REPORT ON THE
U.S. ENVIRONMENTAL PROTECTION AGENCY'S
     POLLUTION PREVENTION PROGRAM
                September 1991
      Office of Policy, Planning and Evaluation
          Office of Pollution Prevention

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Contents


Preface

Introduction	    1

Progress and Activities in Pollution Prevention	    2

       Institutionalizing Pollution Prevention	    2
       Cross-Program Initiatives	    3
       Office of Pollution Prevention	    4
       EPA Program Offices	    10
       EPA Regional Offices	    14

Future Directions, Challenges, and Issues	    20

       Promoting a Lifecycle Perspective	    20
       Creating a Pollution Prevention Ethic	    21
       Measuring Pollution Prevention	    22

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PREFACE

       William K. Reilly, Administrator of the U.S. Environmental Protection Agency
(EPA) has established pollution prevention as one of the highest priorities at EPA and
the solution of first choice to environmental problems.  This report outlines the
progress made to date in  the Agency's own pollution prevention program and outlines
the issues that the program will be facing in the coming years.

       The report contains the  following sections:

       I.     Introduction — provides a  brief history of the pollution prevention
             program at EPA and the policy direction under which the program
             operates.

       II.    Progress and Activities — provides an  overview of EPA's current activities
             in pollution  prevention and near-term initiatives for the pollution
             prevention program.

       III.    Future Direction, Challenges, and Issues — outlines some of the primary
             challenges for the Agency's pollution prevention program in the long term.

       The pollution prevention concept has captured the imagination of many people
both inside and outside of EPA  A comprehensive documentation of activities to date
is virtually impossible to compile. Each day, EPA learns of new success stories in
industry, government, and academia — literally, in all sectors of the environmental
community. Likewise, new success stories happen continuously in the various EPA
programs and regional offices and in state programs. This report is intended to capture
a sense of the progress being made by EPA and its state partners and the future
direction of pollution prevention from EPA's perspective.  The focus  is to provide a
sampling of the programs that EPA has initiated in this area; it is not exhaustive, nor
does it cover pollution prevention activities underway outside EPA. Comments
regarding this report are most welcome and may be sent to:

                                Stanley L. Laskowski
                  Director, Office of Pollution Prevention (PM-222)
                       U.S. Environmental Protection Agency
                                 401 M Street SW
                              Washington, D.C. 20460

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L     INTRODUCTION

       EPA first established a central office for pollution prevention in the Office of Policy,
Planning and Evaluation (OPPE) in August 1988.  At the same time, EPA established an
Advisory Committee to help guide and direct the Agency's prevention activities.

       The Office of Pollution Prevention (OPP) is responsible for establishing broad Agency
policies and strategies  for pollution prevention, setting goals, and measuring progress towards
these goals. OPP functions as a catalyst for pollution prevention, promoting the concept inside
and outside the Agency and helping to facilitate and  coordinate prevention programs. OPP's
current management direction is derived primarily from three sources, briefly outlined below.

       •    The Pollution Prevention Act of 1990 calls pollution prevention a "national
            objective" and establishes a hierarchy of environmental protection priorities as
            national policy, whereby pollution should be prevented or reduced at the source
            whenever feasible; where pollution cannot be prevented, it should be recycled in
            an environmentally safe manner; in the absence of feasible prevention and
            recycling  opportunities, pollution should be treated; disposal  should be used only as
            a last resort.

            Among other provisions, the Act directs EPA to facilitate the adoption  of source
            reduction techniques by businesses and federal agencies, to establish standard
            methods  of measurement for source reduction, to review regulations to determine
            their effect on source reduction, and to  investigate opportunities to use federal
            procurement to encourage source reduction. The Act also authorizes an $8 million
            state grant program to promote source reduction, with a 50 percent state match
            requirement.

       •    The FY 91 Appropriations Act outlines six criteria against which the success  of
            EPA's pollution prevention program will be judged.  These criteria include  the
            development of:

            —        A pollution prevention  strategy that addresses the full range of
                      environmental problems;

            —        Analytic tools that can be used to identify the economic benefits of
                      pollution prevention;

            —        A strategy that articulates how EPA's strategic planning process and other
                      management systems will be utilized to promote pollution prevention;

            —        An aggressive outreach program to promote pollution prevention efforts;

            —       A process that assures full and explicit consideration of pollution
                      prevention opportunities in EPA's development of regulations; and

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            —       A program that provides information to the public on the environmental
                     implications of consumer products.

            EPA's Pollution Prevention Strategy.  Formally announced in February 1991, this
            strategy establishes EPA's future direction in pollution prevention.  The strategy
            indicates how pollution prevention concepts  will be incorporated into EPA's
            ongoing environmental protection efforts, emphasizing the need for continued
            strong regulatory and enforcement programs while favoring flexible, cost-effective
            approaches that involve market-based incentives where practical.

            The first part of the strategy to be implemented is the "33/50 Program" (Industrial
            Toxics Project), under which EPA is seeking substantial  voluntary reductions of 17
            targeted high-risk industrial chemicals that offer significant opportunities for
            prevention.  The goal is to reduce environmental releases of these chemicals by at
            least 50 percent by the end  of 1995.  The strategy also calls for the development
            of strategies for the agriculture, energy and transportation, federal government, and
            consumer sectors.
H.     PROGRESS AND ACTIVITIES IN POLLUTION PREVENTION

       Pollution prevention activities have been adopted in a wide range of EPA programs.
This section highlights some of EPA's recent achievements, beginning with institutional changes
that have been implemented to help create a "pollution prevention ethic" at the Agency.  The
remainder of this section features selected (a)  cross-program pollution  prevention initiatives;
(b) activities of the Office of Pollution Prevention; (c) initiatives in other EPA program offices;
and (d) pollution prevention activities in the EPA regional offices. More details on pollution
prevention activities, both inside and outside EPA, will be  available in  the forthcoming 1991
National Report on Industrial Pollution Prevention.

       Institutionalizing Pollution Prevention

       A number of structural and programmatic changes have been implemented to
institutionalize pollution prevention into all EPA program  and regional offices.  The aim of
these efforts is to ensure that prevention becomes  the preferred  approach in confronting any
environmental problem.  Institutional changes include:

       •  Promotion of multi-media source reduction in the Agency's strategic planning process.
          Examples include the  Office of Air and Radiation (OAR) promotion  of the
          development and commercial use of environmentally safe, energy-efficient substitutes
          for CFCs; OAR's encouragement  of the development of effective pollution
          prevention practices and equipment for the secondary  lead smelting industry; and
          support by the Office of Pesticides and Toxic Substances (OPTS) for agricultural
          practices that reduce or eliminate reliance on chemical input, such as LISA (low-input
          sustainable agriculture) or IPM (integrated pest  management).

