EPA741/R/92/001
U.S. ENVIRONMENTAL PROTECTION AGENCY

     POLLUTION PREVENTION STRATEGY
 Environmental programs that foots on the end of the pipe or the
 lap of'the slack, on cleaning up after the damage is done, are no
 longer adequate^ We need new poiides, uchnotog iesฑ and
 processes that prevent or minimize pollution ~ that stop it from
 being created bt the first place. .   ;:: ,..;•: > y...,,i:iฃ::;^ ;>.•:

 —  ; Prerideatt George
    '
                   January 1991
                                        Printed on Recycled Paper

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                                      EPA741/R/92/001
                   TABLE OF CONTENTS

EXECUTIVE SUMMARY

PART I    INTRODUCTION

           A.  Objectives of EPA's Prevention Strategy
           B.  Background
           C  Prevention: First Choice in Every Sector
           D.  Toward a Prevention Strategy

PART H   GUIDANCE FOR EPA'S PROGRAM AND
           REGIONAL EFFORTS

           A.  General Principles
           B.  From Principles to Action

                1.  Identifying  and Overcoming Obstacles
                2.  Expanding  Public Participation and
                     Choice
                3.  Partnership with Federal Agencies
                4.  Investing in the States
                5.  Outreach and Training
                6.  Regulation  and Permits
                7.  Enforcement
                8.  A Research Strategy for Prevention
                9.  Looking Ahead: Emerging Products,
                     Technologies

           C.  Promoting Institutional Change at EPA

PART ffl  INDUSTRIAL TOXICS PROJECT

           A.  Targeting
           B.  Outreach
           C.  Organizing for Action
           D.  Measuring Progress

PART IV.  NEXT STEPS

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                                                 Executive Summary
                   EXECUTIVE SUMMARY
A.  INTRODUCTION

    In the twenty yean since the Environmental Protection Agency was
founded, America has  made real progress in reducing the  threats  of
pollution to human health and our natural environment  EPA enters  its
third decade, however, facing a new generation of complex environmental
challenges requiring  a new response.

    The new  challenges include persistent, mobile and bioaccumulative
toxics released from both  industrial  facilities and  a wide  variety  of
dispersed sources; agricultural practices that jeopardize the quality of our
rivers, lakes, and ground water, and pollution from our ever-growing need
for energy and transportation. These problems must and can be addressed
in a cost-effective manner that does not .impede economic growth and
maintains U.S. competitiveness in the  global economy.

    EPA joins those  spokespersons for industry, states, and environmental
groups  who  advocate  responding to  these challenges by  preventing
pollution at its source, whether  through  changes in production  or  by
reducing reliance on environmentally harmful  materials.  Studies have
shown that pollution prevention can be the most effective way to reduce
risks by reducing or  eliminating pollution at its source; it also is often the
most cost-effective option because it reduces raw material losses, the need
for expensive "end-of-ptpe* technologies, and long-term liability. In short,
pollution  prevention  offers  the unique  advantage   of  harmonizing
environmental protection with economic efficiency.
B.  STRATEGY OBJECTIVES

    This document presents EPA's blueprint for a comprehensive national
pollution prevention strategy.  It is designed to serve two purposes:

    • to provide guidance and direction for efforts to incorporate pollution
      prevention within EPA's existing regulatory and non-regulatory
      programs; and
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Pollution Prevention Strategy
    •  to set forth  a program  that will achieve specific  objectives in
      pollution prevention within a reasonable time frame.

    The first objective reflects EPA's belief that  for pollution prevention
to succeed, it must bs a central part of the Agency's primary mission of
protecting human health and the environment; the goal is to incorporate
prevention into every aspect of the Agency's operations in program and
regional offices (see section C of this executive summary).

    Naturally, the strategies  reflected in this document do no more than
identify the  spM&fc foHtatas tiits EPA will ubdttt*!& on a& Agency-
wide  bW.s uV [htivkte a mufc.! for ctvss-pw&raii  cooperation.   EPA
encoui?ges its proferafti* and legions to continue to identify and exploit
pollution prevention opportunities.   Many such initiatives art already
underway or being planned by program and regional offices; a description
of them is available  upon  request to the Office of Pollution Prevention.

    To address the  second  objective, ths strategy includes a plan for
targeting 15 to 20 high risk chemicals that  offer opportunities for
prevention, and  sets a voluntary goal of reducing total environmental
releases of these chemicals by 33 percent by ths end of 1992, and at least
50  percent by the  end of  199S.   Ths specific  toxics reduction  effort
(summarized in part  D) is only the first step.  EPA recognizes that there
are substantial opportunities  to promote prevention in other sectors, such
as agriculture, energy, transportation, municipal water and wastewater, and
will work with other federal agencies to develop specific strategies for
trws,e  sectors  in the use? future. Agencies that will fepip contribute to the
development  of t  vention policies in thscs areas include tfas Council on
Environmental Quality, and  the Departments of Agriculture, Commerce,
Defense, Energy, Interior, and Transpoft&tica.  The^ efforts will help
bring  needed focus to the Agency's pollution prevention program, and will
allow EPA  to apply some of the concepts discussed in  the general
strategy
        stmtsgy seeks neither to expand EPA'c existinc authority, nor
proposes new regulatory requirements.  Rathe?, tits Agency's gooi is to:

    ซ  investigate asd, where possible,, eliminate bsmess to cost-effective
      investments in prevention in existing and new regulatory programs,
      and
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                                                  Executive Summary
      encourage voluntary actions by industry that reduce the need for
      EPA to take action under statutes tike the Toxic Substances Control
      ACL
C.  GUIDANCE TO EPA PROGRAM AND REGIONAL OFFICES

    While some of EPA's activities in  past decades have employed an
essentially preventive approach, the last  two years have seen a concerted
effort by EPA's program  and regional  offices to incorporate  pollution
prevention into their activities. The general principles stated below will
help to guide the Agency's specific pollution prevention activities outlined
further on.

    General Principles

    Because EPA  believes that pollution prevention can benefit both the
environment and the economy, the Agency's  policy will be designed to
maximize private  sector initiative by working with industry to achieve
reasonable  prevention goals.   This  approach  should  encourage more
businesses to identify and profit from opportunities for prevention, which
in turn will yield significant public dividends in the form of increased
environmental  protection.

    At the same time, EPA believes that there is a continuing need for a
strong regulatory  and  enforcement  program under  existing  statutory
authorities and that these provide further incentives to prevent pollution.
EPA will be working to coordinate its regulatory program to help industry
identify the potential for  multi-media, prevention  strategic* that reduce
end-of-pipe compliance costs.  EPA will  investigate flexible, cost-effective
regulatory approaches that avoid prescriptive approaches and that rely on
market-based incentives where practical and authorized by law. EPA will
also ensure that  its enforcement  program seeks pollution prevention
opportunities as part of ensuring compliance.  Finally, the Agency will
implement  mechanisms  to streamline  regulatory and administrative
processes involved in testing and applying innovative pollution prevention
technologies.
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Pollution Prevention Strategy  •   __   __

    From Principles to Action

    Based  on these general principles,  EPA will  be working on the
following activities:

    ซ  Identifying and overcoming  obstacles to prevention - EPA  is
      undertaking severnl projects to identify specific regulatory and non-
      regulatory barriers and determine how they can be modified.  In
      addition, EPA will promote prevention among small and  msdium-
      sized businesses through technical assistance, financial assistance,
      and information sharing,  EPA will  also work with  other federal
      agencies   to   modify  non-regulatory  programs   to   improve
      opportunities foi prevention.

    •  Expanding public participation and choice -  In the wake of the
      public's   growing  environmental  consciousness,  EPA  will  bs
      responding to the need for more and better  information on the
      environmental performance of both consumer products and industrial
      facilities, establishing voluntar • guidelines for use of environmental
      claims in labeling, and expanding public databases.

    o  Partnership with federal  agencies - EPA will work with other
      federal agencies to develop prevention strategies for agriculture,
      energy,  and   other  sectors,  to  incorporate  prevention  into
      management  of federal facilities, to encourage the development of
      pollution prevention technologies, and to increase the consideration
      of environmental impacts  in federal procurement decisions.

    ซ  Investing in the states ~ Through its Pollution Prevention Incentives
      for States graft program, EPA is prcmotino &? estcblishrasat and
      expansion of stose multi-madia pollution prevention programs and
      is  testing  innovative  pollution  prevention  technologies   and
      applications as  tfcs regional ced state level
      Outreach and training - EPA will ssak to lay the $roundwc& fo?
      o pollution prevention orientation within  govesimsnt, fadostry,
      cccdemic institutions, the pubL  , and inmntionally through a
      variety of ouceech and educational inmcssves.
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                                             Executive Sumrtary
                                                       ,    -,
Regulations and permits - EPA will seek to strengthen the ability
of the existing regulatory framework to provide further incentives
for prevention:

       Regulatory clusters;  The Agency will categorize the  rules
       it intends to propose over the next several years for certain
       chemicals and their sources (taking into account regulatory
       schedules imposed by Congress and by court order). These
       "dusters" will foster improved cross-media evaluation of the
       cumulative impact of standards, encouraging early investment
       in prevention technologies and approaches.
      Flexible use  of TSCA:   The Toxic Substance Control Act
      will provide  a cost-effective and flexible means to create
      direct  or indirect  incentives  for multi-media  prevention
      strategies.  Other regulatory programs will continue to play
      a role  in encouraging incentives for prevention.

-    Permits:  EPA will work to provide industry with the
      flexibility to use prevention  approaches,  as opposed to
      treatment and disposal to meet permitting requirements. EPA
      is also investigating more flexible approaches to permitting
      that encourage multi-media prevention alternatives.

Enforcement  -  EPA will encourage  the inclusion  of pollution
prevention conditions in Agency enforcement settlements.

Research - EPA's Pollution Prevention Research Strategic Plan
establishes a blueprint for future research efforts. Short-term efforts
will focus on targeted contaminants; longer-term efforts will address
social  and  economic  obstacles to   prevention,  as well  as
opportunities for prevention in the non-manufacturing sector.

Emerging products and technologies - EPA will try to identify and
avoid environmental problems before  they  arise  by encouraging
development of safer substitutes for hazardous raw materials or
products, as well as cleaner technologies.
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Pollution Prevention Strategy
    Institutionalizing Pollution Prevention at EPA

    EPA's strategy must confront institutional barriers within the Agency's
own organization that  limit its ability to develop effective prevention
strategies.  While addressing these institutional barriers will be a long-
term  task, EPA will  begin with a  number of measures,  including:
designating special assistants for pollution prevention in each Assistant
Administrator's  office,  developing incentives  and awards  to encourage
Agency  staff to engage in pollution prevention efforts,  incorporating
prevention into  the  comprehensive 4-year strategic plans developed by
each program office, providing pollution  prevention training to  Agenoy
staff, suppor^ udL-uclogy innovation, and   eluding prevention-related
activities in ths Agency's operating guidance, accountability measure*, and
regulatory review and development process.
D.  INDUSTRIAL TOXICS PROJECT

    EPA's industrial toxics project will target specific chemicals from the
manufacturing sector and develop focused prevention strategies for them.
EPA's goal will be to reduce aggregate environmental releases of these
targeted chemicals, as measured by the Toxics Release Inventory (TRI) in
1988, by 33 percent by the end of 1992 and at least SO percent by the
end of 1995.   EPA has chosen  to propose national goals, rather than
specific  ones for each  chemical, industry sector, or company.   This
provides companies that choose to participate  in  the program with the
flexibility to propose their own goals and to allocate reductions among
affected sources, and within the list of target chemicals, according to what
appears most cost-effective.

