality observed, "After
two decades of unprecedented environmental activ-
ism, some facets of the environment show remarkable
improvement, while the quality of others has deterio-
rated sharply."
The investments that the United States has made in
pollution control since 1970 have paid handsome div-
idends. Over the past two economically robust de-
cades, while the U.S. gross national product grew by
70 percent in real dollars, the nation made significant
and indisputable progress in cleaning up its air and
water. For example, in every major category of air
pollution except nitrogen oxides, total emissions have
either leveled off or declined since 1970. Emissions of
particulates are down 64 percent; sulfur oxides are
down 25 percent; volatile organic compounds are
down 29 percent; carbon monoxide is down 38 per-
cent; and lead is down 96 percent.
And there has been substantial progress on other
fronts as well: Hundreds of primary and secondary
wastewater treatment facilities have been built;
ocean-dumping of wastes has almost been eliminated;
land disposal of untreated hazardous wastes has
largely stopped; thousands of hazardous waste sites
have been identified, and clean-up is well underway
on hundreds of the most degraded sites; and the pro-
duction and most uses of such toxic substances as as-
bestos, DDT, and PCBs have been banned. Taken to-
gether, these and other actions have had a
measurable, positive effect on environmental quality
in this country, and they have set an example for
other nations around the world.
Domestic Affairs
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Consider just one concrete example of the net ben-
efits of environmental protection: The Environmen-
tal Protection Agency (EPA) conducted an extensive
study of benefits and costs during the phase-out, over
an eight-year period, of leaded gasoline. The study
found that the lead ban cost refiners about $3.6 bil-
lion. Yet the quantifiable benefits added up to more
than $50 billion, including nearly $42 billion in medi-
cal costs avoided for both children and adults; $1.6
billion in pollution-related environmental damages
averted; nearly $6 billion in lower vehicle mainte-
nance costs; and more than $1.1 billion in improved
fuel economy. Those figures do not include the non-
quantifiable, really priceless value of saving more
than 5,000 lives and preventing 8,000 heart attacks,
strokes, and cases of high blood pressure in just one
year.
New environmental laws, such as the revised Clean
Air Act, will do even more to reduce pollution-re-
lated disease and damage to buildings, sculptures,
monuments and bridges; to water bodies and recrea-
tion areas; and to wildlife habitats and productive
ecosystems.
Similar gains have been made in curtailing water
pollution. For example, $10 billion spent on munici-
pal sewage treatment programs has succeeded in
drastically reducing the volume of conventional pol-
lutants in the Great Lakes. Nutrients are down, algae
is down, fecal coliform bacteria are down, biological
oxygen demand is down. Lake Erie was once the clas-
sic horror story of the ravages of uncontrolled water
pollution: Commercial fishing was all but decimated
there as recently as twenty years ago. Now Lake Erie
is the largest commercial fishery in the Great Lakes.
But even as this progress has been made, new and
more complex environmental challenges have
emerged. Despite our success in curbing conven-
tional pollution in the Great Lakes, for example, fish
are accumulating toxins that make them inedible.
PCBs and even DDT, which was banned in this coun-
try in 1972, continue to show up in the
lakes—presumably transported by air from applica-
tions in Mexico or Central America, where DDT is
still used. Pesticides, herbicides, and petroleum run
off of farms and city streets into ditches and streams,
eventually making their way into the lakes.
Solid waste, another growing concern, illustrates
the extent to which individual actions can accumulate
to create widespread environmental problems. Ac-
cording to EPA's most recent report on municipal
solid waste, the amount generated in this country in-
creased by 13 million tons between 1986 and 1988.
The United States now generates more than 180 mil-
lion tons of new solid waste annually—an average of
four pounds a day for every American! This is a rec-
ord level of per-capita waste generation for this coun-
try; it is two times the per-capita level of West Ger-
many, three times that of Italy.
Despite two decades of unprecedented environ-
mental investment, the creation of waste continues to
accelerate. Many persistent or emerging environ-
mental problems are caused by diffuse, widely scat-
tered, difficult-to-control sources of pollution. These
sources reflect patterns and practices of resource use
and waste generation that at times seem almost out of
control. They do not lend themselves readily to tradi-
tional government regulation.
