EPA 560/4-76-009
VOLUNTARY ENVIRONMENTAL ACTIVITIES OF LARGE
CHEMICAL COMPANIES TO ASSESS AND CONTROL
INDUSTRIAL CHEMICALS
September 1976
OFFICE OF TOXIC SUBSTANCES
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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This document is available to the public through the National
Technical Information Service, Springfield, Virginia 22151
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EPA 560/4-76-009
VOLUNTARY ENVIRONMENTAL ACTIVITIES OF LARGE
CHEMICAL COMPANIES TO ASSESS AND CONTROL
INDUSTRIAL CHEMICALS
Prepared by the
OFFICE OF TOXIC SUBSTANCES
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEPTEMBER 1976
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PREFACE
This Report is intended to help clarify the extent and
character of the activities of companies in the United
States with sales of industrial chemicals exceeding $300
million annually to assess and, as necessary, control
these chemicals beyond the environmental requirements set
forth by Federal, State, and local authorities. The
Report should help establish a baseline of such activities
as of early 1976. The impact of Governmental efforts to
stimulate additional activities in the future can then be
judged against this baseline.
The conclusions set forth in this Report are based
on information and impressions obtained during discussions
with spokesmen for a number of trade organizations, pro-
fessional associations, and related groups, and with
officials of a number of individual companies which are
reasonably representative of the industry. These dis-
cussions were supplemented by visits to numerous industrial
R&D, health and safety, and manufacturing facilities
throughout the country during the past three years. Com-
ments on the conclusions of the Report, as well as other
pertinent information, would be welcomed by the Office of
Toxic Substances.
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TABLE OF CONTENTS
Preface
BACKGROUND
THE ROLE OF THE BOARD OF DIRECTORS
CORPORATE STRUCTURE AND ENVIRONMENTAL
DECISION-MAKING
CAPABILITIES OF HEALTH AND ENVIRONMENTAL
STAFFS
ASSESSMENT AND CONTROL OF PROBLEMS ASSOCIATED
WITH EXISTING CHEMICALS
ENVIRONMENTAL "OUTREACH" ACTIVITIES
THE ROLE OF TRADE ASSOCIATIONS
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Background
Each large chemical company has a unique profile in
its organizational and management approach, its technical
and marketing activities, and its operating philosophy
and style. Each of these companies buys, produces, and
sells hundreds or thousands of chemicals, including some
chemicals which could be environmental hazards, and many
more mixtures and formulations of these chemicals. Each
company has its own historical precedents, its own financial
structure, and its own set of experiences and biases con-
cerning Governmental intervention in the private sector.
Against this background of diversity within the in-
dustry, a few generalizations have been drawn. Obviously,
there will be exceptions to almost every conclusion, but
nevertheless a number of common threads concerning cor-
porate behavior with regard to environmental and health
concerns seem to emerge. Since this study was conducted
over a three-year period, a few of the observations may
be a little out of date, but the general thrusts of the
conclusions appear to persist in 1976.
Clearly, most corporate activities directed to health
and environmental concerns that have been put in place in
recent years have been driven to a great extent by Federal
and State requirements for abatement of air and water
pollution, Federal requirements governing registration
of pesticides, drugs, and food additives, and the re-
gulations concerning shipment and in-transit storage of
the Department of Transportation. Most recently, actions
by the Occupational Safety and Health Administration and,
to a lesser extent, the Consumer Product Safety Commission
have influenced the scope and character of company activities.
While this Report is directed to environmental stewardship
activities concerning industrial chemicals beyond those
activities required by law, industrial programs resulting
from such legal requirements have been instrumental in
shaping the character of additional voluntary actions.
The reasons behind voluntary actions by companies
beyond those required by law are manyfold. For example,
product liability and union pressures concerning worker
safety are of concern to all companies. The reputation
of the company and the public relations value of environ-
mental stewardship programs are often significant factors.
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The personal environmental concerns of individual executives
in top management positions and the pressures within the
company exerted by the scientific staffs for greater
environmental efforts are often decisive. Finally, the
pressures of the Governmental rese~rch agencies such as
the National Cancer Institute, the National Institute of
Occupational Safety and Health, and the National Institute
of Environmental Health Sciences, as well as the latent
threat of future Governmental regulatory intervention
at the national or local levels, often direct company
attention to specific products and problems.
This Report does not attempt to sort out these and
other reasons for environmental stewardship efforts.
Rather, it describes environmental stewardship activities
in very general terms to help provide a framework for
accelerated efforts in this important area in the future.
