I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C. 20460
April 21, 1992
OFFICE OF
THE ADMINISTRATOR
SCIENCE ADVISORY BOARD
EPA-SAB-EEC-LTR-92-007
Honorable William K. Reilly
Administrator
U. S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Subject: Science Advisory Board Letter Report on Review of ORD's Draft
"Pollution Prevention Research Strategic Plan"
Dear Mr. Reilly:
The Science Advisory Board (SAB) has completed its review of the Office of
Research and Development's (ORD) "Pollution Prevention Research Strategic Plan" (March
1991 draft), and is pleased to submit this letter report. On April 11 and 12, 1991, the
Pollution Prevention Subcommittee (PPS) of the SAB's Environmental Engineering Commit-
tee (EEC) reviewed the draft document, received detailed briefings from its developers,
considered technical arguments, and offered advice to the program office on this highly
visible topic of interest to the EPA and outside parties. Since that time, we have shared
various draft copies of a full report with ORD staff; these drafts provided extensive
comments on the document submitted to us for review.
The following findings and recommendations were extracted from the PPS draft full
report (which this letter report replaces) and are aimed at refocusing and improving the
current Pollution Prevention Research Strategic Plan (hereafter referred to principally as the
Strategic Plan).
Critical Program Findings/Recommendations
1. Responsiveness. We commend the Agency for attempting to develop a draft docu-
ment that a) ties into the research requirements of the Pollution Prevention Act of
1990, b) builds on recommendations in the SAB's Future Risk: Research Strategies
For the 1990's (EPA-SAB-EC-88-040, September, 1988) and Reducing Risk: Setting
Priorities and Strategies for Environmental Protection (EPA-SAB-EC-90-21 ,
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September, 1990 - hereafter referred as Reducing Risk) reports, which identify high
risk environmental issues amenable to pollution prevention, c) presents generic
research to address these issues, and d) describes proposed and current research
projects. The SAB was pleased to have been asked to review this document at an
early stage and to offer recommendations for improvement.
2. Strategic Planning Process. We are reluctant to refer to the document as a "strategic
plan" because, as currently drafted, it does not contain all the elements commonly
contained in a strategic plan: a vision, an assessment of the current state of knowl-
edge, and a pathway by which one moves from the current state to realization of the
vision. The document provides an informative assessment of pollution prevention
research currently in progress at the Agency. Some mention is made of a pathway.
A vision statement, however, is lacking. Without a clear expression of a vision, we
are concerned that the research effort lacks focus, which could result in confusion.
Once a vision is established, an optimal pathway can be selected, thereby maximizing
the effective use of available resources. We urge the Agency to draft a strategic plan
for pollution prevention founded upon a vision and containing an optimal pathway
approach. With the strategic plan in place, the current document could be redrafted
as a program plan which, in its current form, it most closely r;sembles.
3. Clarity/Conciseness. While comprehensiveness often is prudem for an early draft, the
final document(s) need(s) to be much clearer and more concise to have major impact.
Also, more citations are needed and acronyms and jargon need to be defined.
4. Risk/Research Selection. This overall prioritization of research activities is not
consistent with those in the Reducing Risk report that was cited '• v the Agency as one
of the guiding principles of the research strategy. For that mattwi', where there are
common elements between the two, the rankings in the Strategic Plan are inconsistent
with those identified by the SAB in its recent report on a Municipal Solid Waste
(MSW) research review (Review of the Office of Research and Development's
Municipal Solid Waste Research Program EPA-SAB-EEC-91-009, May, 1991). In
addition, the draft document also states that those issues not ranked are addressed
through other programs, yet no accounting is made of the "other programs". In view
of these inconsistencies, it would be prudent to revisit and explain the ranking in
some detail. It should be stressed that a high ranking on the SAB's list does not
provide a compelling prima facia argument for expanding or extending research in
that area. The Subcommittee is not saying that the current ranking is incorrect, just
that a risk ranking is not a priority ranking in and of itself. Since ranking ultimately
translates to resource allocation, the Subcommittee is suggesting that the ranking
process be as objective as possible and well defined. The SAB Executive Committee
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notes that the priorities in Reducing Risk and the research strategy for pollution
prevention do not necessarily have to agree, and the prioritization procedure explained
in the Strategic Plan could benefit in the future by periodically revisiting prioritization
in a less ad hoc manner. The formation of a Pollution Prevention Research Council,
such as is being considered for Social Science Research and Bioremediation Research,
is one approach to do this.