Moreover, we are increasingly visited with the ad-
verse effects of environmentally unsound develop-
ment: the devastation of natural habitats, the disrup-
tion of the ability of wildlife to migrate, the rapid
extinction of plant and animal species. Internation-
ally, we must deal with alarming new discoveries of
urgent global environmental problems with localized
impacts. Stratospheric ozone depletion, acid rain, the
destruction of tropical rain forests, climate change,
severe soil erosion— this daunting array of global
challenges threatens to overshadow the environmen-
tal gains already made and to destabilize the very nat-
ural systems that sustain life on this planet.
Why Pollution Prevention?
If we want to continue making progress in environ-
mental protection, we will need to move significantly
beyond the programs already in place and the actions
already taken. In my view, the most important ad-
vance we can make is to shift from an emphasis on
expensive end-of-pipe or top-of-stack pollution con-
trol and cleanup to a dramatically more productive
and less costly focus on preventing pollution in the
first place.
The environmental problems most effectively
brought under control so far have been relatively ob-
vious and straightforward—belching smokestacks,
raw sewage and industrial effluent dumped directly
into rivers and lakes, rusting drums of hazardous
waste carelessly buried in or near human settle-ments.
Our efforts have focused primarily on the correction
of environmental problems—treating pollution, dis-
posing of waste, mitigating the effects of environmen-
tally unsound development. But the environmental
challenges of the next ten years will be increasingly
subtle, complex, and costly to resolve—and they will
be less readily ameliorated with the kinds of correc-
tive measures that have worked well in the past.
There is also a compelling economic rationale for
shifting our emphasis from cleanup to prevention.
Preventing Pollution
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Benjamin Franklin's homily, "an ounce of prevention
is worth a pound of cure," is no less applicable to envi-
ronmental protection than to medicine. Environmen-
tal cleanup is expensive. EPA estimates that the cost
of pollution control, just from commitments already
in place, will grow in constant dollars from more than
$100 billion a year today to about $155 billion in the
year 2000—approximately 2.7 percent of GNP.1 The
most rapid growth in environmental protection costs
over the next decade will be in expenditures for
cleaning up pollution on land—primarily from oper-
ating and hazardous waste sites, both in the private
sector and at federal facilities, and from leaking un-
derground storage tanks. In light of these substantial
and growing costs, it seems only prudent to ask if soci-
ety's resources are being used in ways that will con-
tribute most efficiently over the long haul to the
health and well-being of our citizens and our environ-
ment. And we will be unable to give a positive answer
to that question as long as we continue to spend the
bulk of our environmental resources on cleanup,
while neglecting front-end investments in pollution
prevention and environmental planning.
Cost is only one shortcoming of the conventional
approach to pollution control. An even more funda-
mental problem is the fact that the end-of-pipe focus
is reactive rather than preventive, and thus inher-
ently incapable of correcting the root cause of most
environmental degradation: waste. By concentrating
on treating the symptoms of environmentally damag-
ing human activities, we are in danger of constantly
losing ground in the long-range struggle to protect
and improve environmental quality.
The continuing problem of toxic pollutants in the
Great Lakes is an example of this phenomenon. As I
noted earlier, large investments by the United States
and Canada in municipal wastewater treatment plants
have paid off in substantial reductions in conven-
tional pollutants, such as fecal coliform, nutrients,
and algae. But air deposition of toxic chemicals, as
well as runoff from farms, urban surfaces, industrial
sites, and mining operations, continues to contribute
pollutants to the Great Lakes, which contaminate
bottom sediments—and accumulate in fish and in
such wildlife species as the bald eagle, damaging the
latter's ability to reproduce. The lesson we are learn-
ing is clear: When we focus on treating waste, rather
than on preventing waste, new environmental
problems tend to outstrip whatever progress we can
make.
This is not to say that EPA should or will abdicate
its responsibilities for pollution control and mitiga-
1 These figures represent only the costs of pollution control, without taking into
account any of the very substantial benefits from this investment.
tion. In fact, EPA has redoubled its traditional regu-
latory and enforcement efforts; in the last two years
we have set records in nearly every enforcement cate-
gory. In particular, EPA has dramatically increased
the number of administrative and criminal enforce-
ment actions. Yet while EPA is continuing to improve
and enhance its enforcement programs, we will also
work to develop and apply a variety of creative new
strategies to meet today's complex environmental
challenges.