    The project will offer industry the  opportunity to  participate on  a
voluntary  basis,  while not  interfering with  the  Agency's  statutory
responsibilities under the new Clean  Air Act or other laws.  EPA will
work wWr companies  to ensure that  any initiative' taken to  reduce
emissions ahead of statutory schedules receive  appropriate credit toward
complying with any subsequent regulatory requirements.

    The Agency is hopeful that this voluntary effort will inspire proactive,
innovative responses from the private sector, which  would help  to build
trust in industry's readiness to provide the public with the environmental
protection it expects.  This, in turn, would make it  easier to investigate
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                                                    Executive Summary
those barriers  in existing law, regulations,  and permitting practices that
inhibit flexible, cost-effective solutions to environmental problems.

    The fo"i principal elements of the project are reviewed below.

    Targeting

    EPA will  identify  15 to 20 pollutants from TRI that present both
significant  risks to human  health  and the environment, and  potential
opportunities to reduce  such risks through  prevention.  The list will be
drawn from recommendations submitted  by program offices, taking into
account such criteria as health and ecological risk, potential for multiple
exposures   or cross-media  contamination,  technical   or   economic
opportunities for prevention, and limitations of treatment  technology.
                                                                •

    The target chemicals are based on a rational evaluation of both risk
and  opportunity for prevention, and  EPA  expects  virtually all will be
subject to technology-based standards under the new Clean Air Act. This
will ensure that industries participating in the voluntary program will also
be eligible to  apply for credit under the "early reduction" provisions of
that law.

    EPA expects the target list  will  serve  to  determine whether this
experiment in voluntary reductions can get measurable results.

    Outreach   •ซ

    As a first step, EPA will use TRI- data to identify major industrial
sources of toxic chemical releases to the environment  By December 15,
1990, EPA intends to produce a detailed plan for contacting these facilities
or their, parent companies.  EPA will  ask die facilities or companies that
choose to  participate to make  voluntary,  measurable commitments to
reduce releases of targeted contaminants  to the  environment and to
identify how  they  will carry out these  commitments.'   In light of the
substantial public commitments already undertaken by many companies to
reduce the release  of TRI chemicals, EPA expects a positive response
from this outreach effort

    EPA will  make every effort to coordinate contacts with industry to
eliminate redundancy and paperwork.   Although the outreach program is
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Pollution Prevention Strategy  .
                                                                  ;.
designed  to  be  voluntary, it will not be allowed  to  interfere  with
fulfillment of the Agency's statutory responsibilities (including timetables
for action) and enforcement obligations.

    Organizing for Action

    EPA will form cross-rnsdia workgroups comprised of representatives
from different Agency offices to provide analytical and technical support
to the outreach program, to  evaluate industry voluntary plans, and to
define regulatory clusters.
    To assist in assessing risk reduction froiu pollution prevention efforts,
EPA will rely on data from TRI to track reductions in releases of targeted
contaminants from industrial facilities. Although TRI has soms significant
limitations, at this tints it is  the only available database that permits the
tracking  of chemical releases at specific facilities oa n multi-msdia basis.
EPA has three years of experience collecting TRI data, which is already
being used widely by industry, the states, and enviroamsatal groups as a
scorecard for prevention efforts.   EPA is  taking a numbsr of steps to
address TRTs shortcomings,  and will also develop indicators for sources
not covered by the program.

E.  NEXT STEPS

    EPA will bs undertaking a number of efforts  to further expand the
scops of this strategy, including working with oths? fedsrcl agencies to
develop  strategies for othssr sectors, and obiokdng trrocd input through a
series of public hs&rings regarding implemsataiica of tfes strategy and
refining a national pollution prevention agenda for
    Tfric Pollution Freveatica Stratsgy is EOS os cssssips co eife e
or sup253cs emsting authtmties and pogross^.  S?A' nill cosites to
proces^ witz rcgelatioa dsvelopmsas, pssimtEing, C2i5 eaf give
preference to cost-effective  and environmsntally protective prevention
approaches, in addition to recycling, trcditioaal Geotmssit, cad disposal
                                ES-8

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                            PART I

                       INTRODUCTION
     End~of-pip€ centrob and won* dbposal should b* the last lute of
     environmental defenst* not thtjron Hoi, Preventing pollution at
                                        ifftcave way tortduct
                                                   '
                                              -^
                                             Sepmber 1990,
                                                   '  *
      Over the last two years, EPA Administrator William Reilly has
made pollution prevention one of  the  Agency's top priorities.  This
strategy indicates how EPA intends to incorporate pollution prevention as
a fundamental principle of the Agency's mission to protect human health
and the environment

      This introduction to EPA's  pollution prevention strategy:

    •  outlines  the two principal objectives of EPA's pollution prevention
      strategy;

    •  provides  background  on  why there is  a  need  for  pollution
      prevention  despite two  decades  of progress  in environmental
      protection efforts;

    •  describes how pollution prevention can help meet the environmental
      challenges ahead in major sectors of society; and

    •  explains  the assumptions underlying EPA's  pollution prevention
      strategy.

A.  OBJECTIVES OF EPA'S PREVENTION STRATEGY

    EPA's pollution prevention strategy is designed to serve two purposes:

    •  to provide guidance and direction for efforts to incorporate pollution
      prevention  into  EPA's  existing  regulatory and non-regulatory
      programs; and
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Pollution Prevention Strategy
                                                             .
    •  to set forth  an initiative that will achieve specific objectives  in
      pollution prevention within a reasonable time frame.

    The first objective recognizes that EPA makes hundreds of decisions
each year at every level of the   xgency - from drafting regulations  to
making grants to enforcing permits.  Etch of these cctivities presents
opportunities  for prevention.   This  strategy aims to  provide  policy
guidelines to help decision-making by EPA's headquarters  and regional
staff, to outline soms cctions EPA will undertake to put these principles
into practice, and to strengthen EPA's institutional capacity to undertake
and complete im.v.tttioซ fปiin'8ซlves. . Pr? H of this  strategy details how
EPA will rac . il i  fin. obj ttivo.

    The second objective, is discussed in Pan HI of this  strategy, which
outlines a prevention initiative for industrial toxics.   This represents the
first of several specific projects that will comprise EPA's overall pollution
prevention strategy.  EPA has chosen to begin with  the manufacturing
sector, since it is the current focus of most of the Agency's activities,
and because the  Science Advisory Board has identified toxic pollutants
as presenting  serious threats to human health and the environment.  By
setting measurable goals and laying out a relatively detailed plan for
achieving them,  this project will promote accountability for results  at
EPA.  At the same time, this  effort will help EPA further the first
objective of promoting a cultural change  at the Agency by  practically
applying the general policy guidelines.

    Opportunities for pollution prevention abound in other sectors as well.
EPA plans to develop similar focused, Agency-wide prevention projects
for agriculture, energy and transportation, municipal water and wa-ewater,
and federal facilities.  A strategy for municipal solid waste ha.  Jready
been published1

    It i& important to note that EPA doss  002 visr/  pollution  prevention
as an @KCฃC estivity standing apart from the Agency's piimcry  mission  of
protecting  bumsa health and  the environmsnt; rather,  the  500! is  to
incorporate  prevention into every aspsct of die Agestsy's ops-on'ons  in
program and regions! offices.  Tits national snzasgisB reflected in this
    '  US. EPA. Office of Solid Waste, The Solid Waste DUenaza: An Agenda for
Action. February  1989 (EPA/5 30-SW-89-019).
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                                                  Pan I -  Introduction
docuir'-' ar.J    ' -.equent  installments  do no  more  than  identify
specific initiatives that EPA will undertake on an Agency-wide basis, and
are designed to provide a model for cross-program cooperation.

    EPA programs and regions .will to continue to take the initiative in
identifying and  exploiting  other pollution prevention opportunities.
Because of the nature  of this  document, a delineation  of the respective
roles of the program and regional offices is not included here, but will be
addressed in internal EPA guidance. Examples of the many program and
regional initiatives already underway or being planned are available upon
request to the  Office of Pollution Prevention.

B.  BACKGROUND

    Two decades of progress

    The conventional regulatory approach to environmental protection and
the billions of  dollars Americans have spent over the past two decades for
cleaner air, water, and  land  have produced some remarkable  success
stories. For example:

    •   comprehensive  hazardous waste  management regulations are in
       place; among other things, EPA's Office  of Solid Waste estimates
       that these  regulations  have kept  roughly 1.6 billion  gallons of
       hazardous  waste  per year  from  being  landfilled without  prior
       treatment;

    •   between 1979 and 1988, lead, sulfur dioxide, and paniculate levels
       in ambient air decreased by 89 percent, 30 percent, and 20 percent,
       respectively;2 and

    •   municipal sewage treatment has improved dramatically; over 176
       million  Americans were served by sewage  treatment systems in
       1988 compared to 85 million in 1972.'
    1 US. EPA, Office of Air Quality Planning and Standards (OAQPS), National
Air Quality and Emissions Trends Report, 1988. March 1990 (EPA-450/4-90-002).

    ' US. EPA, Needs Survey Report to Congress: Assessment of Needed PubUcfy
Owned Wastewater Treatment Facilities in the United States, Febnuiy 1989 (EPA
43009-89-001).

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Pollution Prevention Strategy
    Some of EPA's activities in past decades that have banned or reduced
the use of pesticides and other chemicals have employed an essentially
preventive approach. Other regulatory and enforcement policies have also
helped to foster prevention. For example, banning the land disposal of
certain  wastes  under  RCRA, while  sharply  increasing  the  cost  of
treatment, has led to reduced waste generation. Similarly, in the Agency's
water program, certain permitted facilities are required to conduct toxicity
testing of their effluents, aod.  if toxicity is found, to eliminate  it at  its
source.   Best managen&ut practices required in water discharge permits
also prevent process nvirt'r1*  frc.> I,-*:• u-dJฃrh*lto^ f< pollutants to the
environment through lea':? ant' spi'l:.

    In spite of the impressive gains achieved by environmental regulation,
new and more subtle sources of pollution and better methods of detection
have mฃde us aware  of the  brocd scop? of  our  pollution  problems.
Emerging environmental problems include international concerns such as
climate change and ozone depletion; increasing human and environmental
exposure  to toxic chemicals;  cross-media problems  such as acid rain,
nonpoim source pollution, and ground-water contamination; and decreasing
waste disposal capacity and massive waste cleanup costs.

    Need fo? pollutioQ prevention

    Pollution prevention is critical to overcoming some of the limitations
in our traditional approaches to pollution control.  These constraints are
summarized below:

    • Cress-media Transfers.   It  is  increasingly clear  that some
treatment technologies, while solving one pollution problem, have created
others.  .Air pollution control devices  ox industrial wcsfswnter treatment
plants prevent wnsteo from going into the oir or Tvoes; bu tfes toxic ash
and clc^ip &og tfesss systems prcdizco cca becoma  fecsontoso waste
prob&s^Q fcenKelvea  Wastes disposed of cm tire lead'err in deep wells
may ccatasiinnts ground  water, and evaporation from poods ond lagoons
can craves solid or liquid wastes into air pollutioa fjooblosio.

    The Great Lakes (see box on page 6) offer oa excellent example of
how our understaodiag of environmental problems bos expoo&d, revealing
the need for a multi-media focus to  adequately protect human health and
a fragile, interdependent  ecosystem.  While cross-media connectic   are

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                                                    Pan I - Introduction
complex and difficult to manage, part of the solution should be to reduce
or even eliminate pollution at the source.  Prevention reduces emissions,
discharges or wastes  released  to  all parts of  the ecosystem,  thereby
eliminating a potential cross-media "shell gams."