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       •  Incorporation of prevention into the Agency's budgeting process.  In addition to the
          budget for the Office of Pollution Prevention, EPA estimates that close to  100
          workyears are being spent on pollution prevention throughout the Agency as a result
          of integrating prevention  into the mission of each program office.

       •  Incorporation of a pollution prevention component in a regulatory development course
          for EPA staff.

       •  Use of EPA publications  to commend and publicize pollution prevention success
          stories by industrial facilities, both new and old.

       •  Establishment of cash awards  for EPA facilities  and individuals for devising policies or
          taking action to promote  prevention as a new approach.

       •  Sponsorship of numerous meetings, conferences, and training programs on the
          potential for pollution prevention.

       •  Greater coordination within EPA when developing regulations and implementing
          programs in order to promote pollution prevention and to avoid situations where
          wastes are shifted  among  environmental media.

       Cross-Program Initiatives

       New initiatives are being taken in all parts of the Agency, with  the aim of promoting
and integrating a pollution prevention ethic across Agency programs and in society at large.
The initiatives are characterized by their use of a wide range of tools, including market
incentives, public education and information, small business grants, technical assistance, research
and technology applications, as well  as the more traditional regulation and enforcement.

       A primary example of this is the 33/50 Program mentioned earlier, being  coordinated by
the Office of  Toxic Substances with assistance from the Office of Pollution  Prevention and a
number of Agency workgroups. The program will make use of technical assistance, technology
transfer,  and other tools to elicit voluntary industry reductions in toxics releases.   (See box on
next page for a description of the 33/50 Program.)

       Another important example of cross-Agency activity is the set of "2% set-aside projects."
In 1989,  EPA sponsored an Agency-wide competition  for pollution prevention projects in order
to encourage new and creative initiatives in this area.  The program was funded  by setting aside
2 percent of the Agency's FY 1991  and  1992 extramural budget.  All EPA offices were allowed
to compete.  Twenty-five projects were selected, with most designed to last  two years.  Many of
these projects represent joint efforts between EPA offices and/or regions and focus specifically
on activities dealing with source reduction or toxic chemical  use substitution issues.

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    The 33/50 Program

    The 33/50 Program, EPA's Industrial Toxics Project, is a voluntary initiative to reduce
    toxic waste generation from industrial sources that is expected to achieve real results
    in pollution prevention in a relatively short time frame.

    Under this program EPA has targeted 17 chemicals for reductions of 33 percent by the
    end of 1992 and 50 percent by the end of 1995. The 17 chemicals are: benzene,
    cadmium and compounds, carbon tetrachloride, chloroform, chromium and compounds,
    cyanide and compounds, dichloromethane, lead and compounds, mercury and
    compounds, methyl ethyl ketone, methyl isobutyl ketone, nickel and compounds,
    tetrachloroethylene, toluene, 1,1,1-trichloroethane, trichloroethylene,  and xylenes.

    Since its inception in February 1991, EPA has contacted 600 companies that use
    and/or release the targeted chemicals to inform them about the program and solicit
    their participation.  These 600 companies account for 79% (1.1  billion pounds in
    1989) of the total releases and transfers of the targeted chemicals.

    Response to date has been extremely positive; close to 300 letters were received by
    May 31, with a  large  portion of them providing numerical reduction  commitments.
    One company noted:  "We feel that the achievement of this goal will benefit the
    public, through  reduced emissions, and will have potential savings for industry through
    better utilization of materials? EPA is now contacting another 5400 companies for
    participation in  the program.
       Office of Pollution Prevention

       In addition to its coordination role, the Office of Pollution Prevention administers
several innovative grants programs, develops strategy, encourages the incorporation of pollution
prevention in the regulatory process, undertakes cooperative efforts with industrial and
professional organizations, and promotes  prevention through outreach, education, and training.

       Grants Programs

       •   EPA's Pollution Prevention Incentives to States.  States have been at the forefront of
           the pollution prevention movement.  Through EPA's grant program, state pollution
           prevention programs are being strengthened and channeled into priority areas, such
           as the 33/50 target chemicals. In FY 1990, EPA awarded $7 million to fund 25
           state-based initiatives on pollution prevention across the country.  Funded projects
           included the establishment of state-wide integrated pollution prevention programs,
           educational programs, expanded technical assistance and auditing, training of state
           inspectors and interns, and demonstration projects that test different pollution

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    prevention methods and technologies.  Highlights of state pollution prevention
    programs are presented in the box on  the next page.

    In FY 1991, $8 million is being  made available through the competitive state grant
    program, with an additional $100,000 per region for state pollution prevention
    projects dealing with major environmental problems identified by EPA's Regional
    Offices.

•   EPA/USDA  Grants for Sustainable Agriculture.  EPA and USDA have joined
    together in one of the first interagency cooperative grant programs in the federal
    government. In FY 1991, the Office of Pollution Prevention at EPA and the LISA
    program of  the USDA Cooperative State Research Service will distribute grants to
    states from a $2 million joint pool, to fund projects involving education,
    demonstrations, habitat research, and economic studies.

•   Energy Efficiency Grants.  A joint project of the Department of Energy and EPA's
    Office of Pollution  Prevention aims at  demonstrating how industrial competitiveness
    can be enhanced through waste  reduction and energy efficiency. Large-scale
    research and demonstration projects  will  be  funded in key industrial sectors, such as
    steel, petrochemicals, and synthetic organic chemicals.

    Municipal Water Pollution Prevention.  In a joint Office of Water/Office of Pollution
    Prevention project,  pilot studies  will  commence in each  region, aimed at having
    POTWs routinely assess their  capabilities, project  future demand for treatment,  and
    make plans to meet future demand through  industrial and municipal pollution
    prevention.

Regulatory Analysis & Review

•   The Office of Pollution Prevention is preparing guidance for incorporating pollution
    prevention into the regulatory development  process, including  training of regulation
    writers. Also, as required by the FY 91 Appropriations Act, the Office is  developing
    analytical tools that can be used by both  the federal government and the private
    sector to identify the economic benefits of pollution prevention.

•   The Office of Pollution Prevention targets specific regulations  under the Clean  Air
    Act, Clean Water Act, and RCRA and participates  in their development in order to
    incorporate prevention concepts into the  regulations.  Current examples include
    MACTs (maximum  achievable control technologies) for chromium electroplating, dry
    cleaning, hazardous organics, pulp and  paper. The Office is also active in promoting
    source reduction in the reauthorization efforts for RCRA and  CWA.

Cooperative Efforts

•   Model Community Demonstrations. These projects are underway in several well-
    defined communities. The object is to  develop and implement multi-media pollution
    prevention strategies that  are readily transferable to other community settings.

