x>EPA
           United StaU.'S
           Environmental Piotection
           Agency
            Office of
            fox ( Substances
            Was-vn-jton DC 20460
July 1980
           Toxic Substances
State Administrative
Models for Toxic
Substances Management

Toxics Integration
Policy Series

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Toxics Integration Policy Series                  EPA 560/13-80-018
                 State Administrative Models for



                   Toxic Substances  Management
                          Written by



                         Barbara Faust



                            -! and



                         Murray Newton



                    Edited by Helen Ketcham








                   Toxics Integration Staff



                           July 1980

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Publications in Toxics Integration Information Series:

EPA Chemical Activities Status Report—First Edition—EPA 560/13-79-003

Directory of Federal Coordinative Groups for Toxic Substances - First Ed.
     (June 1979), Second Ed.  (March 1980)

Federal Activities in Toxic Substances — EPA 560/13-80-008
     (June 1980)

perspectives on the Top 50 Production Volume Chemicals — EPA 560/13-80-8OQ
     (June 1980)
          For  further information or to order copies contact;
          Industry Assistance Office  (TS-799)
          U.S. Environmental Protection Agency
          401 M Street, S.W.
          Washington, D.C.   20460

          Telephone Toll-free 800-424-9065
          or in Washington, D.C. 554-1404

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                          FOREWORD
This paper describes examples of State administrative responses

to toxic substances problems.  It is an initial effort in a

continuing exploration of Federal-State cooperation for

toxic substances control.  We hope the products of this new

focus will provide useful information to States about State

problems and programs.  Through continued information exchange

and legislative policy analysis, the Program Integration

Division XPID) plans to assist States to develop their own

toxic substances strategies.  These strategies when implemented

in cooperation with EPA's Regional Offices enhance the

probability of successful, nationwide toxic substances

management.  For more information on this project contact:

Director, Program Integration Division,  Office of Pesticides

and Toxic Substances  CTS-7931,  U.S.  Environmental Protection

Agency, 401 M Street,  S.W.,  Washington,  D.C.   20460.
                              Walter W.  Kovalick,  Jr.
                              Director
                              Program Integration Division

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                        Table of Contents



A,   Background/Summary                                      1



     1.   Sources, background



B.   Problems and Constraints                                2



     1.   Political



     2.   Administrative



C.   State Administrative Responses                          6



     1.   Commissions



     2.   Task forces



     3.   Staff models



D.   Conclusions                                            17



E.   Selected bibliography                                  19



F.   Appendices                                             20

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                              -1-
A.   Background/Summary

     The Toxic Substances Control Act (TSCA)  of 1976, unlike
     the Clean Air Act and the Clean Water Act which provide
     funds to State/local agencies to administer and implement
     specific environmental programs, does not expressly delegate
     authority to State or local officals.  However, State
     involvement and implementation efforts are crucial to
     the success of TSCA.

     Currently, control efforts under TSCA necessarily focus on
     national problems (e.g.,  the widespread use of asbestos in
     schools) because of limited resources in EPA.   The Federal
     government (EPA) both promulgates and enforces these
     regulations under TSCA.  Thus, local chemical problems will
     continue to be the concern of State government.

     Are States equipped to deal with chemical problems and crises?

     This broad question was discussed by EPA staff with State
     executive and legislative branch people.  The interviews
     were conducted during the summer of 1979 and in early 1980,
     and ranged from a few minutes to over two hours.

     Persons interviewed included gubernatorial assistants,
     environmental management agency staff, legislators, and
     legislative staff.  They represented 17  States in all

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                             -2-
     10  EPA Regions,, as well as:
     b    The  Great Lakes  Regional Commission;
     o    The President's Office of Science and Technology
          Policy;
     o    The National Conference of State Legislatures;



     o    The National Governors' Association;  and,



     o    The University of Michigan/Ford Foundation



     While many people explained their programs in detail,

     others directed us to better sources of information, or

     confirmed that their States were not actively interested

     in general chemical issues or TSCA.



     This paper discusses part of the findings about State

     chemical management.  It describes several State administrative

     models that have been developed to manage chemicals  and

     analyzes trends in State program development.