Decentralized Pollution Problems
Even though EPA has made great strides in eliminat-
ing large, obvious, and acute forms of pollution dur-
ing a time of substantial economic expansion, troub-
ling increments of more insidious and elusive
pollution remain. Furthermore, the world now faces
pollution problems that are different in kind and in
scope. Some of the most intractable of these problems
come from scattered, decentralized sources—pollu-
tion that does not emerge from a smokestack or a
pipe, but results instead from the activities of millions
of citizens going about their daily lives. Emissions
from the tailpipes of cars, the use and release of
ozone-depleting chlorofluorocarbons, agricultural
and urban runoff, indoor air pollution, the use and
disposal of consumer products containing toxic sub-
stances—all are examples of large, decentralized pol-
lution problems generated by millions of small
sources. Reducing these remaining increments of de-
centralized pollution through traditional ex post facto
control and cleanup programs would be extremely
costly, if indeed such programs could even achieve
the desired results.
The distinctive nature of these problems suggests
that they will be solved only by a different array of
approaches than EPA has used in the past. Fortu-
nately, there is a growing consensus that pollution
prevention offers a good framework. Pollution preven-
tion is a decentralized approach to a decentralized
problem.
Accordingly, EPA has embarked on a comprehen-
sive effort to make pollution prevention a top priority
on the nation's environmental agenda. We have es-
tablished a hierarchy of various approaches for deal-
ing with waste. In this hierarchy, the preferred ap-
proach is source reduction—the minimization or
outright elimination of waste generation. A strong
preference for recycling is next in EPA's hierarchy; if
waste cannot be prevented, at least we should recycle
and reclaim as much as possible, thereby conserving
Domestic Affairs
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resources for the future. On the bottom rung of the
hierarchy, to dispose of waste that cannot be pre-
vented or recycled, come safe incineration and
proper landfilling as last resorts.
Pollution Prevention at Work
Many of the initiatives that already have been taken,
and that have produced substantial environmental
benefits, could be classified as examples of pollution
prevention: banning DDT, eliminating lead in gaso-
line, phasing out most uses of asbestos, cutting down
on the range of permissible uses of certain pesticides
and herbicides. But even more impressive reductions
in pollution can be achieved by putting pollution pre-
vention to work in every sector of society.
Within the industrial sector, pollution prevention
means changes in products, materials, practices, and
processes or increased efficiencies in existing
processes. For instance, a new technique developed
by the Department of Defense replaces solvents in
paint removal. The new process, called "plastic me-
dia blasting," uses tiny plastic pellets instead of sol-
vents to strip paint. The Defense Department reports
that this technique cuts the time it takes to strip an F-
4 fighter from 340 to 40 hours while reducing the
amount of waste generated from 10,000 pounds of
hazardous, wet solvent sludge to 320 pounds of dry
paint chips. Emissions of pollutants into the air are
virtually eliminated. As an additional bonus, this
technique sharply cuts the cost of complying with a
myriad of hazardous waste disposal regulations.
Another example—a process change—shows how
simple prevention-based solutions can dramatically
reduce pollution. As reported by INFORM, an envi-
ronmental research organization, Borden Chemical
Company slashed releases of organic chemicals from
its Freemont, California, plant by 93 percent after
conducting a pollution prevention audit. One of the
most significant reductions came when Borden sim-
ply changed rinsing processes in an 11,000-gallon re-
actor vessel. Borden replaced a single rinse, which re-
sulted in a moderately concentrated wastewater, with
a two-stage process. The first rinse uses about one
hundred gallons of water and yields a concentrated
residual, which is reused. The second rinse is ex-
tremely dilute and easily handled by Borden's ex-
isting treatment systems. The total amount of waste
organics released to the environment has been drasti-
cally reduced through this simple process change.
Nor is pollution prevention just for Fortune 500
companies. The managers of a one-hour dry cleaner
in Anchorage, Alaska, cut discharges to zero by
changing filtering practices and recapturing fugitive
air emissions. In each of these examples, companies
actually reduced operating costs. And while that is
not always the case, these success stories underscore
an important point: The basis for pollution preven-
tion is efficiency, both in process and in the use of raw
materials.