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The Role of the Board of Directors
Only very rarely is an environmentalist appointed to
the Board of Directors of a chemical company, and seldom
does the Board draw upon environmental expertise beyond the
operating staff of the company. Thus, the Board is not in a
position to make technically credible and independent assessments
of the soundness of the environmental considerations incorporated
into recommendations that it receives.
Almost all, if not all, Boards of Directors have adopted
a broad environmental policy framework intended to guide
company activities. In some instances, such policies are
strikingly limited to simply calling for strick compliance
with environmental and health regulations promulgated by
Governmental authorities. In other cases, the policies are
more broadly directed to protecting health and the environment
and, by implication, they call for environmental assessments
and environmental restraint beyond legal requirements. The
character of Board-adopted policies ranges from relatively
short and general exhortations about the importance of
environmental considerations, to more explicit and detailed
procedural guidance to operating staffs, to explicit endorsement
of rather extensive films and other communications that are
disseminated widely throughout the company.
However, seldom does the Board follow up with a systemmatic
examination of the actual impact of its adoption of an
environmental policy framework on the improved environmental
acceptability of company operations. Nor does the Board
carry out a hard-headed evaluation of the effectiveness of
organizational, administrative, and operational adjustments
that may flow from the policy. Thus, it is generally very
difficult to discern the impact of Board involvement in
establishing general environmental policies -- in contrast
to or in addition to the impact of Governmental regulations --
on the way business is conducted at the working level.
All Boards have become very aware of the need to take
into account environmental considerations when making major
investment decisions. They are particularly sensitive to
the likelihood of stricter pollution and worker exposure
regulations and are increasingly concerned over the possibility
of Governmental action against carcinogens and other toxic
chemicals. In general, in making investment decisions, the
Boards seem far more concerned in understanding what the
Government may require than delving into the details of the
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health and environmental risks associated with the proposed
activities which might warrant steps in addition to Govern-
mental requirements.
Environmental concerns, and particularly those triggered
by Governmental actions, are frequent agenda items for the
Boards. Company organization, environmental expenditures,
Governmental regulations, and actions on specific products
of questionable environmental acceptability are often
discussed. However, the more general topic of environmental
stewardship -- beyond what is required by law -- is seldom
probed in depth.
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Corporate Structure and Environmental Decision-Making
The operating divisions and the plant managers within
these divisions remain the profit-making focus, and hence the
organizational backbone, of most companies. They largely
determine whether environmental stewardship directed to
existing chemicals and existing facilities is simply a
slogan or is a reality. Specialized corporate staffs have yet
to make major in-roads in influencing the environmental
behavior of the line managers beyond fulfilling legal requirements,
and promotion incentives for the line managers continue to
pivot on maintaining high levels of production at minimum
cost. Occasionally, environmental and health staffs within
the divisions or subordinate to the plant manager, drawing
on but seldom responding to the expertise of centralized
corporate staffs, have significantly influenced day-to-day
operational activities of environmental stewardship significance.
Most large companies now have central staffs concerned
with medical affairs (principally but not exclusively physical
examinations and plant accidents), toxicology (assessments
of the health effects of selected chemicals), and air and
water pollution. Occasionally, staffs for ecological studies
of industrial chemicals (usually aquatic studies) have been
established as an off-shoot of ecological studies directed
to pesticides. In almost every company mechanisms are now in
place to help insure that these central staffs have the
opportunity to comment on any significant new facility
investment and new product line. Usually, one of the members
of the company's top management team has line responsibility
for the activities of these staffs. Occasionally, there is a
division of responsibility at the top level between medical
and health concerns, on the one hand, and pollution and ecological
concerns. In some companies, 'however, lack of adequate
staff resources seriously impedes the ability of these
central staffs to participate adequately in the decision-
making process.
Company management, and particularly the line managers
in the operating divisions, is seldom anxious to question
the environmental acceptability of important items in the
company's product line. However, central staffs, prodded by
such actions as the NIOSH List of Suspected Carcinogens,
have begun to take the initiative to question the hazards
associated with existing chemicals. In general, these
staffs have yet to demonstrate that they will be a significant
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force in the decision process when a chemical important to
the company's profit is at stake. Also, a variety of decisions
taken by the operating divisions may not come to the attention
of the central staff.
While the organizational positioning of R&D activities
varies among companies, this organizational entity exerts
considerable influence on company decisions, often as a
parent or as an ally of the toxicology staff. Clearly, with
regard to new chemicals, the views of the R&D unit are
usually decisive. With regard to existing chemicals, the
views will at least be heard since there is almost always
R&D representation at the highest levels of the company.
