ENVIRONMENTAL PROTECTION AGENCY

(OSWER-FRL-xxxx-x)

Pollution Prevention Policy Statement

Agency:  Environmental Protection Agency (EPA)

Action:  Proposed Policy Statement



Summary:

     The Environmental Protection Agency's progress over the last
18 years in improving environmental quality through its
media-specific pollution control programs has been substantial.
However, EPA realizes that there are limits as to how much
environmental improvement can be achieved under these programs,
which emphasize management after pollutants have been generated.
EPA believes that further improvements in environmental quality
can be achieved by reducing or eliminating discharges and/or   
emissions to the environment through the implementation of source
reduction and environmentally-sound recycling practices.

     EPA's proposed policy encourages organizations, facilities
and individuals to fully utilize source reduction techniques in
order to reduce risk to public health, safety, welfare and the
environment, and as a second priority to use environmentally
sound recycling to achieve these same goals.  Industrial source
reduction can be accomplished though input substitution, product
reformulation, process modification, improved housekeeping, and
on-site, closed loop recycling.  Although source reduction is
preferred to other management practices, the Agency recognizes the
value of environmentally sound recycling, and is committed to
promoting recycling as a second priority, above treatment, control
and disposal.

     Since not all pollution can be reduced or recycled, safe
treatment, control and disposal will continue to be important
components of an environmental protection strategy.  Source
reduction and recycling will not totally obviate the need for or
the importance of these processes.  Individuals as well as
industrial facilities or organizations can practice source
reduction and recycling through changing their consumption or
disposal habits, their driving patterns and their on-the-job
practices.

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     EPA firmly believes that all sectors of our society must
work together to ensure continued environmental protection.
Today's notice commits EPA to a preventive program to reduce or
eliminate the generation of potentially harmful pollutants.   The
Agency has established an Office of Pollution Prevention which
together with EPA's media-specific offices will develop and
implement this program.  An Advisory Committee of senior Agency
managers will help direct EPA's pollution prevention program and
will assure the participation of the entire Agency in this
important mission.  EPA also believes that State and local
government must play a primary role in encouraging this shift in
the environmental priorities of all sectors of industry and the
public.

     Today's notice also commits EPA to working with States to
develop and implement specific strategies and technical
assistance programs to encourage commercial and manufacturing
industries, the agricultural sector and the general public to
reduce the amount of pollution generated.

     There are varying views among representatives of industry,
public interest groups, state and local governments and others '
over the role of recyling in pollution prevention.  The Agency)
believes that source reduction (including closed-loop, in-plant
recycling) is generally preferred over other management
approaches.  The Agency also believes that out-of-loop and
off-site recycling, when properly conducted, also offers the
potential for significant economic benefits and reduced risk.
With the publication of this proposed pollution prevention
policy, the Agency would like to specifically request comment on
the role of environmentally sound recycling in the pollution
prevention program.  Other comments on this policy, and on the
steps necessary to implement  it effectively are invited.

Dates:  EPA urges interested parties to comment on this notice
in writing.  The deadline for submitting written comments is  (90
days after publication in the Federal Register.

Addressees*  All comments must be submitted in triplicate
(original and two copies) to:  EPA RCRA Docket (room SE-201)
(mail code OS-305), 401 M Street, S.W., Washington, D.C. 20460
Place the docket number, # F-88-SRRP-FFFFF, on your comments.
For further information, contact:

Gerald Kotas, Director, Pollution Prevention Office, Office of
Policy, Planning and Evaluation, 401 M Street, S.W., Washington,
D.C. 20460, (202) 382-4335; or

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James Lounsbury, Office of Solid Waste (OS-302), 401 M Street,
S.W., Washington D.C. 20460, (202) 382-4807.