B.   The Problems



z    Developing an effective approach for dealing with chemical

     problems presents a difficult challenge to States.  One

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                          -3-
of the principal reasons for this is that many  States



— like the Federal government — have many agencies or



departments dealing with toxic substances.  This



is because chemicals are everywhere — in the workplace,



in food, in consumer products, in all media of  the



environment, and in human beings and animals.   They



are, therefore, not easily classified under the



jurisdiction of any one department.  They involve



authorities and issues corresponding to those



administered at the Federal level by such agencies as



the Food and Drug Administration (FDA), the Occupational



Safety and Health Administration (OSHA), the Consumer Product



Safety Commission (CPSC), the Departments of Agriculture



and Transportation, and EPA.  This complexity has meant



that the States have been quicker to identify the need



for some kind of toxics program than they have been



to attempt solutions.  They continue to explore methods



of responding to the problems (usually perceived as



episodic)  posed by toxic substances, but only a few



have defined their responses well enough to act.







In choosing management structure to cope with chemical



problems,  States have to determine the best way to put



together all the pieces of the toxic substances puzzle —



within political and administrative constraints.

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                             -4-
Political Constraints
                                                c
     Because improper management of chemicals can endanger public
     health, toxic substances management can be, and often is,
     a controversial and emotional issue.  Many interest groups
     — including industry, labor unions, private citizens
     and public health officials — have a vested interest
     in ensuring that toxic substances are managed to their
     best advantage.  Thus, there can be strong pressure
     for States to develop an organization that is responsive
     to, and often with representatives from, special
     interest groups.  Identifying and responding to all
     special interests is a formidable task, and one which
     gives  many States  (and the Federal government) great
     difficulty.

     Public responsiveness must often be balanced with
     the need for  "economy and efficiency."  A Governor,
     for example, must be concerned with keeping within the
     budget and minimizing conflicts with existing programs
     and organizational patterns.  Taxing policies must
     also be considered in this political equation.  Favorable
     tax environments have long been used to encourage business
     and industries  to  locate in  a particular State.  Harsh
     or unfavorable  chemical management policies might offset
     these  economic  advantages for some industries.  Lack of
     State  uniformity on  either taxing or chemical control
     policies may  favor industry  relocation.  Every State must
     simultaneously  balance  the needs for public protection
     against protection of the economic base of the State.

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                               -5-
Administrative Constraints

     Expertise and the need for coordination also has an
     impact on the type of organizational structure chosen.
     Because the issues are complicated and technical,
     and cut across traditional organizations, it is
     necessary to gather together scientific professionals
     from different State agencies and non-government groups
     involved in toxic substances.

     Almost without exception,  these needs were discovered
     while in the midst of trying to cope with a specific
     incident, chemical or problem.   Most of these are well
     known:  PBB's in Michigan; Love Canal; PCB's in New York
     (Hudson River), Montana, Alabama,  and North Carolina;
     and kepone in Virginia,  to name only a few.  Other States
     demonstrating interest in  toxic substances also had
     identifiable "spurs," although less obvious or publicized:
     DBCP in Arkansas (also mentioned by California)  and the
     publication of the "cancer atlas"  identifying New Jersey as
     showing an extremely high  incidence of many kinds of cancer,
     for example.  Only in Maryland could State staff not
     identify the existence of  a problem-specific moving force
     behind their program.

     The significance of this finding is that these emergencies
     demonstrated to the States the difficulties in mobilizing

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                               -6-
     their resources to respond to a multi-media toxic
                                             n
     substances problem.   The presence of PBB's in Michigan
     cattle,  for example,  was described as the first
     "non-disease food problem11 the State Department of
     Agriculture had faced.   It involved the Departments of
     Agriculture, Health,  and Natural Resources, and
     showed that those agencies had responsibility overlaps,
     duplications, and gaps.   The State agencies, according
     to one Michigan interviewee, "didn't know how to cope with
     it."  Arkansas staff commented on the tendency of media
     representatives to have a "segmented" view and to not see
     the "larger picture" in toxics management.  Interviewees in
     Michigan, Minnesota, New Jersey, and Wisconsin stated that
     the various State agencies were not communicating adequately
     with one another on toxic substances problems.

C.   State Administrative Responses

     Three state administrative models are considered below.
     Some of the criteria for analyzing these models include:
     institutional viability, whether the system has a political
     or a technical focus, whether it provides for flexibility
     and involvement of many interests, and visibility for toxic
     substances issues.