    •  Pollution from Dispersed Sources.  In addition to controlling and
reducing discharges from large "point sources," EPA must more effectively
address diffuse  sources of pollution, usually referred to as  "nonpoint
sources" or area sources, as well as the many small point sources.  For
example,  only  a  fraction  of  chlorinated  organics  released   to  the
environment corns from  large  industry.   The  rest corns from a wide
variety  of largely unregulated  activities such  as  dry  cleaning, paint
stripping, and degreasing operations. These and other small sources are
so numerous that it is often not practical or economical  to control their
pollution  by mandating treatment  technologies.   Alternative prevention
policies may be more effective in encouraging development and use of
safer  substitutes, such as  water-based solvents.

    o  Search for Cost-Effective Alternatives.   Finally, industries  and
public agencies at all'levels  of government  already spend as much as
$120  billion annually to treat or contain wastes once they are generated.4
Hazardous waste treatment and  disposal costs have risen as much as 300
percent over the past decade due to the ban on land disposal ot hazardous
waste, minimum technology requirements for hazardous waste units, and
limited treatment and disposal capacity.5

    Implementation of the Clean Air Act end other statutes will add to
these costs in the years ahead,  suggesting toot it is appropriate to begin
looking for ways to elinrio&s or reduce waste streams that will otherwise
have  to be managed at great expense. Tits public accountability fostered
by the- Toxic Release  Inventory has also created a strong incentive to
minimize waste.

    Gives these  factors,  some  companies (but  by no means all) have
already begun to demonstrate that preventing pollution at the source offers
a low cost alternative to  investment in traditional treatment technologies.
    '  U.S. EPA, Office of tits Administrator, Environmental Investments:  The Cost
of a Clean Environment, Report to Congress, unpubliritsd draft

    '  US. EPA, Office of Solid Waste estimate.
                                  •5-

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Pollution Prevention Strategy  .
    TfeGrcdtLofcea
    IdemfiM
    tei  Lcte Cassf&oc^
                              ^f^irg^^

    jfcflflOJJifo/??^
BeneSrr to firms uadsstaMag wests rafcctica caj ictluds redcced on-
site occD3 ireatmssK coots; reduced tSTiacprariniica osd dicposol costo for
wastes gfdppd off-cits; savings in parcbosso of chsmfcol^ ei^gy,
and other input materials;  and reduced pToductioa costs through  better
management
    To cite a few of the hundreds of examples available:

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                                                  Pan I -  Introduiown
    - Chevron's Save Money and Reduce Toxics (SMART) Program.
      In 1987,  the  first  year  of SMART, hazardous waste  disposal
      dropped 44  percent, from  135,000 to 76,000  tons, saving the
      company $3.8  million.  In part, this was achieved by substituting
      non-hazardous  drilling  mud additives for  compounds that  were
      considered hazardous.  Chevron has  set a goal of a 65 percent
      across-the-board reduction by 1992.

    •• Clairol plant in Camarillo, California, which produces hair care
      products,  previously flushed their pipes  with large  quantities of
      water, wasting  the material inside the pipe. By installing a $50,000
      system using a foam ball  propelled  through  the pipe by air to
      collect the product, waste was reduced by 395  gallons per day and
      $240,000 was  saved each year.

    - Major Paint Company.  By replacing a caustic cleaning solution
      with a  longer-lived substitute,  this  small  California  company
      achieved  a  50  percent reduction  in  dirty solvent  disposal.
      Switching to a high-pressure spray system  to wash tanks reduced
      wastewater volume by 25 percent  The firm estimates that it has
      saved more  than  $2 million in disposal  fees  over the past  eight
      years.

C.  PREVENTION:  FIRST CHOICE IN EVERY SECTOR

    How does pollution prevention apply to the major environmental
challenges  in  each  sector of  our society?   The cornerstones  of  a
comprehensive pollution prevention strategy will be  its responses to the
challenges  in manufacturing,  agriculture,  energy  and transportation,
municipal solid waste and  municipal water and wastewater.

    L   Manufacturing and Chemical Use

    In  spite of  the progress  that has been made controlling  industrial
pollution, the release  of industrial toxic pollutants into the environment
continues. The Toxic Release Inventory data for 1988 show that reporting
facilities released  t  total of  4.57  billion pounds directly  into the
environment Of this total, 360 million pounds of toxic chemicals were
released into rivers, lakes,  streams, and other bodies of water, 2.4 billion
pounds were emitted  into the air, 560 million pounds were disposed of in
landfills; and 12 billion pounds  were injected into underground wells. In
                                -7-

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Pollution Prevention Strategy
addition, 570 million pounds were transferred to munici-.il waste water
treatment plants and  1.1 billion pounds were transferred to commercial
treatment and disposal facilities.

    The impacts of these discharges on human health and the environment
depends  upon  the  toxitities  of tire  chemicals end  on  the various
characteristics of the  media into which they ere released.   Exposure  o
some toxic  chemicals  may increase  the  risk  of cancer,  neurological
disorders, birth  defects,  and other health effects.  Once released to the
environment, some toxic chemicals may persist for long periods of time,
be  easily transferred from one  part  of the ecosysteiu  to another,  or
bioaccumulate in the  food  chain.

    2.   Agriculture

    Agriculture  in the United States consists of over 2 million  farms
covering more than 800 million ceres  generating such diverse pollutants
as sediment, pesticides, and nitrogen and phosphorous from livestock and
fertilizers.  Agricultural pollution, like otas? types of nonpoint  source
pollution, is characterized by the widespread nature of its sources; it stems
frc  n literally millions of everyday activities cad management  decisions
made by individual fanners and agricultural concerns.  Individually these
activities may  not   cause discemable environmental  harm,  but  the
aggregation of  hundreds or thousands of activities ova many weeks,
months,  or years can combine  to  adversely affect  ground water and
surface water quality, species habitats, and the quality and productivity of
the soiL

    Agricultural runoff is a major reason dies so many lakes, river  and
estuaries have failed to attain water quality stnadosiSs.   Because  water
pollution does  not respect property Bass, the  resulting water quality
problems typically appear  downstream and off  &3 fona, father than at
their cs&os,  Of the  waters assessed to date, pollution from agricultural
source? ecatribatso to 58  psscent of tfes lofes esses, 55  pssceat of the
stream miles, end approximately 18  psiccas of tfes cqoore  mileo  of
esnisriso that do not mssi woter quality ggs&s&P.  Threats to
water .quality are also  present;  40  stoiso cstfi CSHJESIGS repout
       US. EPA. Office of Water. National Water Quality Inventory, 1988 Report to
Congress, Wcdtingjoa, O.C, April 1990.

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                                                    Pan I •  Introduction
                                                               .-     .
agricultural  activity  is a concern to ground water  and, in virtually all
states, nitrates in ground water exceed drinking water health standards.7

    Irrigation return flows can discharge high concentrations of pesticides
and nutrients, and excessive consumption of irrigation waters can reduce
downstream flows necessary to support  aquatic species.   Surface  water
supplies  of  drinking water can also be affected by, for example, spring
runoff in intensively fanned areas.  Agriculture also  affects other pans of
the ecosystem;, for example, fish, wildlife, and waterfowl may be banned
through  exposure to the  aerial drift of pesticides  and the  leaching of
minerals from topsoil. Pesticide residues on foods can also pose a health
risk.  Finally, agricultural activities can also displace wetlands and other
ecological habitats.

    3.    Energy and Transportation

    The  environmental  impacts of energy consumption are far-reaching,
affecting air and water quality and public health. Combustion of coal, oil,
and natural gas is responsible for air pollution in urban areas, acid rain
that is damaging lakes and forests, some of the nitrogen pollution that is
harming estuaries, and it may contribute to global  warming.  Although
data show  that, for  the period  1977 to 1989, annual average  ambient
levels  of all criteria air pollutants were  down  nationwide,  96  major
metropolitan areas still exceed the national health-based standard for ozone
and 41  metropolitan areas exceed the standard for carbon  monoxide.1

    Reauthorization of the Clean Air Act is expected to impose additional
standards for control of pollution from energy combustion;  historical data
show that increasing energy efficiency could substantially lower the costs
of complying with these new requirements. Between 1973 and 1988, the
U.S. reduced by 27 percent  the amount of energy required to produce
each unit of gross national product.  Without this reduction, U.S. energy
consumption would have been 36 percent higher in 1988, annual carbon
emission* would have reached 1.8 billion tons rather than 1.4 billion tons,
and the economy's annual energy bills would have increased by over $100
     7  US. EPA, Office of Water, National Water Quality Inventory. 1988 Report to
 Congress, Washington, D.C., April 1990, and Water Quality 2000, Draft Phase II
 Workgroup Reports, January 1990.

     '  US. EPA. Press Release, August  16, 1990.

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Pollution Prevention Strategy

billion.'
D.  TOWARD A PREVENTION STRATEGY

    Establishing a definition

    Pollution prevention can best be understood by considering what it
means to the sectors discussed above.

    Manufacturing and Chemical Use. Pollution may be generate** tiuti/g
manufacturing, or wbf.a certain  product* are used cona*/ \ซ-ially  or by
            This may be prevented in three ways:
    • Changing Inputs/Reducing Reliance on Toxic or Hazardous Raw
      Materials:  A  manufacturer may substitute non-toxic for  toxic
      feedstocks in  making a product;

    • Process   Changes/Increasing  Efficiency/Improved  Maintenance
      Practices:  The production process may  be altered to  reduce the
      volume  of materials  released to  the environment as toxic  or
      hazardous waste;  in addition to avoiding waste management costs,
      these changes often improve efficiency by reducing raw material
      losses and conserving  water.   Process changes  may include
      equipment modifications or less expensive housekeeping measures,
      as  well  as in-process, closed loop recycling  that  returns  waste
      materials directly  to production as raw materials;

    • Changing  Output/Reducing Reliance on Toxic  or Hazardous
      Products:  The manufacturers or users of commercial products may
      switch to non-toxic or less toxic substitutes.

    This definition is consistent with that  established under the Pollution
Preventioc Act of 1990.
    ' Amo -; B. Loviru and Robert Sardinsti, et al.. The State of the An: Lighting,
Rocky Mountain Institute, Old Snowmass, CO, March 1988.  Amory B. Lovini, et
aL, The State of the Art: Drivepawer,  Rocky Mountain Institute. April 1989.
                                 •10-

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                                                    Pan I -  Introduction
    Agriculture.  Agricultural pollution may be prevented by:

    • Development and adoption  of low input  sustainable  agriculture
      practices  that eliminate  .the  wasteful  use of  inputs,  such  as
      fertilizers, pesticides, and water;

    • Soil  conservation and land  management  practices  that  prevent
      erosion of sediment and the runoff of pesticides  and fertilizers.

    Energy.  Pollution from energy consumption can  be prevented by:

    • Increasing energy efficiency to reduce the generation of pollutants
      associated with the extraction, refining, and use of fuels;
                                                                 ป
    • Increasing reliance on clean renewable energy sources or alternative,
      less polluting fuels.

    Most  of the  preventive approaches  outlined  above  will  yield
environmentally preferable  and more sustainable production options along
with greatly improved efficiency within the manufacturing, agricultural,
and energy sectors.  More efficient equipment and processes, and more
judicious use of natural resources and other inputs  -  whether energy,
chemicals, water, or pesticides - can help us to meet environmental
protection goals while saving raw material and other production costs'.  As
the Science Advisory Board  noted in a September 1990 report to EPA,

    . . . some pollution prevention techniques* like  using  energy more
    efficiently and recycling  process materials, can pay for  themselves
    quite apart from environmental considerations. One reason that Japan
    and Western Europe are formidable economic competitors is that they
    use energy and raw materials so efficiently. To compete in the global
    marketplace,  American   businesses  also   must  use  them  more
    efficiently.10

    Pollution prevention is grounded in two additional principles:

    • first, a multi-media focus, one that looks at all environmental media
    *   US. EPA. Science Advisory Board? Reducing Risk: Setting Priorities and
Strategies for Environmental Protection, September 1990 (SAB-EC-90-021), p. 22.
                                 •11-

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    tion •Prevention Strategy
      as a unified whole and avoids the potential transfer of risks from
      one medium to another, and

    •  second, a  comprehensive  evaluation of  the  total environmental
      impacts  of  products  over  their  entire  life-cycle,  from  the
      development of raw materials through manufacturing (including
      energy use) to use and ultimate disposal.