In the agricultural sector, pollution prevention en-
tails the adoption of such farm practices as integrated
pest management—which reduces the need for toxic
pesticides by employing natural pest control wher-
ever possible—and soil conservation and planting
techniques that limit reliance on fertilizers and other
agricultural chemicals. The Department of Agricul-
ture recently studied pesticide applications on cotton
in the lower Rio Grande Valley of Texas. Before the
study, pesticides were applied between 15 and 18
times every growing cycle to control boll weevils.
Simply by destroying leftover cotton stalks, which
had been providing a winter home for the pests,
farmers were able to cut pesticide applications to only
four in the following year. In studies in the wheat
belt, researchers found that by monitoring soil nitro-
gen levels and applying nitrogen as needed, instead of
on a predetermined schedule, farmers were able to
reduce nitrogen use by 30 percent. Such practices as
crop rotation and intercropping (mixing different
crops together) are being tested in the Midwest to re-
duce the need for pesticides and to increase yields
without chemical fertilizers.
In energy and transportation, prevention means re-
ducing emissions through improved efficiency and
conservation. Transportation and energy art: respon-
sible for a sizable share of the environmental burden
placed on the planet by human activities. The Na-
tional Acid Precipitation Assessment Program, a dec-
ade-long government study of the causes and effects
of acid rain, estimated that half of the volatile- organic
compounds released by man-made sources come
from transportation.
if the problems are substantial, so are the potential
reductions. Using technology available today, the
United States can drastically improve energy effi-
ciency. Amory Lovins, director of the Rocky Moun-
tain Institute in Snowmass, Colorado, estimates that
the nation could save 44 percent of the energy used to
drive electric motors by switching to high-efficiency
models now on the market and by improving
maintenance.
Another source of significant potential savings is
lighting, which accounts for about one-fifth of the
electricity we use. If Americans were to switch to the
most energy-efficient lighting available today, wher-
ever they could do so profitably, the amount of en-
ergy consumed by lighting would be cut roughly in
half. This would represent a reduction in energy use
Preventing Pollution
-------
of about 250 billion kilowatt-hours a year—about 10
percent of our total annual consumption of electric-
ity. Switching to energy-efficient lighting would save
electricity users more than $16 billion a year. The en-
vironmental benefits would be equally impressive.
Carbon dioxide and nitrogen oxide emissions would
decrease by more than three percent, and sulfur diox-
ide emissions would drop more than six percent.
EPA has developed an energy conservation pro-
gram called Green Lights, in which corporations
have agreed to replace their existing lighting with en-
ergy-efficient lights and lighting designs wherever
they can do so profitably. Charter members of the
Green Lights program include Gillette, Maytag,
Johnson & Johnson, Polaroid, Gerber, Bell Atlantic,
Citicorp/Citibank, Phillips Petroleum, General Dy-
namics, Digital Equipment Corporation, and Brown-
ing-Ferris. More companies are signing on every
week. Green Lights is a "win-win" program in the
classic sense. Companies save electricity, workers get
better lighting, citizens breathe cleaner air, the na-
tion reduces its reliance on foreign oil, and the econ-
omy becomes more competitive. This program is pol-
lution prevention at its best.
And Green Lights is only one manifestation of our
genuine desire to work with industry—to be support-
ive of those firms that display the intention to work
on their own for pollution prevention. Another is a
cooperative EPA-industry effort to secure dramatic
reductions in emissions of toxic pollutants. In the
summer of 1989, I invited the heads of nine well-
known petrochemical manufacturers, whose firms
operated 40 facilities presenting high risks because of
their emissions of toxic air pollutants, to a meeting at
EPA. Everyone in the room knew we could wait for
Congress to enact a stricter Clean Air Act, let a few
years pass as regulations were proposed, debated, and
litigated, and then wait a few more years after that for
emissions reductions to take place.
But we took a different tack: I asked the leaders of
the nine companies to prepare plans to reduce the
risks posed by their plants sooner rather than later. In
response, they developed programs to cut emissions
of their most egregious toxic pollutants by as much as
90 percent. Ultimately, the corporate leaders entered
into written agreements with EPA, and the emissions
already are beginning to drop. By 1993, reductions of
more than 80 percent will be achieved, and more
than nine million pounds a year of toxic releases will
have been eliminated from the environment.