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  ,           Highlights of Three State Pollution Prevention Programs

• Iowa

The Iowa Waste Reduction Center (IWRC) at the University of Northern Iowa began
operations in January 1988 with a mission of assisting small Iowa businesses1 with
minimizing waste, understanding and complying with environmental regulations, and
protecting employees and communities from environmental hazards.  To date, IWRC has
performed over 400 on-site reviews throughout Iowa,  consisting of a  comprehensive
facility tour and assessment report, with a six-month follow-up call to determine if the
business is in need of further assistance or was able to successfully implement the
recommendations.  Eighty percent of the businesses involved reported that they were
able to successfully implement the waste reduction recommendations made by IWRC,
resulting in 10,175 tons of waste being reduced. IWRC also provides a variety of
educational activities to keep businesses up to date  on changing regulations and waste
management options. Last year, IWRC made 49 presentations reaching over 2000
individuals, and conducted ten hazardous waste workshops reaching 600 business owners.

• Kentucky

Kentucky Partners was created at  the University of Louisville's Speed Scientific School
as the State waste center in 1988. Its major goals are to provide technical assistance and
process evaluation to hazardous waste generators; provide information on specific waste
or pollutant generation problems and on current prevention techniques; and provide
referrals  for diagnosis and resolution.  The center operates an 800-telephone number,
coordinates a network of industrial consultants, publishes and distributes a quarterly
newsletter to over 6,500 industrial representatives, conducts workshops for industries and
associations, and offers industry audits, seminars, and  technical visits. Five retired
engineers provide on-site technical assistance; 58 site  visits at paint, aluminum, and
general manufacturing plants have been conducted since June 1989.

• New Jersey

New Jersey's Office  of Pollution Prevention in the Department of Environmental
Protection has as a goal the implementation of a state and facility-wide multi-media
permitting program which is  intended to minimize the media transfer of waste and
achieve further waste reductions.  The New Jersey Technical Assistance Program
(NJTAP) for Industrial Pollution Prevention provides free, confidential information and
technical  assistance to industries in the state.  NJTAP services include literature searches
on economic and technical information, site visits, publishing a Technical Information
Publication Series (TIPS) on various manufacturing industries; and implementing a
pollution prevention verification project that will verify annual generator reports and use
the information to compile a database of pollution  prevention practices being utilized.

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           Projects are being developed at/with: Tufts University, Center of Environmental
           Management; a three to five year project at several defense facilities in the Norfolk,
           VA area (Langley Air Force Base, Fort Eustis (Army), and Norfolk Naval Base); the
           Milwaukee River Basin; and a two-year project at the University of Pittsburgh with
           the Center for Hazardous Materials  Research.

       •   Consumer Labeling,  EPA is working with the Federal Trade Commission, the U.S.
           Office of Consumer Affairs, and other federal agencies to explore the  possibility of
           establishing uniform national standards for the use of environmental terms in
           advertising.  The standards would  affect such terms as "recyclable" and
           "biodegradable."

       •   Dye Manufacturers.  In  the first ever industry-wide prevention program, EPA (Office
           of Solid Waste and OPP) and the Ecological and Toxicological Association of the
           Dyestuffs Manufacturing Industry  (ETAD) have joined forces in a voluntary project
           to develop and implement a comprehensive pollution prevention program for the
           dye industry.  Among other products, a guidance manual will be developed to assist
           companies  in identifying prevention opportunities.

       •   Trade and Professional Associations.  The Office of Pollution  Prevention, in
           conjunction with the Office of Research and  Development (ORD), is working
           cooperatively to promote pollution prevention with the American Institute for
           Pollution Prevention (which serves as a liaison to a broad cross-section of industry);
           the American Institute of Chemical Engineers (curriculum development, research
           projects); the American Institute of Architects (indoor air, energy conservation,
           restricted use of certain non-renewable materials, development of a resource guide
           for building materials and design); Chemical Manufacturers' Association (Responsible
           Care Program); the  National Association of Corrosion Engineers (extending product
           lifecycle, reducing contaminants common in manufacturing processes); and the
           American Petroleum Institute.

       Outreach. Education, and Training

       To encourage the rapid  and voluntary adoption of pollution prevention approaches, EPA
is reaching out to  all sectors of society, publicizing prevention issues, educating citizens, and
providing up-to-date information and training.

       •   The Pollution Prevention Information Clearinghouse,  developed  by ORD and OPP,
           is a computerized network of prevention information accessible through personal
           computer and modem.  Clearinghouse information is also accessible through a toll-
           free telephone number  (1-800-424-9346).  Over 1500 people are repeat users of the
           clearinghouse database.

       •   Training is  offered to EPA permit-writers and inspectors to incorporate pollution
           prevention  techniques in their work.   The Office of Pollution  Prevention also
           publishes and distributes an  annual guide, Pollution Prevention Training Opportunities,

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           listing courses and workshops offered by public and private organizations around the
           country.

           A free newsletter, Pollution Prevention News, is published monthly.  A wide variety
           of other materials are also available, including  brochures, fact sheets, and videos.

       •   As one of the Agency's "2 percent projects" and in line with the recently enacted
           Environmental Education Act, EPA is working in partnership with state and local
           governments, industry, educational institutions,  textbook publishers, teachers, and
           others, to strengthen environmental education.  As a first step, over 2,000 existing
           curriculum items on pollution prevention have  been reviewed and referenced in a
           bibliography.  New materials are now being developed by the Pollution Prevention
           Education Materials Task Force to enhance existing curricula and to help educators
           and schools increase awareness of the importance of pollution prevention  among
           students from kindergarten through grade 12.

       Strategy Development

       The Office of Pollution Prevention is responsible for developing and implementing  a
comprehensive pollution prevention strategy that addresses the full range of environmental
problems in industrial and non-industrial sectors.  OPP also is responsible for coordinating  the
Agency's efforts to measure progress  in industrial source reduction and is developing methods
for evaluating prevention progress in  other sectors as well.

       Pollution  prevention strategies are currently under  preparation for agriculture, energy
and transportation, the consumer sector, and the federal government.

       Agriculture

       The link between economic interests (farm profitability) and environmental protection, as
well as the statutory authorities represented in the 1990 Farm Bill, point to  new opportunities
for promoting sustainable agriculture.  The primary goals of an EPA strategy for pollution
prevention in agriculture are likely to include:

       •    Working with USDA to expand the LISA (Low-Input  Sustainable Agriculture)
            program, focusing on wildlife, water quality, habitat preservation, and education and
            training.

       •    Demonstrations and  education - harnessing SCS and Extension  to mainstream
            LISA/IPM (Integrated Pest Management) practices into U.S. agriculture.

       •    Targeting specific geographic areas for specific pesticide reductions (e.g., Great
            Lakes);  targeting water use reductions and pesticide container waste.