    First step in the risk reduction hierarchy

    Pollution prevention does not mean that we will  be able to eliminate
all wastes from all production processes.  Rather, it offers a meat c'-ct-
effective means of minimizing the generation of waste.  Another wty to
look at prevention (or  "source reduction")  is  as  the  first step in  a
hierarchy  of options for reducing the risks  to  human  health  and  the
environment from pollution.  The next step in  such a hierarchy would
be the responsible recycling of any wastes that cannot be reduced at the
source.  When recycling  is  conducted  in an  environmentally sound
manner, it shares many  of the same advantages as  prevention,  such as
conserving  energy  and other resources, and  reducing reliance  on raw
materials and the, need for end-of-pipe treatment or containment of wastes.
Wastes that cannot feasibly be recycled should be treated in accordance
with environmental standards that are designed to reduce both the hazard
and volume of waste streams.  Finally, any residues remaining from the
treatment  of waste should be disposed of  safely, to  minimize their
potential for release into the environment

    The  hierarchy  establishes a  set of  presumptions,  rather  than  an
ironclad rule.  Other practices,  such as treatment and proper disposal, can
also be protective  of the environment   Industries  can  be expected to
balance costs and benefits when evaluating prevention opportunities,
considering such  factors  as  savings  in  raw  material  and operating
expenditures,  avoided pollution control  costs,  reduced  liability,  and
improved relations with  local  communities.  EPA has the discretion to
require prevention under the Toxic Substances Control Act by restricting
the use of a chemical in  manufacturing or  commerce, but only after
balancing the full range  of costs and benefits.

    Why a federal strategy is needed

    EPA  recognizes that many  states,  industries,   and environmental
                                 •12-

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                                                   Pan I •  Imrodu&ioh
organizations have  advanced  the  cause  of pollution prevention for a
number of years.  While EPA has undertaken a number of successful
prevention actions over this period, it has not been the principal focus of
EPA's efforts.  Not surprisingly, therefore, there is a wide disparity in the
level of commitment to pollution prevention among firms that face EPA's
regulatory and enforcement actions.  Among the impediments to pollution
prevention contributed in pan  by EPA's orientation  are the following:

    •  Separation of production and environmental  decisions.  At many
      companies, environmental issues are divorced from the immediacy
      of  the production process.  Environmental compliance staff, for
      example, may have little influence in production decision-making.
      On  another  level, environmental  expenses may  not be  fully
      accounted  for in cost assessments  and  price  setting.   Some
      corporations account for waste management expenses and pollution
      control costs as overhead, rather than as costs incurred by distinct
      production processes.  In part, these failures reflect the limitations
      of  a regulatory tradition that focuses on controlling wastes  after
      their generation, a tradition that EPA must help to change.

    •  Absence of a long-term perspective.   Prevention  opportunities
      should   be  evaluated  taking   into   account  changes   in   the
      environmental climate that might reasonably  be expected to occur
      that could increase the  cost of compliance.  EPA has not always
      provided industry with  the  kind of advanced notice  of  potential
      regulatory action  likely to  affect  specific contaminants or  their
      sources  that   would  encourage  industry   to  make long-term
      investments in prevention.

    •  EPA's single-media organization. Finally, EPA's own single-media
      offices,  often  created  sequentially as individual  environmental
      problems were identified and  responded to in legislation,  have
      played a role in impeding development of cost-effective multi-media
      prevention strategies.   In the past, the use of flexible authorities
       such  as TSCA, innovative cross-media  settlements involving or
      promoting pollution  prevention,  and voluntary  agreements for
       overall reductions in releases have not been encouraged.

    Thus, a clear and coordinated federal  strategy for pollution prevention
is  needed both  to  remove the obstacles  of the past  and to foster
preventive initiatives  in the  future.
                                 -13-

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Pollution Prevention Strategy

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                                 Part n - Guidance to Programs, Reffrhs
                           PARTH

             GUIDANCE FOR EPA'S PROGRAM
                 AND REGIONAL EFFORTS
       EPA should anphasizt pollution prevention Of the, preferred
       option for reducing risk.              7>

       ~ Science Advisory Board, TteducinjRiak*, September 1990.,
   EPA's formal commitment to prevention  was signaled  with  the
creation of a Pollution Prevention Office in the summer of 1988.  The
directive creating the new office also called for the development of an
Agency Pollution Prevention Strategy, coordinated by a Subcommittee of
the Pollution Prevention Advisory Committee, with input from all EPA
program and regional offices.  The last two years have seen a vigorous
response  from EPA's program and  regional offices in incorporating
pollution prevention  into EPA's efforts. Successes include:

   •  holding  an Agency-wide competition  for innovative  pollution
      prevention projects, with awards made to 25 projects;

   •  setting  up the Pollution Prevention Information Clearinghouse,
      comprised of a hotline, document repository, and electronic bulletin
      board;

   •  coordinating development of rule-makings aimed at the pulp  and
      paper  industry to  focus on process changes  that eliminate  the
      formation of dioxins from bleaching operations;

   •  developing an active and innovative grants program to support state
      efforts in pollution prevention;

   •  establishment  of the American Institute for Pollution Prevention;

   •  developing a pollution prevention audit guide for use by industrial
                               •15-

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Pollution [Prevention Strategy  _ ~ *--  -   - ...  - -  .  ___     .      . v

      facilities; and

    •  building a database on prevention opportunities through use of
      statutory authorities to gather information.

These efforts  help to illusfcate the range of opportunities for building
prevention into existing programs and activities.  This section outlines:

    A. General principles that will guide the Agency's efforts to build
       upon these successes.

    B. Specific  activities  that  EPA  will  undertake  to apply  these
       principles to its
    C. EPA's plan for coordinating and improving the Agency's own
       institutional capacity to incorporate a pollution prevention ethic in
       its basic mission of protecting human health and the environment

A.  GENERAL PRINCIPLES

    The Pollution Prevention Act of 1990 requires EPA to "develop and
implement  a strategy  to  promote  pollution  prevention."   It includes
provisions directing EPA to set measurable goals, to consider the impact
of regulation on source reduction, and to evaluate regulatory and non-
regulatory barriers. The Act also amends the public reporting requirement
of Section  313 of SARA  to require industries to quantify the effect  of
source reduction,  as  well as  recycling and  treatment, in reducing
environmental releases  of toxic chemicals. EPA must report on national
progress in reducing these releases.

    EPA's  new responsibilities  under the Pollution  Prevention Act must
be integrated with its obligations under existing law, particularly under
recently enacted dean Air legislation.  For example, the Clean Air Act
require* EPA to establish technology-based standards for the control of air
toxics, tnd to take farther action to reduce any "residual risks" that remain
after these  standards take effect

    The Agency is also obligated under the Toxk Substances Control Act
to protect the public from "unreasonable risks" posed by the manufacture,
processing, or use  of toxic chemicals.  Finally, EPA must issue permits
that embody pollution control requirements, and take enforcement actions
                                -16-

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                                    Pan n • Guidance to Programs, Regions
against those who violate environmental law.

    Rather than propose expansion  of its authority under existing  law,
EPA's strategy is designed to encourage industries to take voluntary action
to identify  and exploit  cost-effective prevention opportunities.   These
voluntary efforts can serve two important purposes:

    • Reducing the cost of complying with mandatory requirements under
      the new. Clean Air Act and other laws;

    • Reducing  the need for  additional regulation under TSCA  or the
      "residual risk" provisions of the Clean Air Act

    Voluntary actions offer industry the advantage of maximum flexibility,
and  sufficient time to make economically sound changes in production or
use  of raw  materials.

    Cooperative strategies:  making the  most of voluntary efforts

    EPA  believes that* voluntary efforts have  a great potential to yield
change, based  on the following observations:

    • Pollution prevention  is often  in the self-interest of manufacturing
      enterprises, since it has the potential to save raw material (including
      energy),  reduce  present  and  future  waste management costs,
      minimize liability, and earn public goodwill.  Failure to realize this
      potential often results from lack of an adequate understanding of
      these benefits and costs.  EPA believes that where these factors are
      clearly understood, most businesses  will have a strong incentive to
      maximize the return  from prevention,  which in  turn will yield
      significant public dividends in the form of increased environmental
      protection.

     • EPA has also taken note of the substantial public commitments to
      prevention that have been undertaken  by  some  of  the nation's
      leading  manufacturers.   One  aim of this strategy is to create a
      climate  that encourages  such efforts, and persuades others to move
      forward without delay in instituting preventive approaches.

     EPA's  support  for  non-regulatory  approaches does not  mean the
 Agency  will  be a passive bystander,  rather,  it will pursue a  series of
                                  •17-

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Pollution Prevention Strategy
cooperative efforts with indusay-designed-to-improve understanding ofahe
costs  of pollution  and  the  benefits of prevention,  and  to  encourage
businesses  to  act  on  this  knowledge.   The  targeting of  specific
contaminants and the benchmarks for measuring progress discussed in Pan
m of this strategy will help to set clear expectations for industry and to
focus private sector initiatives  in  areas  of significant environmental
concern.

    Continuing need for strong regulatory and enforcement programs

    Of course, EPA will continue to promulgate and enforce regulations
require undf.* its various  statutory authorities tod those will provide a
further incentive  to prevent pollution by increasing its cost.  EPA will
coordinate  de velopir^nt of  these regulation; in 9 manner designed to help
industry identify  the potential for multi-medie prevention strategies and
technologies  that reduce  end-of-pipe compliance costs.

    When EPA determines  that specific regulatory actions are needed, the
Agency  will investigate  flexible, cost-effective  strategies  that  avoid
prescriptive approaches,  including market-based incentives that can  be
practically  applied and are authorized by law.  In particular, EPA will
make effective use  of new authority under toe Clean Air Act  to provide
credit for early reduction in air toxics emissions.   As an example of a
flexible approach, EPA recently exercised its statutory discretion to work
with several states to adopt regulations extending the compliance deadline
for companies that were  attempting to eliminate, rather than  control,
solvent  emissions from coating lines.

      A  strong enforcement program continues to create incentives for
pollution prevention; both as a means for a regulated entity to come into
compliance and as an additional set of measures beyond compliance which
may result in  EPA's mitigating  (but not eliminating) the penalty for
noncompliancc.   EPA will use its prosecutorial discretion to negotiate
enforceable  prevention   plans  with  facilities   that  have  violated
environmental law.  EPA believes most businesses have a strong incentive
to  push prevention  strategies far  enough  to  reduce  the  need for
enforcement  action.  The  strategy allows industry a greater measure of
control  in  avoiding die  costs  associated with these  coercive measures
through voluntary actions.
                                 -18-

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                                   Part n • Guidance to Programs, Regions
B.    FROM PRINCIPLES TO.ACTION

    The specific pollution prevention actions discussed  below illustrate
how EPA  intends  to  apply these principles in practice, rather than
representing an exhaustive list of activities.  The discussion is organized
around the following categories: identifying and overcoming barriers to
pollution prevention, expanding public participation and choice, working
with other federal agencies,  investing in  states, outreach and training,
regulation  and  permits, enforcement, and research and  analysis  of
substitute technologies and products.