Through these voluntary agreements, with their
ambitious environmental goals, we have achieved sig-
nificant environmental advances quickly, with a mini-
mum of bureaucratic intervention, burden on indus-
try, and taxpayer expense.
Domestic Affairs
Commitments Beyond Compliance
Now, EPA is ready for the next step. In a Pollution
Prevention Strategy announced in February, we
targeted 17 high-priority toxic pollutants for reduc-
tion. These are high-volume industrial chemicals,
some highly toxic, that are associated with a variety of
environmental ills. Benzene, for example, is a known
carcinogen and also contributes to ozone pollution;
lead is a notorious toxin that is a major health risk to
pur children. These pollutants are all controlled by
existing regulations, yet their releases from more
than 10,000 industrial plants still total more than a
billion pounds a year.
I have set goals of reducing aggregate environmen-
tal releases and off-site shipments of these pollutants
one third nationwide by the end of 1992, as measured
against a baseline of emissions reported to EPA in
1988, and at least one half by the end of 1995.1 have
created an Industrial Toxics Project—a team of EPA
specialists who will work with interested companies to
achieve the goals. The project will focus on bringing
about reductions through pollution preven-
tion—actions that eliminate wastes at their sources.
(Companies will, however, be encouraged to partici-
pate even if some part of their reductions are
achieved through more traditional recycling or con-
trol methods.)
In the end, companies need to find the ways to
achieve reductions that work best for them. As the
recent experiences of the companies cited above
show, an ounce of prevention can achieve dramatic
environmental benefits while actually saving money
and improving productive efficiency. I have written
to more than 600 CEOs asking them to begin consid-
ering their responses to the Industrial Toxics Project;
more companies will be contacted in the coming
months. EPA officials are meeting with industry lead-
ers to discuss reduction commitments. In those meet-
ings, EPA representatives emphasize the voluntary
nature of the Industrial Toxics Project, but they also
stress the substantial benefits of pollution preven-
tion—including enhanced community relations, em-
ployee pride and satisfaction, and savings from re-
duced material loss and waste management expenses.
We are emphasizing as well the nation's simple and
profound desire for a cleaner environment.
We are asking companies to consider a range of vol-
untary commitments. Some may pledge to do what
they can and leave the specifics to be worked out be-
tween now and 1995. Others may feel comfortable
embracing more explicit goals—setting timetables
and targeting specific chemkals and facilities for re-
ductions. Still others may elect to expand their com-
mitments, exceeding EPA's goal of a 50 percent re-
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duction by 1995, targeting more than the 17 priority
chemicals, or even carrying out reductions at all facil-
ities here and abroad, regardless of the environmen-
tal frameworks under which they operate. Some com-
panies are, in fact, already way ahead of us. Monsanto,
General Dynamics, Polaroid, and AT&T have all
made public commitments to reduce toxic chemical
releases by more than 50 percent. And, of course,
other firms may well decide, for whatever reasons,
that the Industrial Toxics Project is not for them.
That will be their choice to make—EPA will in no
way penalize companies that choose not to
participate.
Although EPA is taking a strong leadership role in
this effort, we expect that others—state and local
governments, supported by environmental groups
and community organizations— will want to negoti-
ate their own agreements with businesses. We are
preparing to devote technical know-how and person-
nel to assisting in these efforts and to identifying
whether our existing regulatory programs might cre-
ate unintended disincentives to early toxics
reductions.
As the nation's environmental protection efforts
mature, more managers are finding that the elimina-
tion of wastes goes hand in hand with an emphasis on
Total Quality Management—a philosophy of contin-
uous improvement—to make industrial operations
more efficient and more profitable. A commitment
to continuous improvement can succeed in the reduc-
tion of chemical waste just as it has in the pursuit of
quality and customer satisfaction. Some corporate ex-
ecutives have even said that their ultimate pollution
prevention goal is zero discharge of toxics—a notion
that, just a few years ago, would have invited derision
from serious observers of business. In the end, zero
discharges may not be possible—but what an energiz-
ing standard to hold aloft! A very informative article
in the New York Times quoted an executive from a firm
that has pioneered in the field of pollution preven-
tion, 3M, as explaining, "If we get rid of the pollu-
tion, we get out from under the regulations." For
3M, this is one more reason, besides profitability, to
pursue pollution prevention.