       •    Applying an integrated crop approach: i.e., determining how best we can grow corn,
            cotton, soy beans, etc. ~  in the process, reducing use of key pesticides.
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       Energy & Transportation

       Substantial opportunities exist for achieving energy savings and environmental
improvements in the energy & transportation sectors.  Mechanisms  include:

       •    Fostering energy efficiency (extending OAR's Green Lights program to Green
            Machines, Green Fleets, Green Power programs).

       •    Using regulatory authorities of new Clean Air Act to prevent pollution. E.g: toxics
            reduction goals for reformulated gasoline; requiring alternative fuel fleet vehicles;
            emphasizing demand side approaches for achieving SOx, CO2, NOx reductions.

       Consumers

       Consumer purchasing power and behavior can have an enormous impact on pollution
problems.  Elements of a strategy to empower consumers as a positive force for pollution
prevention will likely include:

       •    Educational actions to increase awareness by consumers of their own role in
            pollution and prevention.

       •    Developing and implementing a program which will allow the environmental and
            health impacts of products to be assessed over the product's life cycle and which will
            develop ways  of conveying this information to consumers.  EPA's Consumer Product
            Comparative Risk project will develop a method for conducting sophisticated
            product lifecycle  assessments that can form the basis for an environmental labeling
            program.  As  noted, EPA is already working closely with the Federal Trade
            Commission and  the U.S. Office of Consumer Affairs to discuss guidelines for
            environmental claims.

       Federal Government

       Federal facilities need pollution  prevention in order to meet their own environmental
objectives.   Moreover, federal pollution prevention policies could have a dramatic effect,
spurring pollution prevention throughout the economy.  The Office of Pollution Prevention is
already working with the Department of Defense and Department of Energy to  target the 17
Industrial Toxic Project chemicals for reduction. Elements of a federal pollution prevention
strategy may include:

       •     Federal leadership in demonstrating technologies and in conducting maintenance
            activities, e.g., implementing energy efficiency opportunities at federal facilities;
            establishing clean fleets of alternative fuel vehicles.

       •     Using procurement specifications to stimulate demand for clean technologies and
            products, e.g., procuring safe alternatives to high risk chemicals now  in use (DOD);
            procurement of recycled and reused  material wherever feasible.

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       •   Designing policies to promote pollution prevention, e.g., working with State and
           AID to help developing nations "leapfrog" inappropriate technologies; establishing
           procurement policies with OMB, DOD, GSA.

       EPA Program Offices

       Inclusion of pollution prevention principles into EPA's ongoing regulatory and program
agenda is an important goal of the Agency.  Pollution prevention is being incorporated into a
wide range of activities, including regulatory development, enforcement, compliance-related
activities, state/EPA interfaces, grants and cooperative agreements,  research and development,
technology transfer, training, technical assistance, outreach and education.  Integrating pollution
prevention concepts into legislation is a critical task as well.  EPA will be working hard to
integrate pollution prevention into the reauthorization of RCRA and the Clean Water Act.

       Following is a sampling of some of the many pollution prevention efforts currently
underway in the program offices and the types of initiatives being pursued  in the near-term.

       Air Programs

       An important goal of EPA's air programs over the next few years will be the
implementation of the new  Clean Air Act, which incorporates innovative strategies and a
pollution prevention approach to tackle serious air pollution problems, including acid rain,
stratospheric ozone depletion, and toxic air emissions.  In addition,  the linkage between energy
use and air pollution is giving rise to new initiatives to reduce energy demand:

       •   Green Lights.  Lighting accounts for about 25%  of all electricity used in the U.S.
           EPA's "Green Lights" program is an aggressive,  non-regulatory  effort to reach
           corporate decision-makers with information on new lighting technologies and the
           economic and environmental benefits of efficient lighting. Over 30 major
           corporations  have already signed  agreements with EPA  committing  themselves to
           upgrading their  facilities over the next five years with energy-efficient lighting
           products. The program's target is a  10 percent  or greater reduction in national
           electricity demand with an associated  4 to 7 percent  reduction in emissions of carbon
           dioxide, sulfur dioxide, and nitrogen oxides.

           Firms signing on as of February 8, 1991 include: American Standard,  America West
           Airlines, Amoco, Bechtel, Bell  Atlantic, Boeing, Browning Ferris, Inc., The Oliver
           Carr Company,  Citicorp/Citibank, Crestar  Bank, Digital  Equipment  Corporation,
           General Dynamics, Gerber Products Company, The Gillette Company, Hasbro, IPS
           Electric and Midwest Gas, Johnson and Johnson, Eli Lilly & Co., Lone Star  Steel,
           Maytag, Memorex Telex, Fred  Meyer, Inc., Nike Corporation, Phillips Petroleum
           Corporation, Polaroid Corporation, Preston Trucking, 3-M, Union Camp
           Corporation, Warner-Lambert Company, Whirlpool, Wolverine World Wide,  and
           Xerox.

           Under a voluntary agreement, each Green Lights Partner will survey its U.S.
           facilities, consider a full  set  of lighting options (including lamps, ballasts, fixtures,

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           controls, and reflectors), and choose options that maximize energy savings at a profit
           while offering comparable lighting quality.  If appropriate, retrofitting would be
           undertaken on 90 percent of the square footage of these facilities.  EPA and the
           participating companies also agree to undertake education, training, and publicity
           efforts for energy-efficient lighting.

       Near-term initiatives in EPA's air programs include:

       •   development of MACT standards for hazardous air pollutants that promote pollution
           prevention as the preferred option for achieving these standards;

       •   development of a negotiated regulation resulting in an air standard which will
           prevent fugitive emissions of some of the most toxic air pollutants (e.g., 1,3-
           butadiene) from the synthetic organic chemical industry  (new source performance
           standards were structured to encourage facilities  to reduce emissions through
           increased efficiency and additional product recovery rather than through additional
           controls); and

       •   development of rules to control the sulfur and aromatic hydrocarbon content of
           diesel fuels.

       Water Programs

       Pollution prevention efforts in EPA's water programs focus on water conservation efforts
and the pervasive  threats to water quality from  a variety of diffuse sources (called "nonpoint
sources"), such as  agricultural and urban run-off, underground  storage tanks, and spills of
hazardous substances.  Initiatives include:

       •   Great Lakes Pollution Prevention Action Plan.  EPA recently released a pollution
           prevention action  plan for the Great Lakes region, emphasizing the prevention  of
           toxic releases. Termed a "national treasure" by EPA's Administrator, the Great
           Lakes contain about 20 percent of the world's supply of fresh surface water.  There
           is continuing concern over the presence of persistent toxic substances, such as
           mercury, PCBs, and lead,  many of which are carried by air currents for hundreds of
           miles before being deposited in  the  Great Lakes.  Prevention is the obvious strategy
           of choice in this geographic initiative.  The action plan calls for a public/private
           initiative with the  auto industry; a cooperative monitoring effort for Lake Superior;
           pilot programs for urban non-point sources; and a wide-ranging outreach program.