The company's staff for Governmental affairs, which is
almost always closely tied to the legal staff, usually
participates in environmental decision-making. 'However,
this staff is more concerned with development of regulations
and with compliance than with stewardship activities.
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Capabilities of Health and Environmental Staffs
As would be expected, those relatively few companies
with in-house animal toxicological facilities devoted to
industrial chemicals have potentially strong capabilities to
identify chemical problems and to characterize chemicals
suspected to be hazardous. However, even these companies
have relatively little experience in prioritizing existing
chemicals for in-depth evaluations, reviewing and evaluating
available sources of information on the selected chemicals,
identifying the full range of possible environmental impacts
from acquisition of raw materials and manufacture through
disposal, and developing appropriate control strategies.
Other companies which have in-house toxicological facilities
devoted to drugs and pesticides presumably could build on
this core of expertise in developing assessment capabilities
directed to industrial chemicals. Those companies which
have relied principally On contract research in the toxicology
area are usually very limited in the quantity and qualifi
cations of available personnel to work in this area.
In the medical area, the major concern of chemical
companies has traditionally been directed to physical examinations
of workers and to health care following plant accidents,
with the doctors and nurses headquartered at production
sites. Many of the doctors are part-time company employees
with private practices in near-by communities. Indeed, a
few companies still do not have qualified medical directors
at the corporate level for insuring high quality medical
standards and for providing advice to top management.
During the past several years, the increased importance of
epidemiological investigations to help correlate chemical
exposures and long-term effects has emerged as a priority
concern, but few, if any, companies are adequately staffed
or have their record systems in suitable condition to make
major inroads in this area. Even the limited studies to
date have been seriously hampered by lack of capabilities to
develop adequate study designs.
Every major chemical company has a formidable array of
environmental engineers committed to (a) retrofitting existing
facilities to meet pollution abatement requirements, and (b)
designing new facilities that incorporate the most cost/effective
pollution control equipment, usually in anticipation of
future requirements. At the same time, these companies are
not strong in monitoring capabilities and have little experience
in developing and using techniques for measuring low levels
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of many toxic chemicals, and particularly organic compounds.
However, these companies have an array of good analytical
chemists and access to the latest scientific equipment;
thus. it should be relatively easy to mobilize the necessary
resources to make major strides in this area. The past
approaches of the industrial hygienists in gross monitoring
to determine compliance with OSHA standards and the techni-
ques for measuring gross pollution parameters in air and
water are clearly not adequate to determine trace level
concentrations of many worrisome chemicals in discharge
streams or as product contaminants.
Two neglected areas within the staff capabilities of
most companies are (a) ecological effects, and (b) environmental
transport and fate. Thus, these staffs have relatively
little capability to develop and use laboratory and field
testing methods that will clarify the movement and behavior
of industrial chemicals in the environment, including persistence,
bioaccumulation, degradation products, and eventual environmental
sinks. With a few exceptions, the total capability in these
areas is currently committed to pesticide problems.
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Assessment and Control of Problems Associated with Existing
Chemicals
The approaches of large chemical companies to chemical
assessment and control can be addressed in three rough
groupings of chemicals: (1) chemicals clearly identifiea by
the Government as problems, with the likelihood of near-term
regulatory actions of major import to curb the problems; (2)
chemicals clearly identified by the Government as possible
major problems, but with a questionable likelihood of near-
term actions to sharply curtail activities associated with
the chemicals, and (3) other chemicals. In the first category,
for example, have been vinyl chloride, polychlorinated biphenyls,
and the 14 carcinogens now regulated by OSHA, and in the
second category benzene and chlorofluorocarbons. When con-
fronted with a problem in the first category, the companies
usually take a number of steps to limit environmental ex-
posure, even before regulations are in place. With regard
to the second category, the companies almost always empha-
size the need for and frequently support additional research
rather than adopting any precautionary control measures.
The third category, which includes the vast majority of
commercial chemicals, is the principal focus of this Report.
Only recently have a number of the companies begun to
identify within a central staff all chemicals which the
company handles and to review the potential hazards associated
with each. Typically, the procedures that are evolving are
along the following lines. A master list of all chemicals
that are purchased, manufactured, and sold is prepared.
Governmental lists of potentially harmful chemicals are
correlated with the company's list and the overlap noted.
Company specialists review the company list, and taking into
account the overlaps, make subjective judgements based on
individual backgrounds and experience as to which chemicals
deserve priority attention. These priority chemicals, which
usually represent a small fraction of the total company
list, are then subjected to detailed literature searches.