5. Responsibility. The pollution prevention initiative is new and its structure is
evolving, as is ORD's response to the initiative. Therefore, it is not surprising that
areas of overlapping responsibility exist among the programs. We recommend that
these be resolved quickly as the program matures and its leadership and coordination
emerges. To the Agency's credit, the initiative does have a matrix manager in ORD's
Office of Environmental Engineering and Technology Demonstration (OEETD).
6. Funding/Staffing. The Strategic Plan provides insufficient information regarding both
funding and full-time equivalents (FTEs) to enable one to determine if adequate
resources are available to achieve the stated objectives. In the absence of clear
information on funding and FTEs, it is not possible to assess whether the strategy can
be successfully implemented. In most endeavors, the funding and FTEs wi1. be
limited. Thus, a need exists to prioritize the limited resources to be used
7. Pollution Management. Pollution prevention research will not eliminate the need for
ongoing research in areas that serve to manage pollution. Pollution cannot be totally
eliminated and there will be a continuing need for both pollution management and
pollution prevention research. Therefore, initiatives in pollution prevention research
should not be allowed to preclude OEETD's pollution management research r ivities.
8. Terminology. We recommend that ORD establish clear and consistent consensus
terminology for pollution prevention in order to foster common goals and effective
communication. Once this has been accomplished, the terminology must be clearly
communicated both internally and externally to facilitate the implementation of the
strategic plan and technology development as well as its application. The draft
document is inconsistent, e.g., pollution prevention is defined at one point as not
including recycle/reuse, yet such a definition is included in the research strategy. The
SAB advises that recycle/reuse should be included in the pollution prevention research
strategy.
9. Measurement. As the SAB stated previously in its review of the Agency's draft
pollution prevention research plan report to Congress Review of the ORD Draft
Pollution Prevention Research Plan: Report to Congress EPA-SAB-EEC-89-037,
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September 1989), the EEC continues to be concerned about how the Agency will
measure the success of pollution prevention actions and associated research efforts.
The precision and accuracy of the information that is to be used to guide pollution
prevention should be a paramount concern, and specific research needs to be targeted
at that issue. While the 33/50 program and the Toxics Release Inventory (TRI)
database are an appropriate start and a good example of the alternative strategic
options called for by the SAB in its Reducing Risk report, they only partially address
the problem. For example, important industries, such as mining and agriculture, are
exempted from TRI reporting requirements, and accounts of environmental releases of
radionuclides and pesticides are missing.
Specific Program Recommendations
10. Treatment. Reducing waste discharges and emissions by treatment is important, but it
is not pollution prevention according to the current definition, and thus should not be
included in the Strategic Plan.
11. Global Climate. The greenhouse gases/global climate portion of the Strategic Plan
would benefit greatly from a convincing argument to support the magnitude of the
expected effect of the stated conservation research strategy. The characterization of
global climate change should be compared to the more extensive SAB reports on the
topic (e.g., Review of the Report to Congress: The Potential Effects of Global Climate
Change on the United States EPA-SAB-EC-89-016, April 1989, and Review of the
Report to Congress; Policy Options for Stabilizing Global Climate EPA-SAB-EC-89-
034, September, 1989). Better coordination on this issue should be sought with other
activities, such as those of DOE and other entities external to the Agency.
12. Pesticides. The current program dealing with pesticides application is too small and
narrowly focused on managing pesticide containers and partially utilized stocks.
More substantive pollution prevention approaches into pesticide problems should
consider research on non-chemical substitutions and more tightly restricted modifica-
tions of pesticide applications. This effort should be coordinated with the U.S.
Department of Agriculture.
13. Non-Point Sources. Of importance to a pollution prevention research Strategic Plan
would be an aggressive program to implement the most feasible pollution prevention
technologies and approaches to non-point sources of water pollution. The non-point
source water discharges section of the Strategic Plan is weak, lacking both a solid
foundation and a clear sense of criteria for establishing priorities to conduct research
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aimed at improving the knowledge base.
