&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9200.4-1
TITLE: GUIDELINES FOR PRODUCING SUPERFUND DOCUMENTS
APPROVAL DATE: 2/9/87
EFFECTIVE DATE: 2/9/87
ORIGINATING OFFICE:
O FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
VE DIRECTIVE DIRECTIVE D
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6 EPA
United States Environmental Protection Agency
Washington, OC 20460
OSWER Directive initiation Request
1. Directive Number
9200.4-1
27 Originator Information
Name of Contact Person
Betti VanEpps
Mail Code
548-D
Office
PAS
Telephone Number
475-8864
3. Title
GUIDELINES FOR PRODUCING SUPERFUND DOCUMENTS
4. Summary of Directive (Include brief statement of purpose!
Instructs writers of Superfund directives on the production of well-written documents
that clearly set out guidance on policy implementation, procedural requirements and
applicable technology, as applied to the Superfund program operation.
5. Keywords
Superfund, CERCLA. Directives
6a. Does this Directive Supersede Previous Directives)? | | Yes |x No What directive (number, title)
b. Does It Supplement Previous Directives)? f_] Yes fxi No What Directive (number, title)
7. Draft Level
LJ A — Signed by AA/DAA LJ B — Si.
gned by Office Director
DC-
For Review & Comment
D
In Development
This Request Meets OSWER Directives System Format
. Signature^ Lead OffigjcDirectives Coordinator
Date
2/9/87
. Name and Title of ApprovinaOffjgaV^, . „- „
Henr,y I. Longest, II, Director, OERR
Date
2/9/87
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
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OSWER DIRECTIVE 9200.4-1
GUIDELINES FOR PRODUCING SUPERFUND DOCUMENTS
I. ISSUE STATEMENT: The purpose of these guidelines is to provide writers
of Superfund documents with assistance in writing guidance docu
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OSWER DIRECTIVE 9200.4-1
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A. Purpose of Guidance
Superfund guidance is primarily intended to help users implement the
program effectively and consistently. Individual documents may be designed
to serve one or more of the following purposes:
°To provide information and direction regarding procedures, policies,
and technical developments which assist program personnel in conducting
daily business uniformly and consistently throughout the country. This
establishes a pattern for solving specific types of problems.
°In lieu of regulation. Vfliere regulations are silent, and formal
policy documents are inappropriate, guidance documents can provide
general direction to assist the user in solving particular types
of problems.
°As a response to requests for assistance from persons implementing
the program.
In Superfund, the actual writing of guidance usually occurs in Head-
quarters program offices, developed by workgroups which represent a cross-
section of the users. However, it can originate from top-down or bottom-up,
depending upon who perceives the need for the guidance and who initiates
the process. Much of the Superfund Guidance has been developed through a
bottom-up procedure, with significant contributions coning from Regions,
States, and other user groups.
Guidance should be used for the same variety of reasons that it is
written: to assure the consistent, effective implementation of the
program. While guidance is intended to be flexible, e.g., to be applied
to a situation consistent with best professional judgement, it can also be
used to strengthen the manager's position in handling unfamiliar situations.
B. Types of Guidance
Currently, four types of non-regulatory Superfund documents are
produced and generically referred to as "guidance".:
0 Guidance Documents
0 Procedural Documents
0 Technical Documents
0 Manuals
Each serves a different function, as discussed below. Individual docu-
ments may stand alone or make reference to others; taken together, they
form a body of information which establishes pattern and practice as the
program matures.
0 Guidance Documents explain what can be done to fulfill the require-
ments of a regulation or policy.
Generally, they cover a subject broadly and even comprehensively, but
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OSWER DIRECTIVE 9200.4-1
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should not spell out specific steps of an approach. Instead, they explain
ideas which might be considered rather than how a required analysis or
test might be conducted; or they may describe an analytic process, but do
not discuss the mechanics of carrying out the process.
EXAMPLE: Guidance on Remedial Investigations and Feasibility
Studies Under CERCLA; Relationship of the Removal and
Remedial Program Under the Revised NCP
0 Procedural Documents describe specifically how to conduct an analysis
or activity; they provide a sufficient level of detail to complete an action
without need for additional guidelines. They often provide a step-by-step
procedure for conducting an action, including how to fill out forms where
appropriate. They may also deal with the concrete mechanics or methods
of an operation.