     State Toxic Substances Commission

     This approach is now being taken in at least Maryland,

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                          -7-
Michigan, and Virginia.   (California and Wisconsin  have

also evinced interest in this approach, although

neither had done so at the time of these discussions.)

The authorizing legislation for these States enables

or directs the governor to include representatives  of

industry and the public among the commission members, along

with the heads of the appropriate State agencies.



Our example is the Michigan Toxic Substances Control

Commission (see Appendix 1) ,  which has several unique

aspects.  It is staffed by seven full-time employees,

including an Executive Director, and has its own budget

for contracting and research.  The Executive Director

summarized the mandatory and optional responsibilities

of the Commission as follows:



1.   Declaring "toxic substances emergencies;11
2.   "Alerting the Governor and the legislature to
     potential problems" based upon trend data and the
     like; and,
3.   Overseeing and monitoring the way "anyone does anything
     with toxic substances" in Michigan.
The first of these directly responds to the lessons

learned from the PBB contamination of Michigan cattle.  The

Chairman of the Senate Natural Resources Committee, who

wrote the act creating the Commission, believed that the

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                          -8-
State agencies were not working effectively together to

                                                 TV
combat the PBB problem.  The Commission therefore includes


the Directors of Agriculture, Health, and Natural Resources


as non-voting members, in order to "make them


talk to each other publicly."  However, it "can do


most anything" in case of a toxic substances emergency.


Section 6(d)(i) of the enabling legislation, in fact,


allows the Commission, in such emergencies, to


"make all decisions regarding the sale, use, and


method of disposal of the identified toxic substances...."




The Act directs that the Commission include seven citizens


as voting members, but does not require, that they represent


any particular mix of industrial, academic, consumer, or


other interests.




The Maryland and Virginia approaches are similar to each


other; both differ from Michigan's in several important


respects.  Neither Maryland nor Virginia gives its commission


a full-time staff or director; each is  staffed by toxic


substances personnel assigned to the line Departments


in the course of their normal duties.   The Maryland and
                               -•.v
Virginia  commissions report to their respective executive


branch health officials, while the Michigan Commission


reports directly to the Governor and to the legislature.




Neither the powers nor the responsibilities of the Maryland


and Virginia commissions has the apparent reach of the

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                         -9-
Michigan Commission.  The contrast is especially  sharp


with respect to toxic substances emergencies: the


thrust of the Maryland and Virginia legislation is clearly


toward information and advice; neither law allows for the


activist, directive role available to the Michigan Commission,




At least five benefits from the Commission approach


emerge from these experiences:  (1) it institutionalizes


interest in toxic chemical.0;  (2) it de-politicizes chemical


management; (3) it gives greater visibility to the chemicals


problem, (4) it offers a way to recognize and consider the


views of many interest groups in managing toxic substances,


(5) the commission approach (except the Michigan


independent type body) does not require that money be


appropriated by the State for its livelihood.




The Commission approach institutionalizes chemical management


in the sense that the loss of principal sponsors through

                         A-
a change of Governor need not mean the end of the State's


program where there is a statutorily-constituted body.  A


change in Governor, even of party in power, will probably


not entail a loss of momentum.  Even the accession


of a new Governor having no interest in the issue of


toxic substances would leave a staff and mechanism in


place for addressing such problems.  (That will not last
                           \ ,

indefinitely;  the Michigan Act includes a "sunset" provision


giving the Commission a four-year life.)

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                         -10-
Bstablishing a commission de-politicizes toxics management
by isolating the Governor.  A Governor's actions, or
failure to act, may be questioned on bases that divert
attention from the scientific aspects of the problem
itself.  A toxic substances commission is able to make
investigations, draw conclusions, and offer public
recommendations that do not require the Governor's
signature.  The Governor may oppose the commission, but
at least the decision to support or oppose the commission
can be seen as a political decision independent of the
technical aspects of the problem at hand.  The toxic substances
commission can also be required to report to both the
executive and legislative branches, thereby de-politicizing
toxic substances management further in that the commission
would not be a creature of either branch.  This may
be contrasted with the Maryland approach  (the Council is
"to advise the Secretary of Health and Mental Hygiene")
or Virginia's  ("...make recommendations to the
 (State) Board  (of Health)."