For firms that are not so enthusiastic, my proposed
goals will pose a fundamental question: Does it make
sense to wait until the last minute to comply with the
deadlines set by the Clean Air Act and other statutes?
Or can these companies do more, both to improve
the environment and to enhance their corporate bot-
tom line, by taking early actions that reduce contami-
nants at the source—avoiding, perhaps, the need for
expensive end-of-pipe treatment later on? The Clean
Air Act helps to answer this question by providing a
six-year exemption from compliance with maximum
achievable technology standards for those companies
that attain 90 to 95 percent reductions in toxic air
emissions through enforceable agreements before
specified dates. Since all of the contaminants targeted
in EPA's Industrial Toxics Project are also subject to
the new Clean Air Act standards, this incentive will
play an important role in helping to achieve our ob-
jective of 50 percent reductions by 1995. At the same
time, I recognize that not every company has opera-
tions or resources that lend themselves to going be-
yond existing legal requirements. That is why this
new program is strictly a voluntary effort.
We at EPA also have something important to learn
from this venture in obtaining commitments beyond
compliance. The nation's environmental lav/s, and
the great successes achieved over the past twenty
years, have depended on command-and-control ap-
proaches to regulation. It is becoming increasingly
clear that in a number of areas these approaches have
taken us about as far as they efficiently can. Further
reductions in pollution are frequently limited in
scope and very expensive to achieve. But incentives
that work with rather than against the market, and
policies that afford industry greater discretion to
choose the means to achieve ends determined by gov-
ernment, can help us to make further progress in the
most cost-effective fashion. Government, as much as
industry, needs to experiment with new ways of doing
business, even as we continue to enforce the laws vig-
orously and consistently. If our efforts in the Indus-
trial Toxics Project are successful, we will have
powerfully advanced the reconciliation of the na-
tion's environmental goals with its economic aspira-
tions, to the benefit of both.
General George Patton once wrote, "Never tell
people how to do things. Tell them what to do and
they will surprise you with their ingenuity." The Pol-
lution Prevention Strategy takes that advice to heart.
In the future as in the past, EPA will not shy away
from setting societal goals and regulatory standards.
But increasingly, we will defer to businesses regard-
ing choices of means and technologies. These are
business decisions, and as long as they are made with
due regard for the needs and constraints of the envi-
ronment, they should be made by business
executives.
Setting Risk-Based Priorities
Pollution prevention is not the only EPA initiative
that reflects the wisdom of planning for environmen-
tal protection at the front end. Another major thrust
in the Agency's environmental agenda for the 1990s
Preventing Pollution
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is a complementary effort to evaluate the relative
risks of environmental problems, so that we can focus
our efforts—and help to focus those by industry, con-
servation groups, and others—on those activities,
preventive and otherwise, that are likely to do the
most to reduce risks to human health and the
environment.
Recognizing the need for EPA to do a better job of
setting priorities across the range of its programs, my
predecessor, Lee Thomas, instructed EPA's in-house
scientists and environmental managers to rank envi-
ronmental problems on the basis of the risks associ-
ated with them. The result of this exercise was Unfin-
ished Business: a Comparative Assessment of
Environmental Problems, a provocative and pioneering
report published in 1987.
When I took office in 1989 I asked EPA's Science
Advisory Board—an independent panel of outside
scientists, engineers, and other technical experts—to
review the rankings in the Unfinished Business report,
drawing on the best technical and scientific knowl-
edge available. I also asked the group to suggest ways
to improve risk assessment and to identify risk reduc-
tion strategies that could be particularly effective.
The Board's report, Reducing Risk: Setting Priorities
and Strategies for Environmental Protection, was re-
leased in September. It is a thoughtful and significant
contribution to the debate over the future of environ-
mental protection in this country.
The new report builds on the Unfinished Business
project by spelling out a set of fundamental principles
for achieving broader, more integrated, and more
carefully targeted environmental policy-making.
Among its key recommendations:
• "EPA should target its environmental protection
efforts on the basis of opportunities for the great-
est risk reduction."
• "EPA should attach as much importance to reduc-
ing ecological risk as it does to reducing human
health risk."