EXAMPLE: ERGS Contracts Users' Manual; Quality Assurance/Field
Operations Methods Manual
0 Technical Documents provide scientific or engineering information
relevant to program activities. They act as reference documents for use
in complying with requirements, but do not explicitly relate the technical
information to requirements. They are often products of scientific research
or development conducted for program support.
EXAMPLE: Remedial Action at Waste Disposal Sites; Mobile Treatment
Technologies for Superfund Wastes
0 Manuals combine features of all of the above categories, particularly
guidance and procedural documents. They enable users to carry out the
program activities or requirements discussed without need for other supporting
program documents.
EXAMPLE: Public Health Evaluation Manual; Compliance Manual
IV. GUIDELINES FOR WRITING SUPERFUND DOCUMENTS
A. Keeping the user In Mind
Users of guidance represent a cross-section of individuals having a
wide variety of responsibilities. Guidance is used in Headquarters to
define the program and to measure the program's effect when assessing
results. It is used by Regional and State administrative offices to pro-
vide direction to office and field staff and to contractors and PRPs.
Some of those in the latter categories may have little or no knowledge of
the inner workings of EPA or the Superfund program. Thus, the guidance,
combined with direction or verbal information obtained from Agency personnel,
may constitute the basis of their experience with the Agency.
In addition, field personnel who are away from their offices for
long periods of time, with limited telephone access and limited storage
and transporting capabilities, require documents that are accessible
as well as brief, transportable, and concise.
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OSWER DIRECTIVE 9200.4-1
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Insofar as possible, when creating a guidance document, writers
should consider the audiences. The bottom line is that if the guidance
is not (1) accessible, (2) readable (3) brief and to the point (4) clear
and (5) transportable, it probably will not be read—and if it's not
read, it will not be used.
B. Structuring a Guidance Document
Field and program personnel who work with a wide spectrum of problems
need documents that are easily and quickly consulted to provide immediate
information. They do not have time to search voluminous material to
secure an answer to what appears to them to be a straightforward question.
A consistent format saves many hours of research time for the user.
The following proposed structure allows the reader to become quickly
oriented to the issues at hand, then proceed to in-depth material which
can be absorbed as time allows.
0 Issue Statement - The document should begin with a clear, concise
statement of the issue to be discussed.
0 Executive Summary - This section serves two purposes, and may also
be serving several different audiences. First, it should enable the
reader to quickly determine if the document is pertinent. It sketches
the most important points, and indicates where in the document more
in-depth information is contained. Secondly, it can convey a basic message
to the policy manager who may never read the entire document. In many
documents, it also acts as a briefing for upper level rnanagers regarding
the major policy issues embodied in the larger document.
0 Introduction and Background - This section introduces the material
to be presented, may provide historical reference, cites pertinent regula-
tions, statutes or other existing documents and sources of related infor-
mation. It can also provide lead-in for the prescriptive material which
follows in the next segment.
0 Prescriptive Material. This segment provides any prescriptive
material applicable to the matter at hand, flagged or underlined. (Pre-
scriptive material is defined as that which is mandated or required by law
or regulation.)
0 Expository Information. The narrative that constitutes the actual
guidance is placed here, together with case studies, examples, and other
appropriate illustrative material. This provides the next level of
detail for the reader who has concluded that this document addresses the
needs of the situation and now wishes in-depth information.
0 Referencing Section. This segment includes cross-referencing
to other documents, identified by their OSWER identification number, if
available; or by their date and source where no OSWER number has been
assigned. In addition, it should include the name of -a contact with
phone number for obtaining further information. Larger, more comprehen-
sive documents might include glossaries and indexes.
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OSWER DIRECTIVE 9200.4-1
C. Language and Streamlining Techniques
The choice of language affects the user's ability and/or willingness
to implement the guidance. Because "guidance," by definition, is not
prescriptive unless it cites specific regulatory or statutory requirements.
the language style should be flexible rather than rigid. The most common
illustration of flexibility is the use of "may," which is flexible, rather
than "must" or "shall," which connote inflexibility.
When guidance contains prescriptive material, it should be referenced
back to the appropriate regulatory or statutory citation. It is then advisable
to separate or set off the prescriptive material by means of starring,
flagging, underlining, or paragraphing so that it stands out.