       •   Municipal Wastewater.  EPA and the states are launching state-based programs
           aimed at identifying and correcting potential problems at publicly-owned treatment
           works  (POTWs) and applying pollution prevention strategies.  The focus of the
           program is to provide  an  early warning system to prompt activities to reduce flow
           and loadings, encourage water and energy conservation,  ensure environmentally
           sensitive residuals management and  the beneficial reuse of sludge, and ensure
           appropriate planning for future  needs.  The Office of Water has involved EPA's
           Regional Offices and the states in developing a fully cooperative program.

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           Pulp and Paper Regulatory Cluster.  The Office of Water is coordinating a cross-
           Agency effort to promote pollution prevention through a dialogue with
           environmentalists and the pulp and paper industry.  The goal is to encourage
           industry to meet its regulatory obligations through prevention.

       Near-term initiatives in the Office of Water include:

       •   work on new industrial water effluent guidelines that take into account source
           reduction options  available to facilities;

       •   development of a  proposed ban on acrylamide as a sewer grouting compound; and

       •   review of Best Demonstrated Available  Technology (BDAT) regulation to ensure
           the inclusion of pollution prevention technologies in industrial effluent standards
           under the Clean Water Act.

       Solid Waste

       The amount of municipal solid waste generated nationally has continued  to rise in recent
years.  Recycling, however, is  becoming more and more widespread. EPA's goals are to  see a
decrease in the ever-increasing per capita generation of waste and to achieve a 25 percent
recycling rate for the solid waste stream nationwide. EPA's Office of Solid Waste has a  variety
of educational and  promotional programs in place to encourage waste minimization in industry
and households, to  help create markets for recycled products, to develop procurement guidelines
for various recycled products,  and to promote yard  composting.

       EPA's Office of Solid  Waste is currently developing an  Action Plan which will define
how pollution prevention  and waste minimization will be incorporated in RCRA standards,
permits, inspections, enforcement, and reporting requirements, as well as in training and  grant
programs.  The Action Plan will be developed through a five-step process including formation of
an OSW task group, a cross-agency Advisory Group, analyses of comments, and  use of focus
groups. Each focus group will be made up of representatives from EPA program  and regional
offices, states, industry, the environmental community, and other interested parties.

       The Office  has also  begun policy studies and technical analyses that may serve as the
basis for future actions, including the following:

       •   exploring requirements for waste minimization plans as a condition for the issuance
           of Treatment, Storage, and Disposal permits to facilities under RCRA;

       •   identifying products that are the major  sources of mercury in municipal solid waste
           streams for possible chemical use substitution; and

       •   considering possible cross-media integrated permitting mechanisms, coordinated
           multi-media inspections, and requiring permits to include pollution prevention plans.
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       Pesticides & Toxic Substances

       One of the most effective prevention techniques is the banning of substances that pose
unreasonable  risks  to human health and the environment. Examples from the past include
pesticides such as DDT as well as chemicals like PCBs.  Recently, EPA has moved to phase out
the last few remaining uses of asbestos. The Office of Toxic Substances is undertaking various
initiatives to revitalize the Toxic Substances Control Act by using the wide range of authorities
it contains to  tailor cost-effective responses to specific environmental problems.  Among other
efforts underway, OTS  is currently studying alternatives to reduce demand for chlorine bleached
paper products and is analyzing regulatory options regarding the production, distribution, and
use of chlorinated solvents.

       In addition  to the 33/50 Program mentioned earlier, OTS is coordinating EPA's new lead
strategy.

       •    Comprehensive Lead Strategy.  In February, EPA announced a comprehensive, multi-
            media strategy to reduce lead exposures, with particular emphasis on reducing the
            risk to  children.  Lead is a highly toxic metal, known to produce a range of adverse
            human health and environmental effects, particularly in children and fetuses.  EPA's
            plan calls for regulatory programs to decrease lead levels in  drinking water and in
            ambient air near large stationary sources such as lead smelters and refineries;
            stepped-up  enforcement actions against facilities violating lead standards;  and
            investigations into  the location of geographical lead "hot spots."

            In addition, EPA is studying the feasibility of requiring advance notice  from anyone
            intending to manufacture or process lead for a new use, and further increasing the
            recycling rate of spent auto batteries.  Although the current recycling rate is about
            80-85 percent, lead-acid batteries account for a high proportion (about 80%) of all
            lead used each year in the U.S.  Lead also is among the 17  substances targeted for
            voluntary reductions  in EPA's  33/50 Program.

       Enforcement

       EPA is encouraging the inclusion of pollution prevention conditions in Agency
enforcement settlements.  The Office  of Enforcement  has issued a policy statement that
encourages pollution prevention  (along with recycling) "as a means of achieving and maintaining
statutory and  regulatory compliance and of correcting outstanding violations when negotiating
enforcement settlements."

       In the first such case in 1990, an Ohio manufacturing company which was in violation of
a notification  provision  of the Toxic Substances Control Act, agreed to pay a civil penalty and
institute a pollution prevention project at one of its facilities.  The $525,000 project should
result in waste reduction of a half million pounds of waste material annually.

       Based  upon the initial experience of the Agency with the inclusion of pollution
prevention measures in  enforcement settlements, actions to date mark the beginning of what
portends to be an important new trend in  environmental enforcement

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       Research and Development

       EPA's Office of Research and Development has prime responsibility for the Agency's
research in the area of pollution prevention.  ORD has developed a Pollution Prevention
Research Plan, submitted to Congress in March 1990, which establishes a blueprint for future
research efforts. Short-term efforts 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.

       Current research initiatives include:

       •   The Waste Reduction Innovative Technology Evaluation Program (WRITE)  - EPA has
           entered into three-year cooperative agreements with California, Connecticut, Illinois,
           Minnesota, New Jersey, and Washington to evaluate some 30 waste reduction
           technologies in order to identify ones worthy of being applied industry-wide.

       •   The Waste Reduction Assessments Program (WRAP) - A program designed  to
           encourage the use of waste minimization assessments by the industrial community as
           a tool  to  identify options for reducing waste generation.

       •   The Waste Reduction Evaluations at Federal Sites Program (WREAFS) - A program
           which  focuses on waste minimization demonstration and evaluation projects at
           federal sites  conducted cooperatively by EPA the Department of Defense, the
           Department  of Energy, and other federal agencies.

       In 1989, EPA established the American Institute for Pollution Prevention in cooperation
with the University of Cincinnati.  The Institute provides a bridge between EPA and  industry
and acts as liaison between professionals in the field of pollution prevention and  those who
need to employ prevention techniques.