« "EPA should reflect risk-based priorities in its stra-
tegic planning and budget processes."
• "EPA—and the nation as a whole—should make
greater use of all the tools available to reduce
risk. . .[with] pollution prevention as the pre-
ferred option."
Taken together, these principles provide a basic
framework for addressing some of the most pressing
environmental problems of the 1990s and beyond.
The Science Advisory Board identified four such
problems that, based primarily on the degree of di-
rect public exposure to known toxic agents, continue
to pose relatively high risks to human health despite
the progress of the last two decades:
Domestic Affairs
• ambient air pollution;
• worker exposure to chemicals in industry and
agriculture;
• indoor air pollution, including radon and environ-
mental tobacco smoke; and
• drinking water contamination.
The Board pointed out that additional data, which
EPA is now working to gather and analyze, may re-
veal that other problems, such as pesticide residues in
food and toxic chemicals in consumer products, may
pose human health concerns as well.
The Board also identified four problems that, ow-
ing to their geographic scope and the amount of time
it will take to reverse them, present relatively high
risks to the environment and thus to human welfare:
• habitat alteration and destruction;
• species extinction and loss of genetic diversity;
• stratospheric ozone depletion; and
• global climate change.
Let me be clear: The Science Advisory Board did
not suggest, nor do I, that conventional approaches
to environmental problems not cited as high risks,
such as the cleanup of hazardous wastes, should be
abandoned. EPA is firmly comm'itted to continued
and intensified enforcement of the environmental
laws already on the books, as evidenced by the rec-
ord-setting enforcement actions in 1989 and 1990.
But, guided by the best information we can find on
the relative risks of various environmental problems,
we are thinking carefully about where our limited dis-
cretionary resources can most effectively be spent.
Actually carrying out the Science Advisory Board's
recommendations will not be easy. Any effort to set
environmental priorities based on relative risk—to
rethink the environmental agenda for the 1990s and
the 21st century—will be arduous and contentious.
Just look at what almost invariably happens even
now when EPA announces a regulatory decision.
Some scientists, environmentalists, and citizens who
understand risk point to the uncertainties inherent in
risk-based decision-making and charge that our ap-
proach is not sufficiently protective, or that it under-
estimates the environmental and health problems
that will result from not taking stronger action. At
the same time, others in academia or business or the
agricultural community assert that the assumptions
used in our risk models, which are purposely
designed to err on the side of safety in order to ensure
public health protection, are too protective—that
they undervalue the economic and other benefits of
pesticides and other chemicals.
Reactions are so disparate because decisions about
environmental risks are complex and require a great
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deal of information—about the health and ecological
effects of pollutants, about their presence and persis-
tence in the environment, and about the extent to
which human beings and natural systems are exposed
to them. Given this complexity, government regula-
tors, who must live in the interval between the discov-
ery of a problem and its solution (typically before the
science is adequately established) have to get used to
the fact that disputes and disagreements go with the
territory. But disagreements can co-exist with trust.
To build and maintain the public's trust in EPA, we
need to improve the public's understanding of how
we make regulatory decisions. While we must and will
listen carefully and respond to the public's concerns,
we have to make it clear that we also must and will
continue to rely on a rational, science-centered pro-
cess to guide risk-management decisions. And we
need to assure the public that decisions will be based
on the best available science and that when we do not
have all the data that we would like to have, we will
take a cautious, protective approach unless and until
new information supports a finding of lesser risk.
The public should also know that we are constantly
updating our risk assessment guidelines as scientific
knowledge advances. We are insisting that these as-
sessments be subjected to rigorous internal and exter-
nal peer review. And we are looking for ways to
achieve greater consistency in our use of risk assess-
ments across the range of EPA decision-making.
The threats to the environment are sufficiently se-
rious—and time is growing sufficiently short—that
we cannot afford to go without a long-range plan for
environmental protection. The nation needs a better
understanding of the sources of environmental risk;
it needs the best available scientific evidence of which
health and environmental risks may be most signifi-
cant; and it needs a comprehensive strategy to reduce
those risks, both with traditional regulation and en-
forcement and with non-traditional tools—public in-
formation and education, aggressive research and
technology development, international cooperation,
and economic incentives that enlist the power of the
marketplace on behalf of environmental protection.