Supplementary Information:

POLLUTION PREVENTION POLICY STATEMENT


Outline:

     This policy statement is organized as follows:

     I.     Background
     II.   EPA's Pollution Prevention Policy
     III.  Development of EPA's Multi-Media Pollution Prevention
           Program


I.   Background

     EPA has made substantial progress over the last 18 years ift
improving the quality of the environment through implementation} of
media-specific pollution control programs.  Notwithstanding past
progress, there are economic, technological, and institutional
limits on how much improvement can be achieved under these
programs, which emphasize management after pollutants have been
generated.  As early as 1976, EPA believed the nation could not
continue to reduce threats to human health and the environment
while utilizing only better methods of control, treatment or
disposal.

     In the development of its hazardous waste management program,
EPA recognized the importance of a hierarchy with source reduction
at the top and recycling above treatment and disposal.1 The
emphasis of EPA's hazardous waste program over the past twelve
years, however, has been primarily on implementing
statutorily-mandated requirements concerning waste identification,
treatment, storage, and disposal.  In spite of the significant
progress which has been made using this approach, the sheer volume
of hazardous waste generated each year poses a continuing and
serious environmental problem.
    1  See 41 FR 35050, August 18, 1976.  This notice provides a
discussion of EPA's preferred hierarchy of environmentally sound
hazardous waste management practices.

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     Section 1030(b) of the Solid Waste Disposal Act, as amended
by both the Resource Conservation Recovery Act (RCRA) of 1976 and
the Hazardous and Solid Waste Amendments of 1984, established a
national policy, initially referred to as the "Waste Minimization
Policy", that expressed a clear priority for reducing or
eliminating the generation of hazardous waste over managing wastes
that were nevertheless generated.  Specifically, it stated that:

     "The Congress hereby declares it to be a national policy of
     the United States that, wherever feasible, the generation of
     hazardous waste is to be reduced or eliminated as
     expeditiously as possible.  Waste that is nevertheless
     generated should be treated, stored or disposed of so as to
     minimize the present and future threat to human health and
     the environment."

     Today's policy statement commits EPA to a program that
extends beyond minimization of hazardous waste to reducing all
environmentally harmful releases.  EPA's experience with its
current programs has shown that, notwithstanding the substantial
gains that have been made in limiting environmental  pollution,
media-specific programs have some inherent limitations.  Efforts
to control or treat pollutants subsequent to their generation ofc
production can sometimes result in transfers of these pollutants
from one environmental medium to another, where they may continue
to present a hazard.  In addition, once these pollutants have been
produced or generated, some proportion of those releases will have
an impact on the environment, however effective the control or
management techniques.  The preventive approach of today's policy
statement provides a way to more effectively respond to these
remaining problems.

     EPA believes that all sectors of our society must work
together to ensure continued environmental protection.  EPA is
committed to working with individuals and organizations (both
public and private) to make source reduction and as a second
priority, environmentally sound recycling, the major focus of
future environmental protection strategies.  In particular, EPA
believes that State and local governments must play a primary role
in encouraging this shift in the environmental priorities of all
sectors of industry and the public.

     Some programs within EPA have already adopted measures to
promote source reduction and recycling.  For example, the Office
of Water has adopted effluent guidelines that have resulted in
flow reductions and product substitutions.  The rapid phasing down
of lead in gasoline by EPA's Office of Air and Radiation is

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another attempt to reduce pollution at the source.  Nevertheless,
much of the past focus in these programs has been on pollution
control rather than pollution prevention.  It is necessary at this
time to reassess EPA's programs in light of today's policy
statement and redirect them accordingly.

     The term "waste minimization", which EPA has previously used
in reference to source reduction and recycling activities in its
hazardous waste program, has been replaced in today's policy
statement by the phase "pollution prevention".  Through
eliminating a term that may be perceived as closely tied to RCRA,
EPA is emphasizing that the policy has applicability beyond the
RCRA hazardous waste context.  EPA stresses that the policy
focuses primarily on the prevention of pollution through the
multi-media reduction of pollutants at the source.  In addition,
in order to obtain additional benefits of avoiding releases to the
environment, EPA's pollution prevention program secondarily
promotes environmentally sound recycling.