       EPA Regional Offices

       EPA's 10 Regional Offices represent  the Agency's front line in pollution prevention,
dealing directly in  day-to-day interactions with state,  county, and local officials, industry,
grassroots environmental groups, and civic organizations.  Each Regional Office has a  pollution
prevention staff that coordinates and initiates projects.

       Among the important tasks of the Regional Offices is  the integration of pollution
prevention concepts into the routine work performed by regional staff.  This is crucially
important in  the areas of inspections, permit writing, and enforcement negotiations, where many
opportunities exist to promote  preventive approaches.  Many of the regions are examining pilot
projects that  would integrate permits across environmental media and require  prevention
planning. In  these as in  many other activities, a close working relationship between the Regional
Office and the states in  the region is the key to success.  Following are highlights of  pollution
prevention activities underway in each EPA Regional Office.
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       Region 1

       The Region 1 Strategic Plan signals a profound shift away from the traditional emphasis
on legalistic and bureaucratic implementation of statutory requirements.  Pollution prevention is
at the center of the new environmental protection ethic building within the regional office and
across New England.  Region 1's long term pollution prevention objective is to reduce pollution
from  all sources by 30% by 1996.

       Until Region 1's Strategic Planning goal for pollution prevention is implemented in
program workplans, the region will continue to implement pollution prevention through an
annual Pollution Prevention Strategy. This document includes numerous objectives from each
major program.  Current efforts include:

       •   reducing the volume of chemicals used in sample analysis and the amount of waste
          generated by testing in the regional laboratory;

       •   pollution prevention outreach and education programs for "light industries" such as
          dry cleaners and auto body shops, to lessen the threat of ground-water contamination;
          and

       •   an Ozone Layer Protection workshop for 400 CFC-using electronics and metals
          manufacturers.

       A major ongoing project in the annual Strategy which signifies a very new way of doing
business in Region 1 is  the New England  Pollution Prevention Council.  The Council  is
composed of IS leaders in government, business, academia, industry, and environmental groups.
Region 1  Administrator Julie Belaga co-chairs the Council with a prominent New England
business leader.  The  Council is currently  developing transportation sector solutions for the
region's serious ground-level ozone pollution problem.

       Region 2

       Region 2's FY 1990 pollution prevention strategy calls for the initiation of new pollution
prevention projects, promotion of an internal recycling project, and incorporation of pollution
prevention activities into regional initiatives and programs.  Some of these pollution prevention
programs  include:

       •   The Water Permits and Compliance Branch has been recommending the use of
          source reduction techniques and the use of less toxic compounds to its regulated
          industries. In  one case, a company in the region was able to decrease the amount of
          formaldehyde in its effluent by 99.6 percent by substituting another product.

       •   The Air and Waste Management Division has augmented the waste minimization
          provision in RCRA permits and is expecting approximately 40 companies to
          participate in the project. It is also requesting that all RCRA Treatment, Storage, and
          Disposal facilities which apply for new permits develop a Waste Reduction Impact
          Statement, which must include an analysis of the technically and economically feasible

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          source reduction techniques that have been implemented since 1984 and a program
          and schedule for implementing feasible source reduction techniques.

       •  Under the Air Toxics Pollution Prevention Initiative, Region 2 has  been working with
          12 facilities in a voluntary pollution prevention assessment and reduction project.
          Eight of the facilities reported emissions reductions, based on product substitutions,
          process modifications, or other factors.  Three facilities  have established specific
          numeric emissions reduction goals ranging from 68 to 90 percent.  Region 2 is
          encouraging the remaining nine facilities to follow suit.

       •  The Coastal Waters  Initiative addresses point and non-point source pollution,  land-use
          changes, and combined sewer overflows in four regional water bodies: the Long Island
          Sound, New York/New Jersey Harbor, Delaware Bay, and the New York Bight.
          Comprehensive Conservation and Management Plans are being developed for  each
          system.  Ongoing pollution prevention activities include  educating farmers to use less
          fertilizer on their land; encouraging homeowners to reduce pesticide and fertilizer
          usage; working with  municipalities to reduce urban runoff and upgrade stormwater
          pipes; and education and outreach efforts to consumers.

       Region 3

       Region 3 has been actively negotiating pollution prevention into RCRA corrective action
requirements. The owner/operator of the facility involved is being required to develop a waste
minimization plan which addresses procedures for reducing volume and/or quantity of hazardous
waste generated at the  facility.  The pollution prevention requirements focus on releases of TRI
chemicals.  As an example, for a facility located in York, Pennsylvania that manufactures
tracked military vehicles, Region 3 reviewed its TRI data during negotiation of a final RCRA
3008(a) order.  The data  revealed a potential  risk-related problem associated with the discharge
of hex chromium into a receiving stream and the release of chlorinated solvents from degreasing
operations as stack emissions.  The company decided to  install a forced crystallization treatment
process that could handle all the waste streams from the plant in  a closed loop.  As a result, the
discharge of hex chromium into the receiving stream would  be eliminated. The company also
added a  cooling unit to the degreaser, resulting in close  to a 90 percent reduction in chlorinated
solvents  being released.

       Region 3 also has been evaluating the use of TRI data combined with other data to
estimate the  relative efficiencies of companies in the region as a measure of the success of each
company's pollution prevention strategy.

       Region 4

       Resource Center. The Southeast  Waste Reduction Resource Center is one of the prime
showpieces of the aggressive pollution prevention activities going on in the Southeast states and
supported by EPA's Region 4.  Located in Raleigh, North Carolina, the Resource Center
functions as a clearinghouse, with  a library of over 5,000 pollution prevention publications and a
staff of engineers and scientists trained in waste reduction who are ready and willing to
"brainstorm" with company officials looking for solutions to  their waste problems.  The Center

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- has provided "jump starts" for a number of state programs by means of its "Core Reference
 Library," which consists of the basic documents  needed to undertake a waste reduction technical
 assistance program.  In response to popular demand, the Center is planning to enlarge its
 activities to conduct more on-site work with state programs, supply training to regulators, and
 expand its holdings of publications.

        Retiree Program.  EPA Region 4, together with the Tennessee Valley Authority and
 several states, has put in place a program which uses part-time retirees to offer technical
 assistance to industries.  Retirees selected for the program have industrial work experience in
 the type of industries that the state and region  have selected  as priorities.  They have been
 trained to conduct pollution prevention opportunity assessments, and are  familiar with various
 source reduction and recycling techniques and technologies.  In a number of locations, retired
 engineers are now working on-site  at industrial  plants and businesses conducting waste reduction
 audits  and helping to identify pollution prevention opportunities.  Training of retired engineers
 in waste reduction assessments has  been offered in Tennessee, Alabama, Florida, Mississippi,
 Kentucky, and South Carolina.