Streamlining means coming immediately to the point or heart of the
matter with a minimum of verbiage. It results from visualizing the
finished product and producing a final document that mirrors this concept.
Below are a series of suggestions which can assist the writer in
producing readable, usable guidance.
0 Outline the document, and write from the outline. Outlines need
not be formal; they can take the form of concise bullets that
become the organizing points for the document, and can even be
developed into topic sentences. Picture the user and the constraints
under which that individual operates. Visualize the final document
and its intended purpose for the program and for the user.
0 Establish a style consistent with the purpose of the document.
Remain with that style until the document is completed. While style
can be individual, it is also true that each of the four document types
has its own style, and that style has an effect on the reader.
For example, technical documents which inform the user of new tech-
nology or new information tend to be most effective when the style is
concise and direct.
Procedural documents often set forth specific steps, tasks, or
operational steps which the reader is to follow. These documents are
sometimes the least flexible of the four types. The style should be
simple and straightforward, with complete, direct sentences. Emphasis
should be on an orderly, clear presentation.
Guidance documents frequently offer an array of options and case
studies, to which the user may apply best professional judgment in
adapting to the situation at hand, within the broad parameters of
the guidance. The writing style can be somewhat .nore flexible and
expository.
Manuals, in that they stand alone in implementing part of a
program, frequently combine elements of the other documents. They
may be the most lengthy of the four, and may include technical
information with specific procedures and an array of options. Style
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OSWER DIRECTIVE 9200.4-1
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will therefore emerge as a composite of the others.
In selecting the appropriate style, it is useful to remember that nouns
and action verbs written in the active voice supply greater power and empha-
sis than writing with adjectives and adverbs and in passive voice. Further,
impersonal language increases the rigidity or inflexibility of the document.
The language used in a regulation or directive is more impersonal than
that used in a simple memorandum.
For example:
Rigid; "To comply with this provision, the owner/operator
must determine whether a bulk hazardous waste is a liquid
or contains free liquid. EPA regulations define "free
liquids" as "liquids which readily separate from the solid
portion of a waste under ambient temperature or pressure."
(40 CFR 260.10)...EPA believes that the Paint Filter Liquids
Test is the appropriate test to be used to determine the
absence or presence of free liquids in bulk and containerized
waste."
(Note the prescriptive material quoted and referenced)
Flexible; "This step is designed to facilitate responses to clear-
cut, time-critical emergencies for which only limited data are
available. In those cases, OSCs may have to rely primarily on
findings of the preliminary assessment, without significant
additional data collection... .Vftiere the OSC n/ts determined that
the incident is not time-critical, a more thorough analysis...will
be possible before recommending a...response."
0 Limit explanation. Select simple words and omit needless words. The
reader has limited reading time. "Less is more" is often a useful concept
in government writing.
For example:
Excessive Detail; "Implementing the notification program will
require both staff time and the direct expenditure of funds. You
will find guidelines on typical costs of various activities through-
out this handbook. The available funding and staffing level will
have an impact, for example, on how extensive the public education
program can be and which methods of form distribution can be used.
State budget allocations will also impact the types of activities
possible. Some states will find that they have adequate staffing
but little money to pay for printing and travel, while other
States may experience the opposite."
Concise; The scope of the rulemaking will be limited to municipal
landfills because, currently, reliable data on which to construct
and defend sound Criteria exist only for municipal waste landfills.
Moreover, by limiting the rule, the Agency can expect to promulgate
the revisions within the Statutory deadline of March 31, 1988.
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OSWER DIRECTIVE 9200-4.1
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0Avoid unexplained acronyms/ unexplained technical terms, and program-
specific language not part of the general experience of the reader. The
standard Agency practice of writing a phrase in full with the acronym in
parentheses at the beginning of the article is helpful. Even so, assumptions
that the reader has the same working knowledge of the subject as the writer
can be unwarranted. Many readers find themselves intensely irritated at
government writing which requires the constant translation of acronyms
and jargon. In extensive documents requiring acronyms, inclusion of a glossary
can be helpful.
For example:
(1) "You should begin exploring mechanisms to implement
CA's with OFA Regional counterparts early in the FY
about sites in Regions targeted for CERCLA action.
This should be accomplished by review of the NPL,
the SMP, and the SCAP. The SCAP commitments should
be reflected, as appropriate, in the SEA's for your
Region."
