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 ies± and
processes that prevent or minimize pollution ~ that stop it from
being created bt the first place. . ;:: ,..;•: > y...,,i:i£::;^ ;>.•:
— ; 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:
« 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:
« 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.
« 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 •«
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
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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.tttio« f»iin'8«lves. . 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 @KC£C 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-dJ£rh*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 m£de 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.
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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
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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*/ \«-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;
»
• 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
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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.
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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
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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
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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.
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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
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Pollution Prevention Strategy
Amoco-EPA Joint Poirution Preventioit Project Amoco
COTpomioo acd EPA i» jointly carrying out * project to Wentiff existing
% - . * » * * "'...^»^_'.S * ^^^ s i "•. ^ • ~ »_ v ' j. ^^
ori
AawcoY Ywta^^5^^i^^!^^l^^^^til **
ffOOOOttOfPf^'SQF VOttVEDDHEflE' ~lli^K^iQBiVHcK«OF 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
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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
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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).
« ImpFovSag dots 8®& 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
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Part II - Guidance to Programs, R«ion$
•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 aSe« &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 . > • «oi* >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
•27-
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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 > •» ,'f %:' ' ' <$-*< *,
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a. TSCA dva irimtntOTMive
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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
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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
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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
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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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