The last strength of the commission concept is that it
formally acknowledges the necessity for working with a
variety of experts.  The enabling legislation may direct
that members of  the commission include representatives
of specific interests.  The Maryland law  includes,
in addition to a number of State agencies, the

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                        -11-
AFL-CIO;  the Maryland Chamber of Commerce;  and "any other
private or governmental entity  that  the governor  deems
appropriate."  The Virginia  law directs the Governor to
appoint one representative from each of "the  fields of
agriculture, medicine, labor, industry, and local government."
Among these three laws, only Michigan's fails  to  specify  the
interests commission members should  represent.  Instead,  it
directs the governor to appoint citizens trained  in one
or more of several listed natural sciences.  As noted
earlier, the Michigan Commission does include  an  industry
representative in its membership.

The most serious weakness of the commission approach  is
perhaps also the most obvious:  it usually requires a
new governmental agency, with new staff and new budget.
In today's political climate. Governors are understandably
loath to do anything that appears to expand government,
no matter the purported merits of the new agency.   Commissions
are often politically difficult to manage.   As noted
earlier, the Michigan Act includes a "sunset"  provision
that limits the Toxic Substances Cont-.ro! Commission
to a four-year life,  which can address both expansion and
management problems.

A second weakness to this approach is that it probably
requires new legislation.   This means,  in part, that the

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                          -12-
process may be slow, and that the final product may be very



different from the initial proposal.  This is a weakness


in the sense that the other approaches, described below,


offer an administrative simplicity and directness not


possible if new legislation is required.






The last weakness is the possibility that any newly-created


commission may be opposed by the existing toxic substances


staffs in the State's agencies.  Many States already have
                                             ''J;,

toxicologists, epidemiologists, and other environmental


health professionals working on pieces of the toxic


substances puzzle.  The need for a new, interagency


toxic substances group may r>e less obvious to them.







State Toxic Substances Task Force






This approach  (see Appendix  2) is now being  taken


in at least Arkansas, New Jersey, and North  Carolina.


New York has shown  interest  in the approach, although


it had not been  implemented  at the time of the discussions.



                            •• >r,v
                               •i
The task force approach differs from the  commission approach



in at least  two  ways:

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                          -13-
1.   The membership of the task  force  is  entirely from
     executive branch agencies;  and
2.   No new budget or staff is assigned.  The  task  force
     primarily coordinates and relies on the existing
     resources of the participating agencies  (The
     New Jersey group does have an executive director).
The task force may be created by executive order or by
legislation.  The task forces in these three States
are small, involving four  (New Jersey), five  (Arkansas),
or six  (North Carolina) member agencies.  The product of the
task force may tend toward the intangible of "better
coordination," or toward a fairly comprehensive strategy
document.

One strength of this approach is the ease with which the
Governor can initiate a task force.  North Carolina did
so through legislation, but Arkansas and New Jersey used
an executive order.  A change of administration gave
the incoming Governor the opportunity to easily change his
predecessor's course.  Deciding to continue, he had only
to write a letter directing the chairman of the task
force to reconvene the group.

A second strength is that the task force does not require
additional staff or funds.  It may, therefore, be perceived
by the legislature and the public as a way to get agencies to

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                         -14-
work together, rather than as an expansion of the State


bureaucracy — more efficiency instead of more government.




A third strength is that the task force draws upon the


expertise of the agencies involved.  It is, in fact, a device


to foster the efficient use of available talent.




And last, it allows the Governor to "do something" about


toxics and to do it publicly — the two needs that


prompted every State discussed in this paper to get involved.




The principal weakness of this approach is that it does not


ensure either visibility or permanence to the State toxic


substances program.  An incoming Governor could just as well


dissolve his predecessor's efforts as endorse them.


Furthermore, a task force constituted to make recommendations


to the Governor can do so and never be heard from again.


The members are, after all, the Governor's employees serving


on the task force  as an "additional duty," and all have


been borrowed from their full-time obligations as heads


of agencies or departments.  One gubernatorial staffer
                            i

implied that differences between the old and the new


Governor have left the future of their task force unclear.




Another weakness is that the task force is a part-time


effort without funds or staff.  Such work as is done


is squeezed into the schedules and priorities of staffs


already busy with  their full-time duties.