The new Clean Air Act is a giant advance in the
grounding of environmental protection in economic
incentives. The centerpiece of the legislation is an in-
novative system of tradeable emissions allowances for
sulfur dioxide that will enable the nation to achieve
significant improvements in air quality at compliance
costs some $ 1 billion lower than would otherwise be
incurred. The Act also introduces a range of other
market-based mechanisms, including incentives,
noted above, for companies to act quickly to reduce
toxic emissions and to go beyond minimum require-
ments; commercially tradeable credits for producers
of certain kinds of reformulated fuels, for manufac-
turers of clean-fuel vehicles, and for vehicle fleets
subject to clean-fuel requirements; and performance
targets for reformulated fuels that allow industry to
reduce emissions in the most cost-effective possible
way.
EPA's "Quiet Revolution"
Far from being the inflexible bureaucracy depicted
by some of its critics, EPA is now undergoing a funda-
mental cultural change—what Science magazine
called a "quiet revolution"—in which pollution pre-
vention and risk reduction are being woven into the
fabric of virtually every regulatory decision and pol-
icy directive. Front-end environmentalism increasingly
is becoming the guiding principle underlying all of
EPA's activities.
More than 200 years ago, Thomas Jefferson made
an observation that is relevant to the challenge of
refocusing environmental priorities today. In a letter
to a friend, Jefferson wrote that while he was not an
advocate for frequent changes in laws and institu-
tions, he nonetheless believed that institutions should
make progress hand-in-hand with the progress of the
human mind:
With the change of circumstances, institutions
must also advance to keep pace with the times. We
might as well require a man to wear still the coat
which fitted him as a boy, as civilized society to re-
main ever under the regimen of their barbarous
ancestors.
EPA's challenge—the nation's challenge—for the
1990s is to confront and breach the institutional bar-
riers that previously have impeded the development
of pollution-prevention and risk-reduction strategies.
Internally, the most difficult barrier is EPA's histori-
cally compartmentalized organization. Reflecting the
structure of the laws it must implement, EPA is set up
to deal with pollution of the air, water, and land as if
these were separate and distinct entities, rather than
parts of an integrated, interrelated whole. We are
working to overcome these organizational obstacles
through education and training, through enhanced
accountability and coordination within EPA, and
through Total Quality Management.
Equally important, we need to break down the
traditional special-interest barriers that have balkan-
ized government and society as a whole. As the Reduc-
ing Risk report noted, solving the nation's continuing
environmental problems is not something EPA can
do by itself; all parts of government and all sectors of
society must participate. The quality of the environ-
Preventing Pollution
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ment is directly affected by energy extraction and
use, by agriculture, by transportation, by our rela-
tions with other nations, by our trade policies and tax
policies. Across all of its activities, government must
pay much more attention to environmental consider-
ations at the outset of policy-making.
This is not to suggest that EPA should be getting
into every other agency's business. Rather, I am sug-
gesting that all the other agencies start getting into
our business—the business of protecting the
environment.
And just as EPA cannot do it all, neither can gov-
ernment. Effective national responses to many of our
environmental problems will be mounted only
through countless individual acts of stewardship; only
through the constant adaptations of millions of local
neighborhood and community programs and
thousands of companies to new information; and in
the end, only through the inspired leadership and
continuous learning of every individual citizen. Ulti-
mately, every American must feel empowered to act on
behalf of the environment.
Front-end environmentalism is essential to ensure
continued progress in environmental protection. Our
ultimate goals are the reduction of environmental
risks to human health and to the integrit) of natural
systems—and the reduction (and wherever possible,
elimination) of waste. Changing the nation's way of
thinking, and ultimately the way we live, will take
time and effort, but it can—and must—be done.
In meeting the environmental challenges of the
1990s, the most significant new progress we need is
with ourselves—with our lifestyles, our energy use,
the goods we buy and use, and the waste we generate.
The extent to which we are able as a society to recon-
cile human activities, especially our economic activi-
ties, with the needs and constraints of nature will de-
termine just how habitable and productive our
nation—and indeed this earth that sustains us
ail—vvill remain, for this generation and the genera-
tions to come.
For Further Information
Office Of Communications And Public Affairs (A-107)
United States Environmental Protection Agency
Washington DC 20460
(202) 260-4454
Domestic Affairs
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