Should the results of the literature search raise questions
concerning the chemical's environmental acceptability,
toxicity testing might be initiated, or as is more often
the case, warnings might be issued to employees and customers
concerning the potential hazard.
Related to this chemical audit procedure are two other
activities common to many companies. namely, preparation of
a safety data sheet for each chemical that is manufactured
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and preparation of a label for each chemical that is shipped.
Safety data sheets, which.are intended for use within the
company and also by customers, vary widely from simple
recitations of data found in chemistry textbooks to information
generated through original company research efforts. Similarly,
labelling activities vary widely from simply fulfilling
Department of Transportation labelling requirements to
providing detailed instructions on handling, use, and hazards.
Seldom do the labels address disposal procedures. Some
companies have established internal labelling committees
which have the power not only to design each label but to
prevent shipment of the chemical if the hazard is considered
uncontrollable. Other companies are far less organized and
the environmental staffs. and indeed top company officials,
have difficulty being alert to all of the chemicals which
are shipped out the gates of different plants and the labels,
if any, that are displayed on these chemicals.
Only a few industrial chemicals that are already in
commerce are currently being subjected to long-term toxicological
testing by individual companies. Some of the company efforts
in this regard are channeled through trade associations and
related groups as. described below. Since the protocols used
in company testing programs are often developed without
outside consultation, there would undoubtedly be significant
differences of opinion concerning the adequacy of the designs
of some of the experiments. In general the tests conducted
in-house seem to be reasonably well carried out by qualified
personnel. Recent findings of the Senate, FDA, and EPA
have raised questions concerning the quality of contract
testing activities. Several companies have developed cap-
abilities to conduct the "Ames" test and are subjecting both
existing and new chemicals to this screening technique.
Serious testing of existing industrial chemicals for
environmental fate and effects is the exception rather than
the rule within industry. In a few cases, increasing attention
is being directed to aquatic toxicity although lack of sound
test procedures and qualified personnel is a handicap.
Few managers of chemical manufacturing facilities know
the total chemical cross-section of the airborne and waterborne
discharges leaving plant property. Furthermore, no facility
routinely monitors the ambient pollution levels in the
biota, soil, and sediments surrounding plant property to
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ascertain whether there is a build-up of either the chemicals
being discharged or their degradation products. Several
companies have occasionally taken environmental samples at
the fenceline and at the end of the pipe and subjected them
to total chemical analyses, but these activities are usually
undertaken from the point of view of research rather than
possible control steps.
While there has been considerable discussion within
companies concerning the need for scientific study of worker
populations to correlate chemical exposures with suspected
health effects, investigations funded by industry in the
epidemiological area have been very limited. Apparently,
industry has never supported serious epidemiological investigations
of populations living near industrial complexes which might
be exposed to chemical discharges.
Most manufacturing plants turn their solid waste, .
including hazardous waste, over to private contractors for
disposal. Seldom, if ever, is there a rigorous follow-up
effort by the company to insure proper disposal.oy the
contractor, and company contracts with the vendor do not
usually emphasize this aspect.
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Assessment of Problems Associated with New Chemicals and
Chemical Processes
During the past several years, and partly as a result
of the proposed Toxic Substances Control Act, the large
chemical companies have adopted more systemmatic and thorough
procedures for assessing the environmental acceptability of
new industrial chemicals under development. These procedures
are frequently patterned after the experience that has been
gained in evaluating a new drug or pesticide, with the
extent of the investigations expanding as the likelihood of
commercial acceptability increases. However, as would be
expected, the test program for an industrial chemical would
probably not be as intensive as the program required by the
Government for a drug or pesticide.
Generally, the companies with in-house testing capabilities
are able to carry out the most effective premarket screening
programs, using the scientific staffs in an advisory as well
as in a testing role. Also, they are able to introduce mid-
course correction~ in testing programs, to follow-up unusual
findings very quickly, and to maintain a high degree of
quality control. All of these areas present difficult
problems when operating test programs under contract arrangements.
Since almost all premarket screening and decision-
making is conducted without external consultation, there are
inevitably questions as to the adequacy of the tests that
are performed and the appropriateness of the weight given to
environmental considerations in the decision process. In a
few cases companies have announced publicly their plans to
develop major new chemicals and have actively sought inputs
from regulatory agencies in designing their test programs.
In general, these companies seem to be receptive to modifying
their plans to accommodate at least some of the inputs.
As concern over toxic chemicals grows within Government
and among the public, there seems to be a concomitant
tendency within industry to minimize the development and use
of chemicals of questionable safety while seeking wider
applications of the less hazardous chemicals.