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                          -15-
A third weakness is the group's inability to direct  State


agencies.  The task force is usually by definition advisory,


and is expected to recommend actions to the Governor.


The North Carolina act enumerates seven functions


for the task force, in addition to "incident response," each


of which allows the group to "study and make recommendations."





A fourth weakness is the failure of this approach to


de-politicize the State's action on chemical problems or


incidents.  The task force is clearly a creature of the


Governor, including as it does only members who report to


him, and excluding the various interests outside of the


executive branch, many of which may be directly affected by


the State's action or inaction.





Personal Supervision by the Governor





This approach (see Appendix 3)  is now being taken


in at least Arkansas and North Carolina.  In both cases,


the States are also using the task force approach


discussed above,  but neither Governor initiated the task
                           *                   :, -

force in his State.  The approach is also being used by


California, but apparently as a transitional and planning


device until a more permanent approach is developed.





The principal strength of this approach is also the most


obvious:  the Governor's personal interest and attention ensures

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                          -16-
that all those who work for him will attach their own interest
and attention to the problems.  They know what the
Governor wants and expects them to do.  They also know
that his interest heightens the probability that the policy,
action, or other recommendation they send forward is likely
to be adopted.

Second, the Governor can marshal the State's resources
for those tasks and problems he thinks important.
As a pragmatic matter, then, this approach should
be the most certain to ensure that whatever talent or
expertise is required from the State bureaucuracy will
actually be made available.  Stated differently,
there is little chance that needed resources will be
unavailable due to supposedly higher priority assignments
on other problems or issues.

Third, this approach^ does not require any reorganization, new
staff, or new budget.  The Governor indeed may not be doing
anything additional or new.  He may instead simply
be reordering the priorities of his administration
 (if only temporarily) to put toxic substances near
the top of the State's and his personal agenda.

The Governor's interest will certainly not be either
undivided or permanent.  A change in his or her  interest,
or a change in governors, may quickly slow or stop

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                               -17-
     progress.  Indeed, the change of Arkansas' governor
     early in 1979 seems to have changed — at least briefly —
     the pace of development of that State's program.  Relying
     solely on the continuing attention of the Governor
     does not institutionalize the program.

     The other notable weakness of this approach is that it
     politicizes the issue, if in no other sense because it
     may become "his/her issue."  The aovernor's action or inaction,
     comments, allegations, or recommendation may be
     scrutinized differently than might be the case were there
     a commission or similar body involved.
                                       •.
D.   Conclusions

     1.   Is one organizational type more "effective" than
          another?  There is no simple answer.  It is really
          too early to compare institutional types since the
          oldest toxic substances management organizations
          have only been in existence for two years.   In
          addition, it is difficult to judge what "effective"
          means.  There are, though,  other interesting points
          that can be drawn from examining State institutional
          management of toxic substances.  This is a highly
          visible, timely issue.  It is a difficult management
          problem.  In deciding which organizational structure
          to use,  States are faced with administrative, legal
          and political constraints.   Because proper management

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                         -18-
    of  toxic  substances  cuts  across different agencies,
    States  have  created  new organizational responses
    which cut across different departments.   Cross-cutting
    authority is required in  order to coordinate all the
    actions and  to get all involved parties talking.
    Finally,  the approach selected by a State is determined
    by  the  "mood" of the times.  One of the most striking
    examples of  this is  the use of the temporary
    organization headed  by part-time "experts" with a
    wide variety of backgrounds.  Such an approach
    reflects both our society's respect for scientific
    expertise and the desire  of today's public to limit
    government spending.

2.  Nearly every State currently active in intermedia,
     interagency toxic substances management was spurred
     to the effort by a specific incident or chemical.

3.   States' institutional responses to the toxic
     substances management problem have taken three
     forms:    (a)  A commission or similar body outside
     the existing State organization chart;  (b) A task
     force or similar body within the existing State
     organization chart;   (c) personal supervision
     by the Governor's office.