    1.   Identifying and Overcoming Barriers

    •  Investigating the obstacles

    As  noted in the  introduction,  among the  obstacles  to  pollution
prevention  are some that may  be imposed by our current  regulatory
framework.  EPA is conducting a joint project with Amoco Corporation
(described in the box below) that  will identify whether such .regulatory
barriers exist and, if so, determine how they can be modified to encourage
implementation of more cost-effective strategies that promote prevention
and result in greater net reduction  of risk.

    Other barriers to the development, commercialization, and  use  of
innovative prevention technologies  will need to be overcome if effective
prevention technologies are to become readily available. EPA, through the
Office of Research and Development, the National Advisory Council for
Environmental Policy and Technology,-and  other programs, will continue
to identify and explore these and other barriers and develop appropriate
strategies to eliminate them.

    •  Breaking down barriers  with  technical assistance

    Lack of information and capital  are barriers  to pollution prevention,
particularly among small businesses.  Small polluters such as garages and
dry cleaning operations are often unaware of their polluting practices, or
of prevention opportunities.  They are also often likely to lack the capital
to invest in environmentally  sound  alternatives. (This can be true as well
of medium-sized firms that are  experiencing rapid growth.)

    Since many small businesses are unregulated, there is little incentive
                                -19-

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Pollution Prevention Strategy
      Amoco-EPA  Joint  Poirution Preventioit Project    Amoco
    COTpomioo acd EPA iป jointly carrying out * project to Wentiff existing
    %    -   . * ป *    *  "'...^ป^_'.S    * ^^^ s  i "•. ^ •  ~  ป_  v     '   j.   ^^
    ori
    AawcoY Ywta^^5^^i^^!^^l^^^^til **
    ffOOOOttOfPf^'SQF VOttVEDDHEflE' ~lli^K^iQBiVHcKซOF f

for them to  adopt  environmentally  sound management  or  disposal
practices.  Many small quantity generators of hazardous waste rely heavily
upon  recommendations  from  vendors and  suppliers  of  treatment
technologies in addressing pollution problems.  Such tools  as technical
assistance, financial assistance, and information sharing may be the most
appropriate drivers of small business self-interest

    EPA will work through state and local governments, trade associations
and directly  to promote  prevention among small  and  medium-sizsd
businesses. EPA will also help to develop networks between large and
small businesses to increase technology transfer*

    In addition to the state grants, the Agency already has in place several
tools to assist states and industry:

    •  Two percent projects.  At the federal level, an important infusion
      of demonstration projects is expected to result from the "2 percent
      prevention competition."  In 1989, EPA's Administrator rr 1e a
                               -20-

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                                   Pan II - Guidance to Programs, Regions
      major  commitment  of  Agency  resources  to  prevention
      earmarking two percent of FY 1991 contract dollars for innovative
      prevention projects.  During the summer of 1989, each EPA office
      competed   for  these   funds   with  proposals  for  projects.
      Approximately $12 million was available in the pool ($65  million
      worth of proposals were submitted) and a total of 25 projects were
      selected that are being implemented in FY 1991.

    •  Pollution   Prevention Information  Clearinghouse.    EPA's
      Pollution Prevention Information Clearinghouse is a multi-media
      clearinghouse of technical, policy, programmatic, legislative, and
      financial information dedicated to promoting pollution prevention
      through efficient information transfer.   The Clearinghouse is
      comprised  of  four  elements:    (1) a hotline; (2)  a repository
      containing texts, manuals, fact sheets, case studies, and legislation;
      (3) the  Prevention Information Exchange  System  (PIES),. a
      computerized conduit to databases,  information exchange,  and
      document   ordering, accessible  through  modem and personal
      computer; and (4) networking and outreach with users and a variety
      of national and international organizations.

    2.   Expanding Public Participation and Choice

    The growing  ecological consciousness of the American public has
sparked increased sensitivity on  the pan of consumers, corporations, and
governments  to the environmental consequences of their products and
behavior, as well as  an urgent need for more and better information on
environmental performance of  both consumer products and  industrial
facilities. The Science Advisory Board, as well as a recent survey by The
Economist, found that public information played a vital role in promoting
pollution prevention and reducing risk,  and the SAB concluded:

      "EPA should expand its efforts to provide information
      and to facilitate information sharing that helps
      individuals, businesses, and communities to reduce risk."

    •  Harnessing consumer buying power

    Recognizing  the  buying  power   of  environmentally  conscious
consumers,  many companies have begun  to  incorporate ecological
considerations in the  design  and  marketing   of products.    EPA
                                •21-

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Pollution Prevention Strategy

wholeheartedly supports this
trend,  which  demonstrates
how  a   dynamic   market
economy  can  serve  social
objectives    through   the
powerful   mechanism   of
consumer choice. However,
the    proliferation    of
advertising    claims   has
created    understandable
confusion among the
about tli, specific
of such  clair.is ss "ozone-
friendly,"  "biodegradable,"
and   "less   toxic,"   while
businesses have expressed
concern  about the cost of
having   to   comply  with
many    different   state
standards for environmental labeling.

    Accordingly, EPA plans to work with the Federal Trade Commission,
the Office of Consumer Affairs, and other federal agencies to explore the
possibility of establishing uniform national guidelines or standards for the
use of environmental terms in advertising.

    In  addition, EPA   is  testing methodologies  for   evaluating the
environmental consequences of consumer products (see box above).

    ซ ImpFovSag dots 8ฎ& developing fadleetoFS to txaestiFO progress

    Establishing dec? and  measurable indicators of progress in pollution
preveasjosi serves  a  numbs? of purposes:   it promotes accountability at
EPA, fcslps to focus the efforts of etch sector of society, and makes it
easier for the publk and Congress to understand and trcsk progress in
reducing pollution.

    Ideally, EPA could  track prevention by estimating reductions in risk,
e.g., by observing concentrations of targeted contaminants in air, ground
water, surface water, and soil samples as  they relate  to  exposures to
humans and ecosystems, and determining to what extent prevention efforts
                                 -22-

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                                   Part II - Guidance to Programs, Rซion$
                                                               •v? +V
reduced these concentrations. Unfortunately, because some contaminants
may persist in the environment for long periods after their initial release,
reductk." in discharges or emissions may produce no quantifiable effect
on pollution levels  in  the  short term.  In addition, EPA lacks data on
ambient concentrations of many pollutants and on the extent of human
and environmental exposures to such pollutants, in pan because regulations
under some environmental statutes are based on technology, rather than
ambient measurements.

    EPA is attempting to  fill  these  information gaps  by developing
"ecological indicators" designed to track the  rise and fall of pollutant
concentrations in the environment  In the meantime, practical limitations
will require EPA to identify alternate  means for measuring progress in
preventing pollution in the manufacturing, agriculture, and energy sectors.
                                                                9
    The Toxic Release Inventory (TRp established under Section 313 of
the Emergency Planning and Community Right-to-Know Act is the most
powerful tool available to EPA at the present time for tracking pollution
prevention  efforts from industrial sources. Section 313 requires certain
manufacturers to report the amount of each of the more than 300 toxic
chemicals listed in die Act that are released to the air, land, or water prior
to their treatment or off-site transfer.  The reporting requirements, which
will expand to cover more than 28,000 facilities nationwide fc* 1989 data,
apply to plants  that (1) employ at  least  ten persons;  (2) fall within the
manufacturing Standard Industrial Classification (SIC) Codes 20-39; and
(3) use at least  10,000 pounds or manufacture at least 25,000 pounds of
any  TRI chemical!

    Unlike any other  database. TRI permits the  tracking of chemical
releases at specific facilities on a multi-media basis. Because the database
is chemical specific, it may be easier to distinguish prevention  efforts
from treatment  methods that do not reduce releases  of  pollutants. (For
example, dewatering a particular waste stream may  reduce  volume, but
would not necessarily reduce the amount of die toxic chemical released
to the environment)

    The Resource Conservation and Recovery Act (RCRA) also requires
EPA to conduct a biennial census of hazardous waste generators.  These
results provide  information that can be  useful in evaluating prevention
efforts. There are limitations to applying the census data to multi-media
prevention strategies, since RCRA only applies to transportable hazardous
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Pollution Prevention Strategy
wastes (not including air and water discharges) and includes large volume
waste  streams  with multiple  contaminants that  are  difficult to  track.
However, the biennial reports could eventually provide EPA with more
detailed information on processes responsible  for generating particular
wastes, information which is not available through TRI.  In addition, the
Biennial  Report will  play  on increasingly important  role in measuring
changes  in  quantities of secondary hazardous wastes  (i.e., hazardous
residuals from .the treatment of either hazardous or nonhazardous wastes).

    The Ageiry will seek continually to improve  the qualify of the dar-
gathered  undu lo>l RGtA accS YRI, to impixwc the effesiiveaess of botli
profciUuS in tracking  progress  in  preventing pollution at  industripJ
facilities.    An  interagen'-y workgroup  will  lead  an effort  to  better
coordinate and, where possible, integrate TRI and  RCRA data.   In
addition,  the Office  of  Research  and Developmsnt  is  working on
developing a more comprehensive database, designed to measure pollution
prevention in sectors other than manufccturing (such as minerals, forestry,
etc.); identify the most useful indicators and units for measuring pollution
prevention ct ths source; determine whether the sants indicators and units
can  bs used csross different sectors; and identify relationships between
plant-level n&asuremsnts of pollution prevention and the combined effects
of prevention by multiple sectors at regional and national scales.

    3.   PdTiBcrsbip wttfe Federal AgGEdoo

    Other federal agencies can  play an important  fole  in  promoting
prevention through their policies, as well as by setting an example. EPA
is commat&d  to building a strong  wozMag  relattahip  with  the
DspoRBtsats of Agncutase, Energy, Transportatica, Defense, Interior, and
with otfcsr fedsrol ag^cies that have important juricdictioa ove? activities
that aSeซ &3 eavisxramsrti. In cMtica, SPA wiH WC3& wit& ageosies to
help ut5i ch&f&stesistics of pTodnctc  os  impOTicat coosid^QSica in
goveramsat proccresstsnt programs.

    4  Havestfao te> t&G Sfia&os: BuU
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                                    Pan n • Guidance to Programs, Regions
governments and playing a key role in technical assistance and technology
transfer.   Through  its Pollution  Prevention Incentives  for States grant
program, EPA is  promoting the establishment  and expansion of  state
multi-media pollution  prevention programs, and  is  testing  innovative
pollution prevention technologies and applications at the regional and state
level.

    In FY 89 and FY 90, EPA awarded a total of $11 million to 40 state
and  interstate  organizations to conduct demonstration projects, provide
direct technical assistance to industry, businesses, and local governments,
and institutionalize multi-media pollution prevention as an environmental
management priority.

    In FY  91, EPA will target  grant funds to specific sectors or areas
with  a  high potential for risk  reduction  and  for significant gains  in
pollution prevention. EPA will evaluate state programs to determine what
has and has not been successful at the state level and why, and will begin
to integrate this analysis  into  a long-term  strategy that defines the
appropriate relationship between federal and state  roles  in implementing
multi-media pollution prevention. In addition,  EPA will begin to identify
areas in its media-specific  grant programs where pollution prevention
concepts and methodologies can be integrated.

    5.   Outreach and Training:  Achieving a Cultural Change

    On a still  broader basis, EPA will be seeking  to lay the groundwork
for  a pollution  prevention orientation  within  government,  industry,
academic institutions, die public, and internationally through a variety of
outreach and  educational  initiatives.   These  include  EPA's  Pollution
Prevention Information Clearinghouse, various technical and non-technical
resources,  including Pollution Prevention Afcw,  booklets on  industrial
prevention techniques, and video presentations on pollution prevention, and
the  development of curriculum materials  on pollution  prevention for
kindergarten through university levels.