A neglected area is the evaluation of the likely environmental
impact of changes in formulations and mixtures. Given the
large number of chemicals and products involved, greater
attention to methods for assessing such impacts would seem in
order.
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Environmental "Outreach" Activities
The record of the large chemical companies in making
available to the Government, other companies, and the public
adverse information concerning chemical hazards is mixed.
Recently, there have been a number of highly publicized
cases of industry releasing information concerning the
impact of chemicals on worker's health. In several cases
the companies that reported the data had previously abandoned
the product in question. There are also instances of adverse
toxicological data not being released.
Some companies encourage publication of toxicological
and related data developed by company scientists, while
others consider that the effort required to transform data
points into an acceptable scientific paper is not warranted.
Similarly, some companies send representatives to make major
contributions to national meetings on environmental health,
while others send representatives simply to listen.
In general, there is reasonably good sharing of industrial
experiences as to methodologies and general approaches to
chemical assessment and control but little sharing with
regard to experiences with specific chemicals. In part this
reticence may be attributed to trade secret problems and,
possibly, anti-trust concerns.
The large chemical companies have shown little concern
over the environmental behavior of their suppliers and
customers, and particularly very small companies. Seldom
are small suppliers asked to provide effects data on their
chemicals, even if the chemicals are being manufactured in
commercial quantities for the first time in response to
batch orders from large companies. Seldom, if ever, do the
large companies question the environmental soundness of the
housekeeping practices of small suppliers. Similarly,
relatively little effort is devoted by the major companies
to helping upgrade the environmental and health capabilities
of small customers. While there are specialized technical
services units in every large company, their charters and
their capabilities apparently do not extend to upgrading the
environmental capabilities of the customers who cannot
afford the types of expertise available to the large companies.
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The Role of Trade Associations
As indicated in Appendix A, a number of trade associations
are actively involved in the identification and characteri-
zation of chemical problems. They vary widely in membership,
staff capabilities, availability of resources, and policy
and program interests. They have many overlapping intetests.
and it is not uncommon for several organizations to be
addressing the same problem. As would be expected, their
activities directed to specific chemicals almost always in-
volve chemicals manufactured by at least several companies.
Information developed by these organizations is generally
available to the Government and to .the public, and they
are invariably interested in contributing their expertise
and viewpoints to the efforts of regulatory agencies.
A number of animal toxicological test programs are
being supported by trade associations. Occasionally,
epidemiological studies are also supported. Almost all
of the industrial chemicals being tested have been identified
by Governmental agencies as possible problems. While the
testing protocols are usually designed by recognized taxi
cological experts, the trade associations have not been
particularly eager to seek out the formal views of regulatory
agencies and to incorporate them into the protocols.
In addition to animal testing and epidemiological work,
the trade associations have also supported aquatic studies
and atmospheric investigations related to specific chemicals
of concern. In these areas, they have frequently called
upon academic scientists to carry out the studies, usually
under the guidance of an industry steering committee.
The trade associations provide many forums for the
airing by Governmental and industry representatives of
general and specific chemical concerns. They are usually
willing to respond to Governmental requests, even on very
short notice. to assemble the leading industrial specialists
to address particular problems. They usually provide
written responses promptly and in detail to Governmental
inquiries although they are seldom, if ever, willing to
take the initiative in identifying future chemical problems.
The recently established Chemical Industry Institute
of Toxicology CCIIT) plans to support toxicological investi-
gations of selected high volume industrial chemicals. Un-
fortunately, the decision processes in selecting chemicals
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to be tested and in designing the test protocols do not
provide for effective Governmental inputs, with the possibility
that the data resulting from the tests may not satisfy future
regulatory requirements. While the establishment of errT
and the expansion of individual company testing programs
are beginning to fill a void in the assessment of industrial
chemicals, the industrial resources being directed to this
area are still very small in relation to the magnitude of
the task ahead and industry profit levels in recent years.
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_.=>.oo----_~.-----"r_-"""-~ -
TECHNICAL REPORT DATA
(Please read ftls.1rUetions on the reJlerse before completing)
1 REPORT NO. 12. 3. RECIPIENT'S ACCESSION-NO.
EPA 560/4-76-009
4. TITLE AND SUBTITLE 5. REPORT DATE
Voluntary Environmental Activities of Large September 1976
Chemical Companies to Assess and Control 6. PERFORMING ORGANIZATION CODE
Industrial Chemicals
7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT NO.
Office of Toxic Substances
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency
Office of Toxic Substances 11. CONTRACT /G RANT NO.
401 "M" Street, SW
Washington, DC 20460
12. SPONSORING AGE~
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