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                              -19-
F.   Selected Bibliography
     Adrian, Charles R. State and Local Governments.  New York:
          McGraw Hill Book Company, 1976.
     The Council of State Governments.   Reorganizing State Government-
          A Report on Administrative Management in the States
          and a Review of Recent Trends in Reorganization.Chicago:
          The Council of State Governments,1950.
     The Council of State Government.   Integration and Coordination
          of State Environmental Programs.   Lexington, KY.,1975.
     H^skell, Elizabeth H.f & Price,  Victoria S.  State Environmental
          Management Case Studies of  Nine States.   New York,
          Praeger Publishers, 1973.
     Horton,  Forest W.,  Jr.   "Organization and Management Techniques
          in the Federal Government."   S.A.M.  Advanced Management
          Journal 35 (January,  1970):   66-67-
     Michigan.   Public Act No.  116  (1978)
     The National Conference of State Legislatures.   "TOXIC  SUBSTANCES
          A Survey of Incidents and Government Responses  in
          Selected States."   Denver,  Colorado,  1979.

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                                        COMMISSION EXAMPLE
         REGULATORY
        MONITORING
                                      * RESEARCH/STUDY
                                                                               MANAGEMENT
      Declare Emergency
          Implement
       Emergency Plan
     Coordinating State
     Agencies, Activities
                                      I
 Investigate,  Reports,
      Problems,
   Irregularities
   Emergency
Administrative
   Functions
 Investigate and
 Compile Data Not
 Otherwise Available

         1

 Alert Governor  and
•*-  Legislature of
 Potential Problem
-"              \
      Organize Data on the
      Identified Toxic Sub-
 stances and make Recommenda-
 tions for their Regulation
                                  Recommend State
                                  Agency  Undertake
                                      Studies
                                  Investigate  and
                                  Compile Data Re:
                                Product to be Sold
                                     in State
                                                                          Report Annually
                                                                          to Government and
                                                                             Legislature
                                                               \
                                                      Require Assistance
                                                      from State Agencies,
                                                   Institutions, Universities

                                                               I
                                                      Make and Sign Contracts
                                                         with Institutions
                                                      Foundations or Research
                                                           Organi zations
                                                                           Employ Personnel
                                                                                  I
                                                           Appoint Executive
                                                               Secretary
                                                                           to
                                                                           o
                                                                           i
                                                     Promulgate  Rules,
                                                        per Act  306
6
H
                                                       Make and Sign Any
                                                     Agreements and Perform
                                                            Any Acts

                                                               I
                                                           Establish
                                                       Advisory Commi'h'hees
                                                  Examine State Programs;
                                                  Develop and Evaluate
                                                    Emergency Plan

                                                  ~       I         ~

                                                  Make Necessary Expendi-
                                                     tures from Toxic
                                                  Substance Fund During
        *Permissive function

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                                      TASK FORCE EXAMPLE
                                         OFFICE OF COMMISSIONER

                                              Commissioner
                                           First Deputy Commissioner
O
H
to
       Asst. Commissioner

             for

        Natural Resources
             Lands and
              Forests
             Division
                   Toxics
                 Coordination
                  -—I
              Fish and
              Wildlife
              Division
                    Toxics
                  Coordination
                  L-J
  Marine
Resources
 Division
                    Toxics
                  Coordination
                      "1
                                             Asst.  Commissioner
                                                    for
                                            Environmental Quality
                                              Toxics Policy and
                                                 Coordination
                                      Air
                                    Division
                                                      Toxics
                                                   Coordination
                              Asst.  Commissioner

                                    for

                                Regional Affairs
                                      Water
                                    Division
i
to
                                    Regions
                                     1-9
                                                       Toxics
                                                    Coordination
                                         Toxics
                                      Coordination
                                   Solid Waste
                                     Division
                                         Toxics
                                       Coordination
                                                 Construction
                                                  Mangement
                                                   Division
   Toxics|
Coordination  J—

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                                     GOVERNOR'S  COMMISSION EXAMPLE
                                                  GOVERNOR
                                          1.  Toxic  Substances
                                           and Hazardous Mate-
                                              rials Policy
                                                Committee


2 . Information
Management
Committee

- . . 1
3. Toxic Substances
. Assessment
Committee



4. Committee on
Alternative
Methods & Materials


5 . Regulatory
Assessment
Committee


6. Crisis
Response
Committee
                                                                                                       ro
                                                                                                       M
                                        Elemental Responsibilities

                                    1.   Intergovernmental Cooperation and Coordination
                                    2.   Information Management
                                    3.   Assessment
                                    4.   Prevention and Control
                                    5.   Prevention and Control
                                    6.   Crisis Response
M
x
UJ

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