    Training is needed to help institutionalize prevention as the strategy
of choice in all environmental decision-making  and  protection activities.
In addition to developing  a training resource guide, a 30-minute video
documentary,  and cosponsorship of conferences and workshops, die Office
of Pollution Prevention is developing  specialized courses designed for
government employees and industry.   The  courses will be available
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 Pollution Prevention Strategy
 through the EPA regional offices starting in 1991.

     6.   Regulation and Permits

     As discussed previously, EPA will seek to strengthen the ability of the
 existing regulatory framework to provide further incentives for prevention.

     •  Toxic Substancts Control Act: evaluating costs and benefits

     EPA has rrthc"*ty u^u the Toxic Subs&ftccs Control Act to limit
 the use of a c- . X'  s '•    ^ h.cpiu^/ii* m manufacturing, when
 these  substAT >   pis  ?   (u . > • ซoi* >hlo risK to  humm health.   In
 determining wi- ,-'iO:: ar tioE if v/ti/aitui against p&u&uU? risks under  that
 law, EPA balances the full laugc; of costs and be&efits.
     •  Regulatory clusters:  applying more cost-effective approaches

     EPA believes that pollution prevention can provide a cost-effective
 alternative to traditional treatment technoloi 'es, particularly when the long-
 term cost of complying with a series of regulatory requirements is taken
 into account  The Agency is categorizing the rules it intends to propose
yover the next two to three years according to the manufacturing and non-
 manufacturing sources that will be affected.

     These  regulatory clusters  will  permit  accurate  evaluation  of the
 cumulative impact of standards  affecting specific industries over time,
 which in turn should encourage early investment in prevention alternatives
 that avoid the expense of  installing and operating treatment  facilities.
 Providing industry with,   ivance notice of regulatory actions establishes
 a suitable framewoffc for negotiating prevention alternatives that might not
 be  considered on a short-term basis.  Needless to say, the clustering
 project will not be allowed to impede statutory or court-ordered deadlines,

     •  Early reduction* under the Clean Air Act

     The dean Air Act provides a significant opportunity for pollution
 prevention by offering credit for "early reductions" of toxic air emissions.
 More specifically, industrial sources can obtain a six-year extension from
 compliance with  Maximum Achievable Control     hnology standards if
 they:
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                                   Pan n • Guidance to Programs, Retftms
      - achieve reductions of 90 to 95 percent below a baseline year (no
      earlier than 1987) before such standards are proposed, or

      - enter into enforceable commitments to  achieve such reductions
      by January 1,  1994.

    •  Permits:    EPA  will  promote   cost-effective  alternatives  to
      conventional treatment alternatives

    There are substantial opportunities to explore source or use reduction
alternatives during the negotiation or reissuance of environmental permits.
Prevention approaches may  be more  cost-effective  for  meeting the
regulatory requirements of existing statutes  than traditional treatment or
disposal  methods.    EPA will work  with  industries  to  identity such
opportunities when developing or renewing permits.  Where authorized by
law, EPA will give preference to performance standards that maximize the
range of choices for  permittees.

    In  many circumstances,  prevention may require application  of new
processes or technologies.  Development of these  innovative solutions may
in turn require  a  specialized  permitting process  designed  to expedite
testing and operation. The National Advisory Council for Environmental
Policy  and Technology, a panel of experts  from government,  academia,
states,  and  public  interest  groups,  in  its  advisory  capacity  to the
Administrator, has pointed out this need and suggested several ways to
foster technology innovation  through permitting (and compliance). These
include (1)  designing effective processes to issue permits for testing
innovative prevention technologies; (2)  coordinating reviews  of permit
applications  in  the  context  of  cross-media impacts and  prevention
potential;  and (3)  expeditiously  and  consistently  reviewing permit
applications  for early  commercial  uses  of  innovative  prevention
technologies.  All of these steps will need to be augmented by technical
support to permit writers, permit applicants,  and  the public, if they are to
be
    7.  Enforcement:  Incorporating Prevention into Settlements

    Vigorous enforcement remains a primary tool for creating an incentive
to reduce  industrial pollution.  Pollution prevention can help private
industries avoid some of the costs  of complying with federal  and  state
requirements for the treatment and management of pollutants and the
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Pollution Prevention Strategy
liability costs that  result from noncompliance.   Enforcement generally
creates an environment in which permanent solutions, such as eliminating
some pollutants entirely, may be preferred to less reliable approaches to
compliance.

    EPA's Office of Enforcement is currently developing an interim policy
on the inclusion of pollution prevention Conditions in Agency enforcement
settlements.  The policy, expected to coke effect in  FY  1991,  will be
applicable to  both  administrative actions and. civil judicial settlements
negotiated in conjunction with the Deparaneai of Justice.  It encourages
the  inclusion  of  single-medL  or  cross-medik pullmjoc  prevention
conditions, as either the means of corr^tfag the* violation or as additional
conditions incidental to injunctivt relief, especially when  they offer the
best chance of avoiding recurring or  future violations, have no negative
cross-media impacts, and technologically and economically feasible options
exist   Consistent  with  EPA policy, civil penalties, which reflect  the
gravity  of the violation  and the economic benefit of noncompliance, will
continue to  be a mandatory component of the settlement

    EPA has concluded several successful pollution prevention settlements
in FY  1990 (see box on next page) and expects the number of such
settlements to increase in FY 1991 and beyond.

    8.  A Research Strategy for Prevention

    Research is the primary vehicle for enhancing our pollution prevention
knowledge  base.   EPA has committed  substantial resources  toward
pollution  prevention  research and,  through  its  Pollution Prevention
Research  Strategic  Plan, has established  t "blueprint" for future Agency
research efforts. The research strategy iithe culmination of efforts of the
Office  of Research and Development  to  identify* set priorities, and
coordinate its  research  designed  to  increase pollution prevention and
implement a cooperative program to conduct this research.  It is designed
to provide the scientific and technical knowledge necessary to implement
pollution prevention initiatives on a cross-media, cross-program basis.

    In the short term, research will be directed toward development of
specific  prevention strategies for individual  contaminants, clusters of
contaminants or sources  targeted in the industrial toxics project (see Pan
m  below).   Longer term efforts will focus on approaches to  address
problems  outside of ^manufacturing sector and on research designed to
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                                   Pan n - Guidance to Programs. Regfew
      Pollution Prevention Settlement   > •ป  ,'f %:' ' ' <$-*< *,
      Shtrcx
      a. TSCA dva irimtntOTMive
                                                           The
                                                     ป
undenomd and overcome sociil and insdtntional obstacles to pollution
prevention.  This research is  intended to promote  cultural change by
which prevention will become an integral part of public programs and
private activities.

    9*   Looking Ahead: Emerging Products and Technologies

    EPA's  strategy  will  also try to identify and avoid  environmental
problems  before they  arise,  by  encouraging development  of  safer
substitutes  for hazardous raw materials or products, as well as cleaner
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Pollution Prevention Strategy  .            _

technologies. The  Office of  Toxic Substances (OTS) currently has
authority under  TSCA to require the testing of chemicals  to  identify
potential  hazards.   OTS is  beginning to focus these  testing rules on
clusters of chemicals that share similar characteristics, or that are used for
similar purposes. This will allow comparison of the relative risk of all
chemicals in the cluster, to  ensure  that  EPA policies  do not result in
industries reducing, their use  of specific toxic chemicals  by switching to
equally hazardous substitutes.
             •
    EPA  also is sponsoring an innovative  "anticipatory research" program
through the Office  of Research a>/ Develepuimt that  concentrates on
emerging technologies that could pi"vcif"o i/da*? fabife problems.  The
Agency's objective is to ideotify aik' exploit  u.-ugiiifc technologies and
patterns in resource  use and dispose! that  have long-toui implications for
the nation's programs in pollution prevention.

C.  PROMOTING  INSTITUTIONAL CHANGE AT EPA

    EPA's strategy must confront institutional barriers within the Agency's
own organization that limit  its ability to develop effective prevention
strategies.    Most  fundamental is  the  Agency's  compartmentalized
organization, a reflection of the single-media orientation of most of the
environmental statutes under  which EPA  operates.   The  Agency
regulatory development and review process has historically tracked eacn
regulation individually, with little effort to link rules related to the  same
contaminant or  industry.  In addition, EPA's performance measurement
and incentive structures do  not explicitly  reward  or encourage multi-
media  or cross-program efforts.

    EPA  has  identified  four distinct  requirements  for  promoting
institutional change  within the Agency:

    • Gear commitment from management to establish  prevention as a
      priority and to establish  common definitions to guide programs.

    • Promoting cooperation among program and  regional  offices by
      improving communication and motivation.

    • Providing resources and training to support regional and program
      initiatives in pollution  prevention.
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                                   Pan Q • Guidance to Programs, Regions
      Integrating pollution prevention into the Agency's strategic planning
      process.
    Clear commitment from management

    The EPA Administrator's commitment to prevention as a priority was
made clear with the establishment of an independent Pollution Prevention
Office in 1988 and the  accompanying directive.  After broad consultation
with public interest groups,  private industry, members of Congress, and
others, EPA  is preparing to publish  a final policy  statement defining
pollution prevention and placing it at the top of the hierarchy of preferred
environmental practices (as discussed on page 12).  The policy statement
as well as this strategy help to signal a prominent role for prevention in
the  context  of  EPA's  mission to  protect  human  health  and .the
environment

    Working together:  improving communication and motivation

    EPA has taken the first  step in improving cross-program cooperation
by establishing an Agency-wide Pollution Prevention Advisory Committee,
comprised of representatives  from program and regional offices. EPA will
take the following steps to encourage programs  to  work together in
developing multi-media prevention strategies:

    • Designate  special  assistants  for pollution prevention  in each
      Assistant Administrator's office-to coordinate activities within that
      program;

    • Establish cross-media workgroups to identify clusters of rules that
      affect  a  particular  contaminant or industry,  and to  explore
      opportunities to promote pollution prevention through coordinated
      rulemakinR

    • Develop incentives to encourage Agency staff and  managers to
      engage in pollution prevention efforts and to think creatively about
      prevention opportunities (e.g., individual and program performance
      measures,   awards   for  cross-rnedia/cross-program  prevention
      approaches);

    • Incorporate prevention as a primary  tool for achieving program
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Pollution Prevention Strategy
      goals within the comprehensive 4-year strategic plans now btiflg
      prepared by each program and regional office (see below;;

    •  Include prevention-related  activities in the  Agency's operating,
      guidance, accountability measures,  and  regulatory review  and
      development process;

    •  Identify the steps needed to foster technology innovation through
      the Agency's regulatory and  administrative  processes,  including
      pei nutting, compliance, and  procurement.

    Provide resources for prevention and trail to j

    Through  the Office of Pollution Prevention, EPA will continue to
provide resources  and expertise to  help program and  regional offices
identify and exploit opportunities for prevention. As noted earlier, this
will include training for Agency staff to ensure integration of prevention
concepts into permits, inspections,  and enforcement  settlements.

    Pollution prevention  and strategic planning

    In 1989,  EPA began requiring each program and regional office to
develop a strategic plan to set clear, forward-looking priorities for the
Agency.  Headquarters and regional offices are increasingly using strategic
planning to target resources to problems  posing the greatest risks to
human health and the environment, and on approaches with the greatest
potential for reducing those risks.  Pollution prevention is meant to be the
central feature of these strategic planning efforts - the strategy of first
choice.