        Region 5

        Paper Reuse.  Working with the Illinois Department of Energy and Natural Resources, in
 1990 Region 5's Solid Waste Section convened  a work group  of seven Midwest  companies in
 the pulp and paper industry to embark on a joint project to create greater markets for post-
 consumer waste  paper.  The  Great  Lakes Waste Paper Work Group is  focusing its efforts on
 increasing old newspaper and lower paper grade reuse;  improving public education on waste
 paper needs; preparing waste paper quality guidelines; and encouraging organizations to buy
 products made from post-consumer waste paper. Plans are underway to initiate a similar project
 with representatives of the plastics  industry.

        Farm*A*Syst.  Region 5  is conducting several educational activities related to non-point
 source pollution from agriculture, a sector targeted in the region's strategy. Using the
 Farmstead Assessment System (Farm*A*Syst), Region 5 is promoting a  system to help farmers
 identify potential sources  of ground-water contamination and take action to prevent  the
 pollution from occurring.  Farmers  work through a series of worksheets to determine the risk of
 ground-water contamination from farmstead structures and activities, and to evaluate the site's
 vulnerability to leaching of pollutants.

        A prototype educational  unit for junior and senior high school students within the Great
 Lakes Basin has been developed as well.  The unit, based on  Farm*A*Syst, contains a series of
 lessons on analyzing pollution potential from  daily activities on farms or rural properties.  A
 paper on this program will be presented at the National Environmental Education Conference
 in September 1991.

        Region 6

        A fruitful collaboration between EPA Region 6  and the University of Texas at Arlington
 has produced The Environmental Institute for Technology Transfer. Em's mission is to
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•encourage the application of new technology through environmental research, education, and
training in the five-state federal region.

       One major initiative of EITT is the Prairie Project, which proposes to further
environmental protection and pollution prevention by teaching children the value of the natural
setting and their interconnectedness to earth. The prairie can serve as an inspirational
educational metaphor for children living in the central region of the country, and it captures a
sufficient variety of materials and experiences to serve as a versatile tool and site for outdoor
classrooms. The project will involve curriculum development, teacher training, outdoor
education site development, and continuing research. A pilot study is expected to  be in place in
Fall 1991.

       Region 7

       Region 7's Pollution Prevention Strategy focuses on addressing environmental
opportunities  in the most significant sectors of the regional economy:  large businesses and
industry,  agriculture,  small quantity generators, and commercial establishments.   The aim is to
maximize efforts by working with the states and private sector to achieve improvements in
environmental protection.

       The region's geographical industrial toxics project complements the Agency's 33/50
program.  Region 7 is undertaking a county-by-county approach, starting with Sedgewick County,
Kansas, one of the most industrialized counties  in the region.  Using the EPA Pollution
Prevention Strategy,  both large and small quantity releases are being  targeted and community
participation will be encouraged in achieving voluntary reductions through community goals.

       Agricultural practices are a major consideration in the Midwest, and Region 7 has a
number of pollution  prevention projects underway cooperatively with the states.  For example,
with the  Missouri Department of Natural Resources, Region 7 is demonstrating and
documenting  pollution prevention techniques for fertilizer and pesticide handling.  Region 7 also
is helping to educate farmers and communities on the importance of integrated crop
management in order to reduce the loadings of agricultural chemicals, particularly herbicides,
into two  surface water impoundments currently used as drinking water sources in Southern
Iowa.

       A grant to the Waste Management Authority of the Iowa Department  of Natural
Resources focuses on large quantity generators.  Pollution prevention audits are performed
through  a corps of retired engineers with a wealth of solid waste industry experience. A
complementary grant program is managed by the Iowa Waste Reduction Center at the
University of Northern Iowa.  The program concentrates on small quantity generators by
providing assistance to selected companies on waste minimization.

       Region 8

       Videos.  Negawatts, a 20-minute video produced by EPA Region 8 and the  Rocky
Mountain Institute, describes how corporations  can join in the energy-efficiency revolution and
increase both profits and productivity.  The video covers energy efficiencies in lighting, motors

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..and controls, windows, and insulation.  New videos in production will examine transportation
 innovations and sustainable agriculture.

        Denver Airport.  EPA Region 8 signed an agreement in March 1991 with the Denver
 International Airport to promote pollution prevention in the airport's operation and
 maintenance.  EPA will assign a Pollution Prevention Coordinator  to the New Airport Office
 for one year.  EPA's involvement with the New Airport Office began in September 1989 with
 an offer of technical expertise aimed at incorporating prevention principles in the design and
 planning of the airport, including fueling, air quality, water conservation, and glycol  (de-icing)
 handling.

        SolvNet.  A Pollution Prevention Partnership was formed in Region 8, with membership
 from EPA, the Colorado Department of Health, Coors, Martin Marietta, Hewlett Packard,
 Public Service of Colorado, Colorado PIRG, and the League of Women Voters.  The
 organization's current focus is SolvNet, a solvent-reduction pollution prevention project.  Under
 this project,  corporate partners have reduced usage of trichloroethane by up to 95 percent and
 have actively encouraged other companies to follow suit.  In addition, a brochure is being sent
 to over one  million residents, as part of Public Service's billings,  with information on solvent
 reduction in the home and small business.

        Region 9

        Some of Region 9's initial pollution prevention efforts involved  pilot projects with
 several San Francisco Bay counties.  Region 9 worked with Contra Costa County, one of the
 largest generators of hazardous waste in California, to develop a Hazardous Waste Minimization
 Program.  During the first year of the program, the county and Region 9 conducted workshops
 for small generators, trained county inspectors to conduct waste minimization  assessments at
 industrial facilities, and worked  with large  quantity generators which produced about 80 percent
 of the county's hazardous waste, to encourage the development of  facility waste minimization
 plans.  With the conclusion of the pilot project, Contra Cost has committed to continuing and
 expanding its Hazardous Waste Minimization Program.

        In another successful pilot project, Region 9 worked with the California Regional Water
 Quality Control Board (RWQCB)  and the publicly-owned treatment works (POTWs) of Palo
 Alto, Sunnyvale, and San Jose,  to minimize the discharge of metals into South San Francisco
 Bay.   Initially, Region 9 worked with the RWQCB to amend the POTWs' permits to require an
 investigation into the sources of metals entering their plants and an evaluation of opportunities
 for source reduction  of those metals.  Currently, EPA is assisting the POTWs with the
 development  and implementation of waste minimization programs which were required in recent
 permit amendments.