(2) "You should begin exploring mechanisms to implement
cooperative arrangements with Office of Federal
Activities (OFA) Regional counterparts early in the
fiscal year. This should be accomplished by review
of the National Priorities List (NPL), the Site
Management Plan (SMP), and the Superfund Compre-
hensive Accomplishments Plan, (SCAP). The SCAP
commitments should be reflected, as appropriate, in
the State/EPA Agreements for your Region."
"Summarize when appropriate. Use of summaries depends upon the degree
of complexity of the material being presented. When the material is lengthy
and complex, it may be useful to summarize at the end of sections or
chapters, or it may be useful to present a final summary at the end of the
document. Another effective technique is the use of bullet points at the
beginning of sections to highlight main points. In addition, careful
construction of the Executive Summary assists both writer and reader in
keeping to the point.
°When revising and rewriting, look for redundancy, strive for clarity,
and reduce detail when possible. Then recheck the editing to be sure
the meaning hasn't been lost. Short, complete sentences placed in logical
order with logical paragraphing simplify the work of the reader. All para-
graphs should have topic sentences at the beginning or the end. The final
editing effort is the comparison of the finished product with the writer's
initial concept and the mental picture of the user. How well do they match?
Will the reader be able and willing to understand the writer's message?
Only when the match is achieved, is it time for others to review the document.
D. Content.
Appropriate Level of Detail. There are two considerations with re-
gard to detail. The first is that the level of detail should be appropriate
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OSWER DIRECTIVE 9200.4-1
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to the document. As a rule, procedural documents require the most detail
and specificity, technical documents somewhat less, and guidance documents
least of the three. Manuals will be a composite and should have a level
of detail appropriate to the subject.
Secondly, consideration should be given to the amount of detail needed
by the various users. Mule the material may be applicable to a variety
of situations, some users may need less detail. Where more detail is
required, it should be presented and organized so that it does not distract
such users.
It is the writer's job to determine the appropriate level of detail in
planning and outlining the document.
Technically Correct. The writer is responsible for presenting a
final document that is technically correct and to conduct whatever reviews
and checks are necessary to assure that the document is in fact correct.
Prescriptive Only When Required. Guidance should be assumed to be
"guidance" unless otherwise stated. "Best professional judgment" should
be assumed unless the document specifically flags prescriptive (mandatory)
material. When these flags are present, statutory or regulatory references
should be cited, as well as appropriate back-up policy or precedential
material. Otherwise, flexibility should be assumed and language should
be constructed accordingly.
Filing, Indexing, and Follow-Up Information have been discussed in
Section B. However, each document should end with a section that provides
assistance in obtaining additional data, and in filing and cross-referencing.
E. Classification.
Documents have been classified for general use in the Superfund
Program. The four classification types previously discussed are designed
to be broad and flexible, while giving users a clear idea of the kind
of information presented in each. As the system evolves, it is anticipated
that each kind of document will be identified by a characteristic cover
which makes it easily identifiable.
In addition to the Superfund classification system, each document
will, of course, be assigned an OSWER Directives Number and be included
in that indexing system. Beyond that, institutional users (Regional
or State offices, others) may wish to develop their own internal filing
or reference system. The classification system, plus the Issue Statement
and Executive Summary at the beginning of each document, will facilitate
the design of such a system.
(F) Considerations in Publishing a Document
Once a document text has been prepared and approved for publication,
a variety of publication requirements and procedures are triggered. Since
these are-important in assuring that all agency requirements are met, they
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OSWER DIRECTIVE 9200.4-1
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will be the subject of a subsequent procedural guidance. Coordination of
publication procedures is the responsibility of the Office of Program
Management, OERR.
FOLLOW-UP INFORMATION OR CONTACTS
(1) For general writing information - THE ELEMENTS OF STYLE, by William
Strunk, Jr. and E.B. White, Third Edition, MacMillan Publishing Co.,
Inc., New York 1979.
(2) For information about OSWER Directives System - Contact Sherry Fielding,
OSWER Directives Coordinator, Immediate Office, Assistant Administrator
for Solid Waste and Emergency Planning - FTS 382-4483
(3) For information about the Guidance Review Project or OERR Guidance,
contact Arthur B. Weissman, Policy Analysis Staff, Superfund Program,
FTS 382-2182.
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