    The priorities set forth in programs' long-term strategic plans should
drive  annual   operating   planning,  budget  formulation,   program
implementation, and management  tracking systems.   Because pollution
prevention is to be a fundamental component of each program's strategic
planning efforts. Agency managers  will, over time,  devote  increasing
resources and attention to the prevention aspects of the programs they
manage.
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                                        Pan nt • Industrial Toxics Project
                            PARTIH

               INDUSTRIAL TOXICS PROJECT
     fa America HotMnt to
     A-Survey:>

     ^n7&&^*M^K-ฃ3&.'
    This section reviews EPA's plan for targeting certain toxic chemicals
for which focused prevention strategies will be developed.  EPA's goal
will be to reduce aggregate environmental  releases  to  all media from
industrial facilities of these targeted chemicals, as measured by the Toxics
Release Inventory (TRI) in 1988, by 33 percent by the end of 1992  and
at least SO percent by the end  of  1995.   EPA will  measure success
according to whether its goals have been achieved on an aggregate, multi-
media basis, rather than for each chemical, industry sector, or company.
The Agency is principally targeting contaminants that will be  regulated
under  the  provisions  of the Gean Air  Act to ensure that companies
participating in this voluntary program are also eligible to apply for credit
under  the  "early  reduction" provisions of mat law.  The Agency's 33
percent and 50 percent multi-media reduction goals are reasonable, given
that the dean Air Act is expected to eventually result in reductions of up
to 90 percent  in the air emissions of most contaminants.

    EPA will  also seek to identify significant exposures of these targeted
chemicals  that may arise from commercial or consumer uses of such
products, and  develop appropriate strategies for their prevention. While
the project outlined in this  section is limited to toxic chemical releases
generated  from industrial  activities, 'EPA  intends to work with other
federal agencies  to develop similarly  focused  prevention strategies for
energy, agriculture, municipal water and wastewater, and other economic
                                •33-

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Pollution Prevention Strategy
sectors which may target both toxic and other pollutants for reduction.

    The value of the specific project outlined here, as well as the ones
that EPA  will subsequently develop, lie in:

    •  bringing focus and visibility to EPA's prevention program,  which
      in turn promotes accountability for results;

    •  helping to set clear expectations for industry  and other affected
      parties  regarding the need to reduce  releases  of certain high-risk
      contaminants;
            , -  .                                                    •
    •  committing individual program offices to worfr togc the  to develop
      comprehensive, multi-media appro&ohw to specific ei>vuvuki*au!
      problems; and

    •  providing a model that, if successful, could guide efforts throughput
      the Agency.

    The industrial toxics strategy marks a new approach by EPA  to
encourage voluntary action  by industry  that  minimizes the  need for
intrusive federal regulation. The program depends for its success on the
willingness  of companies  to participate, and  this  section  sets forth
principles for implementation that  are designed to elicit that cooperation:

    1) As the program is voluntary, non-participation by a company will
not be the basis for delaying benefits, such as discharge permits, to which
the company is  entitled by law.   At the same time,  of course,  the
voluntary effort will not be allowed to interfere with fulfillment of the
Agency's   responsibilities,  timetables  for  action,  and  enforcement
obligations, including those under  the new dean Air  Act

    2) EPA will not turn voluntary commitments into enforceable permit
conditions without  that company's consent,  to  the extent  that  those
commitments  go beyond that company's obligations under the law.

    3) EPA will measure success according to whether its goals have been
achieved on a nationwide, aggregate basis, rather than for each chemical,
industry sector, or company. Companies  that participate in the program
will have  the flexibility to propose their own goals, and to determine how
best to achieve them.
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                                         Pan HI - Industrial Toxics Project
    4) EPA will work with industries to ensure that any initiative taken
to reduce emissions  ahead of statutory schedules receives  appropriate
credit toward complying with any subsequent regulatory requirements.  For
example, while 1988 provides the base year for measuring overall progress
toward meeting the goals, EPA will explicitly recognize any results  that
companies have achieved since 1987, the first year for which TRI data are
available. This will ensure that efforts made under the voluntary program
are eligible  for  credit under  the Clean  Air Act's "early reduction"
program, which provides a six year extension from compliance with new
technology-based standards for those companies that reduce emissions 90-
95 percent from a base year no earlier than 1987.

    5) EPA  will work with companies to identify and  (to the extent
authorized by law) eliminate barriers in existing  permitting systems to
cost-effective prevention.

    EPA  is  hopeful  that  this  voluntary effort will inspire proactive,
innovative responses from  the private sector, which would help to build
trust  in  industry's willingness  to respond to  the public  demand for
environmental  protection.   This,  in  turn,  would make it easier to
investigate those barriers  in existing law, regulations, and permitting
practices that inhibit cost-effective solutions to, environmental problems.

    EPA's prevention project for  industrial toxics will have four basic
components:

    A. Targeting.  EPA will identify 15 to 20 pollutants from the Toxics
       Release Inventory  that present  both significant risks to  human
       health and the environment, and opportunities to reduce such risks
       through prevention.  As discussed previously, EPA will principally
       target those contaminants also subject to new dean Air  Act
       requirements to ensure that participating companies can apply for
       credit under the provisions of that law for any voluntary reduction
       in toxic air emissions.

    B. Outreach*    The  Agency  will  seek  voluntary,  measurable
       commitments from industrial sources of  these contaminants to
       reduce  environmental releases through prevention.

    C. Organizing for Action. EPA will form cross-media workgroups
       to provide analytical and technical  support for the outreach
                                 -35-

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Pollution Prevention Strategy
       program,  and  to   refine  prevention  strategies  for  targeted
       contaminants.

    D. Measuring  Progress.  The Agency will  use TRI  to  measure
       progress in achieving the  33 and 50 percent reduction goals.

A.  TARGETING

    As the Agency is responsible  under many federal laws for protecting
public health and the environment from toxic pollutants, it is appropriate
that EPA's prevention strategy begin with a plan  to reduce releases of
these contaminants.  The Science Advisory Board's recently completed
report conclude*?  that toxic chemical exposure among plant workers and
the general public represented two of the four most serious threats to
human  health  from  environmental  causes,  while  also  contributing
significantly to the degradation of the ecosystem.

    EPA has not estimated the benefits  of this  strategy, given that it is
voluntary, and given  the uncertainties regarding participation of companies
in the project and the specific reductions that such companies will choose
to undertake. Although costs are similarly uncertain, the purely voluntary
nature of this demonstration project ensures against adverse cost outcomes,
as companies can be expected to balance costs and  benefits on their own
in determining  their  level of participation.  Had EPA chosen to embark
on  a  regulatory program, however,  a more thorough analysis of the full
range of costs and  benefits would have been  used to select program
objectives.

    While t formal cost-benefit evaluation is inappropriate to a voluntary
program,  EPA's  selection of  target  chemicals will  reflect a rational
evaluation of both risk and cost-effectiveness of prevention.  The list of
15-20 chemicals will be drawn  from  recommendations  submitted by
program offices, to  ensure it has practical relevance to day-to-day
operation*.  Program office recommendations will,  in turn, be guided by
the criteria outlined  below,  which are designed to  reflect both risk and
opportunity for prevention.

    • Risk to human health and the environment, taking into account the
      risk of  cancer, chronic non-cancer health  effects, reproductive,
      developmental, and neurotoxic risks, and die potential  for toxic or
      non-toxic ecological damage.   In addition to  laboratory data, risks
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                                     Part 01 • Industrial Toxics Protect
                                                                -
  will be evaluated by considering (1) the extent to which particular
  contaminants  threaten the  attainment of  ambient air and water
  quality standards at specific locations, and (2) whether the volume
  of  releases of a  particular contaminant to the environment  are
  significant enough  to warrant concern.

• Multiple exposure problems.  Some chemicals pose environmental
  problems in both their manufacture and their use. For example, the
  production of certain chlorinated solvents may result in the release
  of  toxic, ozone-depleting contaminants  during  the manufacturing
  process.   But  chlorinated solvents  tend to  vaporize  at room
  temperatures, so  their  use  in  degreasing operations at small
  industrial facilities or in other dispersed applications may lead to
  a second round of releases of the same contaminants.

• Cross-media contamination. Some contaminants, particularly toxics,
  present problems in more than one medium.  Since nature does not.
  recognize neat jurisdictional compartments, these same contaminants
  are often transferred  across media.  For example, an estimated SO
  percent of the heavy metals  in the Great Lakes results not from
  water discharges but from airborne deposits.

• Geographic  location.   The  Agency will  also use  geographic
  information systems, in conjunction with Toxic Release Inventory
  data, to identify specific ecosystems where contamination from toxic
  chemicals is  particularly acute as well as areas of high risk to
  public health or the environment, such as wellhead protection areas.
  The Agency will assess  the extent to which  contaminants  are
  responsible for causing toxic "hotspots" in particularly productive
  and sensitive ecosystems.

• Limitations of treatment technology or disposal capacity.  Some
  contaminant! stubbornly resist traditional end-of-pipe fixes.  Heavy
  metals, for example, cannot be thermally or biologically destroyed,
  and must be separated from  emission  gases  with electrostatic
  precipitaton or scrubbers,  or from industrial wastewater through
  chemical  precipitation.    Since metals  do not biodegrade,  the
   incinerator ash or sludges that result must be contained in landfills
   over long periods of time at  considerable expense.

•  Pollution prevention opportunity.  As an initial screening exercise.
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Pollution Prevention Strategy *
      EPA*s Office  of Toxic  Substances v  \ compare TRI releases to
      production volumes of each of the tc  100 produced chemicals in
      the United States.  Where a high percentage of a specific chemical
      is released to the environment relative to its production, there may
      be  significant  opportunities to  prevent  releases through more
      efficient manufacture or use. Other information may also be used
      to establish the technical or economic feasibility of prevention for
      specific  chemicals,  such  as  case  studies  from  the  po;  ion
      prevention clearinghouse,  or  data from the  voluntary  waste
      minimization forms submitted by some companies under TRI.

    •  As discussed  previously,  EPA  will  principally  target those
      contaminants riso  subject to new Gean Air Act requirements, to
      ensure that participating companies can apply for credit under the
      provisions  of that  law for any voluntary  reductions  of air toxics
      emissions.

    The Agency is sensitive to the fact that there may be  opportunities
to achieve reductions in large numbers of toxic contaminants not on the
target list, through changes in specific  industrial processes.   For that
reason, EPA will evaluate options for identifying  particular industries and
facilities responsible  for  releasing high volumes of TRI chemicals that
pose a significant risk, and crafting appropriate prevention strategies. The
targeted chemicals may also be released in significant quantities by non-
industrial  activities not  subject  to TRI reporting.   The cross-media
workgroups  discussed  below will  evaluate the  extent  to  which these
releases are  derived from the commercial or consumer uses of chemical
products, and recommend appropriate strategies.  It should be noted that
TRI covers many small plants and extends well beyond traditional "point
source"  measurement on  which EPA has relied in the past  by recording
chemical releases from production activities, such as solvent decreasing
operations.

    The- Agency  also recognizes mat there are  limitations to the TRI
database;  its plans for overcoming  these are  discussed below  under
Measuring Progress.

B.  OUTREACH

    As noted above, EPA's goals are to   duce TRI releases of targeted
contaminants by 33% by 1992, and by at least 50% by 1995.  This section
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                                        Put ni • Industrial Toxics
briefly reviews  EPA's plans  for  outreach  which  will  challenge  the
responsible industries to help meet these goals.