II.  EPA's Pollution Prevention Policy
                                                               :
     EPA's proposed policy encourages organizations, facilities/
and individuals to fully utilize source reduction techniques in
order to reduce risk to public health, safety, welfare and the
environment and as a second priority to use environmentally sound
recycling to achieve these same goals.  Industrial source
reduction can be accomplished though input substitution, product
reformulation, process modification, improved housekeeping, and
on-site, closed loop recycling.  Although source reduction is
preferred to other management practices, the Agency recognizes the
value of environmentally sound recycling, and is committed to
promoting recycling as a second priority, above treatment, control
and disposal.

     Since not all pollution can be reduced or recycled, safe
treatment, control and disposal will continue to be important
components of an environmental protection strategy.  Source
reduction and recycling will not totally obviate the need for or
the importance of these processes.  Individuals as well as
industrial facilities or organizations can practice source
reduction and recycling through changing their consumption or
disposal habits, their driving patterns and their on-the-job
practices.  EPA believes that developing and implementing a new
multi-media prevention strategy, focused primarily on source
reduction and secondarily on environmentally sound recycling,
offers enormous promise for improvements in human health
protection and environmental quality and significant economic
benefits.

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III.  Development of EPA's Multi-Media Pollution Prevention
      Program

     EPA has initiated development of a comprehensive pollution
prevention program to implement this pollution prevention policy
throughout the Agency programs, whether they affect air, land,
surface water, or ground water.  EPA has established an Office of
Pollution Prevention which together with the Agency's
media-specific offices will develop and implement this program.
EPA will develop an overall Agency pollution prevention strategy,
as well as coordinate strategies among EPA's program and regional
offices.  An important emphasis of these strategies will be on
educational, technical assistance and funding support to make it
easier to build these programs into the public and private
sectors.  An Advisory Committee of senior Agency managers will
help direct EPA's pollution prevention program and will assure
the participation of the entire Agency in this important mission.

     As part of this program, EPA will establish mechanisms for
avoiding or mitigating the generation and cross-media transfer
of pollutants.  Development of EPA's multi-media pollution
prevention program will focus on several key components.  These
include:                                                       }

     o  the development of institutional structures within each
        of EPA's media-specific and regional offices to ensure
        that the pollution prevention philosophy is incorporated
        into every feasible aspect of internal EPA
        decision-making and planning;

     o  the support of State and local pollution prevention
        programs.  EPA believes that State and local agencies  are
        more aware of the problems facing the commercial or
        manufacturing industries, or consumers, than the federal
        government.  Indeed, a few States have already  formally
        recognized the importance of multi-media pollution
        prevention.  One of EPA's primary goals is to help States
        develop their own pollution prevention programs;

     o  the development of an outreach program targeted at State
        and local governments, industry and consumers,  designed
        to effect a cultural change emphasizing the opportunities
        and benefits of pollution prevention;

     o  the .creation of incentives and elimination of barriers to
        pollution prevention;

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     o  the development of a multi-media clearinghouse to provide
        educational and technical information.  This includes the
        support of research, development and demonstrations
        necessary to provide relevant data; and

     o  the collection, dissemination and analysis of data for the
        purpose of evaluating national progress in multi-media
        pollution prevention.

     EPA believes that the development of a comprehensive
multi-media pollution prevention policy offers enormous promise
for improvements in human health protection and environmental
quality.  Because the focus of pollution prevention is on greater
efficiency in the use of materials and processing of products, its
implementation could additionally result in significant economic
benefits.

     There are varying views among representatives of industry,
public interest groups, state and local governments and others
over the role of recyling in pollution prevention.  The Agency
believes that source reduction (including closed-loop, in-plant
recycling) is generally preferred over other management        
approaches.  The Agency also believes that out-of-loop and     )
off-site recycling, when properly conducted, also offers the
potential for significant economic benefits and reduced risk.
With the publication of this proposed pollution prevention policy,
the Agency would like to specifically request comment on the role
of environmentally sound recycling in the pollution prevention
program.  Other comments on this policy, and on the steps
necessary to implement  it effectively are invited.
Lee M. Thomas
[insert date]

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