        Within the regional office, Region  9 has promoted the institutionalization of pollution
 prevention by including prevention in its permitting  and enforcement actions and in state grants,
 and by conducting training and  conferences for states, local governments, and regional managers
 and staff.
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       Region 10

       The Northwest Pollution Prevention Research Center, a cooperative venture of EPA
and private organizations, was established to identify  research needs and provide funding for
research into industrial pollution prevention opportunities. A non-profit, public-private
partnership, the Center has a broad potential constituency among industry, environmental, civic,
and labor organizations; the media; academia; and federal, state, and local government agencies.

       The Center's functions include setting research priorities; supporting, sponsoring, and
conducting pollution prevention research with an emphasis on practical research that will result
in concrete solutions; and evaluating the effectiveness of pollution prevention methods.

       Region 10 also is involved with several initiatives designed to reduce pollution caused by
agricultural chemicals and to promote the principles of Integrated Pest Management (IPM)  to
growers. The Pollution Prevention through Agricultural Chemical Management Initiative is  one
of the Agency's "2% projects."  As part of the initiative, four projects  have been selected in the
tri-state area  (Oregon, Idaho, and Washington) for future grant funding. The projects involve
low-input sustainable agriculture, improvement of management practices at small farms, research
and demonstration projects to reduce nitrate and pesticide pollution, and a computer-aided
expert advice system for  farmers.
HI.    FUTURE DIRECTIONS, CHALLENGES, AND ISSUES

       Pollution prevention is an evolutionary concept.  As research continues, technology
changes, and progress is achieved, our ideas about what is possible, feasible, and desirable will
doubtless change as well.  Over the longer term, EPA will seek to develop a broader consensus
on the need for all parts of society to become more actively involved in pollution  prevention.
EPA is exploring development of a National Pollution Prevention Agenda for the 1990s, with
wide-ranging input from the public, the private sector, the environmental community, local, state,
and federal government agencies, and the international community.

       The challenges that lie ahead are numerous.  Among the central issues that will
influence our success are: (1) promoting  a lifecycle perspective and sustainable economic
decision-making, (2) changing the EPA ethic over the long term so as to institutionalize
pollution prevention and maintain a more integrated view of environmental media, and
(3) measuring progress in pollution prevention.

       Promoting a Lifecycle Perspective

       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 costs  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 cost
centers.
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        Pollution prevention encourages a lifecycle perspective, which maintains that product
prices must reflect the true costs of using nonrenewable resources and the total environmental
costs of a product, from energy and material needs through manufacture, process, and use of a
product, to its ultimate fate or final disposal.  Promoting such a perspective will be one of the
most difficult challenges we face, but it is only by considering the environmental impacts of
economic decisions that we can hope to sustain continued economic growth and the quality of
our environment for future generations.

        Creating a Pollution Prevention Ethic

        Internal obstacles at EPA need to be addressed and overcome as the Agency moves
toward an ethic of prevention.  For example, EPA's own single-media organization, created
sequentially as individual  environmental problems  were identified and responded to in
legislation, has 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 used as often as they could.

        An integrated approach to the environment must lie at the heart of environmental
policy.  An integrated approach means looking at  all environmental media (air, land, water) as a
unified whole and avoiding the potential transfer of risks from one medium to another. In the
past, many of our control technologies have merely shifted pollution from one part of the
environment to the next in what is sometimes called an "environmental merry-go-round."  While
EPA has conscientiously pursued cross-media initiatives in  the pollution prevention area, this is
an  area where continuing vigilance will be needed.

        More  broadly, EPA faces the long-term task of institutionalizing the ethic of pollution
prevention into all facets of Agency operations. Central to the Pollution Prevention Act is the
premise that "source reduction pays," and as a corollary,  that a significant barrier to our
realization of the benefits from industrial source reduction is a lack of information — both
within EPA and the regulated  community.   Thus,  among the key elements of  the pollution
prevention strategy mandated by the Act are the development of a coordinated source reduction
data collection system that is publicly accessible, and model source reduction procedures to help
businesses understand the benefits of source reduction.

       Investing in long-term activities to build a  base of information and technologies and to
instill a pollution prevention ethic internally and externally, will produce  tangible and permanent
environmental benefits.  At the same time,  shorter-term  pollution prevention projects like the
33/50 Program must be initiated in order to obtain demonstrable results,  push forward the use
of new technologies and preventive approaches, and maintain  the momentum  of the larger
program.  The challenge for EPA will  be to strike an appropriate balance between short-term
demonstration projects and the longer-term  investment in achieving a broad-based and
permanent shift to a pollution  prevention ethic.
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       Measuring Pollution Prevention

       It can be argued that the very nature of pollution prevention does not lend itself to
accurate measurement.  If the prevention of pollution is successfully built into the design of a
product or practice, it may be difficult or impossible to measure.  Nevertheless, measurement is
essential to tracking progress. Both methodologies and data sources need attention over the
next few years.

       EPA currently relies on data from the Toxic Release Inventory (TRI) to track
reductions  in releases of targeted contaminants from industrial facilities.  At this time, TRI is
the only available data base 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.  New reporting of pollution prevention progress as mandated by the Pollution
Prevention Act should help develop a clearer picture of prevention progress in industry.

       EPA recognizes that the TRI data base 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, nor does it cover the millions of diverse
individual sources that contribute pollution (mobile sources, farm runoff, etc.).

       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 years 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 some of these shortcomings by:

       •    improving other data bases, such as the waste minimization surveys required under
            RCRA, so that these may provide a better measure of pollution prevention
            opportunities and activities.

       •    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.

       •    amending the TRI reporting form to require all facilities to provide data  quantifying
            the  effectiveness of preventive measures in reducing wastes prior to recycling,
            treatment, or disposal.

       •    building a comprehensive data base to measure and evaluate pollution prevention
            across a broad spectrum of industrial and nonindustrial activities.
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       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 individual facilities.
       In the last several years, EPA has made major strides in integrating pollution prevention
concepts and techniques into many of the Agency's activities. Program and regional offices are
developing new prevention initiatives and encouraging the use of preventive techniques and
toxic chemical substitution.  This report is an attempt to consolidate some examples of EPA's
activities in pollution prevention and provide a sense of where the Agency is headed in the
coming years.

       As progress is made on the technological side of pollution prevention, there is a growing
recognition of the need for prevention  to become an integral part of our basic philosophy of
environmental protection.  Pollution prevention must become the  strategy of first choice in
addressing any environmental problem.  Creating such a "pollution prevention ethic" requires a
shift in the perspectives of those whose activities affect the environment.  Without question, this
is a massive undertaking, and one that will continue to challenge the Agency in the years ahead.
Increasingly over time, however, we expect to see prevention ideas making an impact on
regulations and guidance, on policies and legislative initiatives, and on EPA's ongoing
interactions with other federal agencies, state and local governments, industry, the research
community, environmental groups, and the public at large.
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