    As a first step, EPA will use TRI to identify major industrial sources
of toxic chemical releases to the environment.  EPA intends to produce
a detailed plan for contacting these facilities or their parent companies to
ask them for voluntary, measurable commitments to reduce releases of
targeted contaminants to the environment and to identify how it will carry
out these commitments.  The  plan, which will be developed by a Task
Force comprised of representatives of EPA programs and regions, will be
guided by the following considerations:

    •  Companies will be encouraged to identify and exploit technically
      and economically feasible prevention alternatives. Awards will be
      provided to facilities with the best plans, and those with the best
      performance in preventing pollution.

    •  Individual companies are free to propose their own goals. In order
      to  make the most  effective  use of  resources, EPA will  initially
      direct its outreach program toward companies that emit significant
      amounts of the targeted chemicals.

    •  EPA  will work with companies to  address regulatory or permit
      barriers and, where appropriate, to  provide credit for voluntary
      actions that meet regulatory requirements.

    •  EPA will make every effort to coordinate contact with industry to
      eliminate redundancy OTd paperwork.
       EPA headquarters will be  contacting the  companies  and will
       coordinate among regions and with states to eliminate duplication
       or confusion.   EPA  headquarters  and  regions  will  both  be
       represented on the Task Force drawing up the implementation plan.

       The Agency will target technical assistance using case studies from
       the Pollution Prevention Information Clearinghouse, and information
       from other sources. The cross-media workgroups discussed below
       will  provide  the  basis for expanding the  Agency's  technical
       knowledge regarding pollution prevention opportunities for primary
       industrial sources.
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Pollution Prevention Strategy
    •  The outreach program will not be  allowed to interfere with
      fulfillment of the Agency's statutory responsibilities (including
      timetables for action) and enforcement obligations.

    EPA expects good response

    There are several  reasons  why  EPA believes  that industries  will
respond by volunteering pledges to substantially reduce releases of toxic
wastes to the environment through pollution  prevention:

    •  Earlier this year, EPA's  Office of Air and Radiation asked nine
      companies representing 40 individual facilities to submit plans to
      reduce air emissions of several toxic pollutants including butadiene,
      a chemical thought to cause cancer. The response was uniformly
      positive.  The nine companies  contacted have  submitted plrJis
      pledging reductions of more than 80 percent overall of specified
      toxic emissions within  one to three years.

    •  When EPA's Office  of Solid Waste asked azo-dye manufacturers
      to develop a waste minimization program for their industry, the
      response was  immediate  and proactive.   EPA's Office of Toxic
      Substances has had  similar success in  persuading industries to
      improve management practices to reduce the use or environmental
      release of toxic chemicals.

    •  Many  companies  have  already undertaken substantial  public
      commitments  to  reduce  the release  of TRI chemicals.   The
      Chemical  Manufacturers Association has  adopted  a  Code  of
      Responsibility asking member  firms to reduce emissions of both
      TRI chemicals and RCRA wastes.  According to  The Economist:

          "Complying with Tide m was an  eye-opener for many
          chief executives  ... quite apart from opening eyes,
          the information  hat American companies are compelled
          by law to collect has become a formidable management tool
          It allows chief executives to  set goals for subsidiaries."
    •  As discussed previously, EPA will remove t contaminant from the
      target list if sufficient progress is made in reducing its release to
      the environment    TTiis  should  provide  added incentive  to
      voluntarily reduce  its release to the environment
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                                        Part HI • Industrial Toxics Project
    •  EPA's clustering project, discussed further below, will be designed
      to fcwti* attention on the long-term  costs  of  failure  to  reduce
      environmental exposures of targeted toxic pollutants.

C.  ORGANIZING FOR ACTION                             ,

    Once the target contaminants have been identified, EPA  will form
cross-media workgroups,  comprised of  representatives from different
program offices.   Depending on what seems most appropriate, these
workgroups may be organized around a single contaminant (e.g., lead), a
related  group of contaminants (e.g., heavy metals), or  a  category  of
sources (e.g., primary and secondary smelters).

    The workgroups will be charged with providing technical support and
analysis for EPA's outreach (described above), and with coordinating the
Agency's goal of reducing releases of targeted toxic contaminants.  The
Office of Pollution Prevention will provide staff support although program
offices will also be expected to provide resources as needed. Workgroup
activities will include the following:

    •  Analyzing Prevention Opportunities. The targeted contaminants
will be selected based in pan on an initial screening of opportunities for
prevention.   The workgroup will  be charged  with  developing more
detailed technical information about these opportunities, and with building
expertise regarding the characteristics of industries identified as primary
sources of  the listed toxic chemicals.  This responsibility will include the
very  important  task  of evaluating ^industry  voluntary efforts,  and
determining whether proposed reductions would replace target chemicals
with equally  hazardous substitutes.

    •  Characttrizinf Non-Industrial Sources. As discussed above, TRI
data can be  used to quickly pinpoint industrial  sources of the targeted
contaminant*  The workgroup wili be responsible for identifying releases
to the environment from non-industrial activities not covered by TRI,
which may include small commercial establishments such  as garages and
dry cleaners, and the use of household products by  consumers. This
analysis will  help the Agency to develop appropriate strategies to reduce
the release of targeted toxk chemicals from non-industrial activities.

    The Agency  believes that prevention strategies are  most likely to
succeed where they have the support of the affected parties. Accordingly,
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Pollution Prevention Strategy
EPA's workgroups will be expected to meet with representatives  of
industry and affected  sources to review data regarding the t  momic and
technical feasibility of prevention  options.   Environments   uid citizen
groups will also be consulted.

    •  Defining Regulatory Clusters.  The Agency has already begun to
identify clusters of related rale-makings in an effort to coordinate control
strategies where a contaminant or industry can expect to be  regulated
under multiple statute* ovti a two to three year time period,  or where
there  art cross-cutting  policy issues.  For example, regulatory clusters
have  been identified  for  heevy  metals,  for issues  relating to  the
exploration and pvo&ictioii  of oil  and g&s, and for source separation  of
solid wastes. Workgioups will be expected to identify regulatory clusters
for targeted contaminants,  to  the  extent these have not already  been
developed  and to the extent allowed by schedules imposed by  Congress
and the courts.

    These clusters  will serve a number of useful purposes. First, they will
help ensure that cross-media transfers of pollutants are not  encouraged
under any  of the regulations.  In  addition, by  focusing the attention  of
EPA and affected  parties on upcoming regulations, they will provide  an
incentive to negotiate cost-effective prevention opportunities.   For  their
part,  EPA's offices  will need to confront how  prevention can most
coherently  and effectively be integrated into the variety 01 rule-makings
affecting a specific contaminant or its sources.

D.  MEASURING PROGRESS

    EPA will  rely on data  from the  Toxic Release Inventory  (TRI)  to
track  reductions in  releases of targeted contaminants from  industrial
facilities.   The Agency will develop  more appropriate indicators from
sources not covered by TRI.

      At this time, TRI is  the  only available database  that permits the
tracking of chemical releases at specific facilities on a multi-media basis.
EPA  has three years of experience collecting  TRI data,  which can  be
sorted and  analyzed according to chemical, industry, facility, geographic
location, and  other criteria.  Furthermore,  TRI is  already  being  used
widely by  industry, the states,  and environmental groups as a scorecard
for prevention efforts.  For  example:
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                                        Pan ni. Industrial Toxics Project
    •  Major corporations  such  as Union Carbide, Monsanto, Dow,  and
      AT&T are already using TRI to measure the  success  of  their
      existing prevention efforts and to set future goals.

    •  Several  states  have used  TRI  as the basis for a  number of
      legislative efforts.   Louisiana has  a law mandating a 50 percent
      reduction in toxic air emissions by 1994; Massachusetts and Oregon
      have enacted similar  laws.   New Jersey  now requires rums to
      submit with their TRI data additional information about pollution
      prevention  practices.  Other  states have instituted a fee system
      based on TRI emissions to provide an economic incentive to reduce
      emissions.

    •  TRI data has been extensively analyzed by interest groups such as
      the Natural Resources Defense Council and the National Wildlife
      Federation, to evaluate prevention programs at specific facilities.
      The non-profit National Institute for Chemical Studies has created
      a scorecard out of TRI data for the chemical industry in Kanawha
      Valley, West Virginia.

    EPA  recognizes  that the  TRI  database  suffers  from  significant
limitations.  For example, it does not cover all pollutants or all sources.
While TRI includes many small industrial plants, it does not cover small
commercial enterprises, such as dry cleaners or garages, that make a
significant contribution to environmental problems.

    In another limitation, companies that are subject to TRI are required
only to estimate their releases of specific chemicals to the environment
after recycling, treatment or disposal,  making it difficult to determine
which reductions are derived from changes to the production process or
reduced use of toxic raw  materials.  Furthermore, in the first few yean
of  TRI  data  collection,  some of  the changes in reported releases
undoubtedly reflect  changes in  reporting or record-keeping practices
(although this is expected to improve in the near future).
    The Agency is taking steps to address these shortcomings by:

    • improving other databases, such as the waste minimization surveys
      required under RCRA, so that these may provide a better measure
      of pollution prevention opportunities and activities.
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Pollution Prevention Strategy .
    •  exercising authority under Section 313 of SARA to add chemicals
      to the TRI list  While the current statutory list includes all of the
      high volume toxic releases,  it does not include every chemical of
      concern. This fall, EPA will propose adding 13 new substances to
      TRI.   EPA will  also  consider  exercising  its  authority  to  add
      additional SIC codes subject to TRI reporting requirements.

    •  amending the TRI reporting  form  to require all facilities to provide
      data  quantifying  the  effective *es* of preventive measures in
      reducing wastes prior to recyclibg, treatment, or disposal.   About
      20 percent  of the firms subjta to TRI currently  provide  this
      information on a voluntary basis.

    •  building a  comprehensive  database to  measure  and evaluate
      pollution prevention across a  broad spectrum of industrial  and
      nonindustrial activities.

EPA will work with the National Oceanic and Atmospheric Administration
and other federal agencies to  make effective  use of existing sources of
environmental data. These efforts will help move the Agency toward the
kind  of  broad  information  base important to  the development of
comprehensive pollution prevention strategies.   In the meantime.  TRI
provides  the  best  available  tool  for  tracking  progress  at  indiv.-~al
facilities.

    The  Industrial toxics Project is not an attempt to either  expand or
supercede existing authorities and programs.   EPA  will continue to
proceed  with  regulation development, permitting,  and enforcement for*
these substances  and facilities as  required by law,  but  will use these
authorities as  discussed previously to promote cost-effective prevention
alternatives.

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                                                  Pan IV • Next Slips
                            PART IV

                          NEXT STEPS
    While implementation of this pollution prevention strategy proceeds,
EPA will be undertaking a number of efforts to expand its scope:

    •  As  noted, EPA will be  working with  the Departments  of
      Agriculture, Energy, and Transportation to develop specific pollution
      prevention programs for these areas.

    •  EPA is continuing to work with other federal agencies to define an
      appropriate federal  role  in pollution  prevention  and pollution
      prevention strategies for federal facilities.

    •  Through a series of public hearings, EPA will solicit advice on the
      implementation of this strategy  and further refine the National
      Pollution Prevention Agenda for the 1990s, with broad  input from
      the public, the private sector, the environmental community, local,
      state, and federal government  agencies, and  the international
      community.

    Pollution   prevention is  an evolutionary  concept    As research
continues, technology changes, and progress is achieved, our ideas about
what is possible, feasible, and desirable win doubtless change as  well
This document will  need to be periodically updated as well as expanded
as we  move  forward.   The strategy will  be announced in the  Federal
Register, and EPA will continue to solicit ideas from public and private
interest groups.   The Agency welcomes a continuing dialogue  on the
strategic,  vision, as  well  as  the practical  tactics,  for  achieving
environmental gains through pollution preventic
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