14. Hazardous Wastes. In response to public concern over the hazardous waste manage-
ment problem, it is imperative that the Agency have a well considered and cohesive
strategy. The Agency should take a facilitating role and continue to act as a clearing-
house of information, but not develop technology by which each individual business,
industry or facility would achieve pollution prevention, leaving that activity principal-
ly to the affected facilities and industries.
15. Consumer Products. The Strategic Plan's emphasis on consumer products appropriate-
ly reflects the growing recognition of these products as important diffuse sources of
pollution and the role of consumer demand in reducing the environmental burdens
associated with their production, use and disposal. The overall research package
includes a balanced mix of technological and non-technological approaches. Life-cycle
assessment (LCA) research is particularly important, but the LCA tool is still in the
evolutionary phase and it needs to be recognized and articulated that considerably
more research is needed before LCAs yield sound, practical, technical, and policy-ori-
ented results. Also, the relationship between the potential projects is unclear and an
overall strategy linking projects is needed.
16. Municipal Solid Waste. Consideration should be given to merging the Pollution
Prevention elements of municipal solid waste and consumer products research areas.
The Federal role is most appropriate in ensuring that waste generators, either
individual or institutional, receive adequate incentives to reduce waste at the point of
generation; hence, the importance for socioeconomic research on incentives and
disincentives.
17. Social Science. The Strategic Plan lacks sufficient programs in the social science
area, in relation to the opportunities. Therefore, the Subcommittee recommends that
serious consideration be given to incorporating specific social science research
activities into the Strategic Plan.
18. Communication. Encouragement should be given to projects which facilitate
communication and technology transfer, particularly those projects which provide
opportunities for integrating and transferring results from many of the complementary
research areas. In addition, a number of specific projects are suggested, such as:
a) A school-based program on pollution prevention activities;
b) A building-based project dealing with indoor air pollutants;
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c) Estuary, lake, or wetland projects that might be organized on both an
individual and a community level; and
d) Social science projects which examine how to identify and deal with learning
and cultural barriers to implementing pollution prevention.
19. Other Projects. Other research projects are proposed by the Subcommittee for
Agency consideration. They are briefly described as follows:
a) The Strategic Plan discussion inadvertently suggests that it is known what
"clean" (or even "cleaner") products are, and that simply getting the data out
to consumers will solve the problem. An extremely important research
element would be to attempt to identify those characteristics of products that
are particularly desirable or undesirable, i.e., to devise objectives for
.clean-product research.
b) The Agency should consider research on broadening its perspective and
shifting the focus from product categories to the function performed by a
product. The current and proposed research may miss wholly different ways
of achieving utility derived from a product use if problems are described too
narrowly. Moreover, focusing on pollution reductions or other improvement
measures per unit of product does not address other generic issues, such as
overall levels of consumption. Several projects can be given as examples to
achieve a broader perspective, such as toxic versus nontoxic cleaners for
household use and toxic versus less toxic pesticides for yards and gardens.
c) Institutional consumers can play a major role in changing the specifications of
various materials purchased, yet relatively little is known about their decision-
making process. Case studies of institutional purchasing decisions could
provide such information.
d) Several universities have altered their curricula to include pollution prevention
emphasis and/or options. There is a need for continuing education programs
for designers and engineers who are already in the work force. The Agency
could facilitate this by developing environmental education programs for
product designers and production engineers.
20. Labeling. There is substantial EPA-sponsored research on the effects of product
labeling of hazardous consumer products. Adequate justification for including the
consumer labeling project is not presented in the research plan. Such justification
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should be either provided or the inclusion of the project reconsidered. The
justification provided should also suggest how the labeling research projects should be
designed.
21. Criteria Air Pollutants. The Strategic Plan does not appear to contain any new efforts
in the area of criteria air pollutants. Current research on means to reduce volatile
organic compound emissions from consumer products use appears to be well planned.
However, means to transfer findings to the users needs to be addressed.
22. Transportation. Transportation planning should be included in the Strategic Plan.
The Plan should be open to innovative ideas that may be more cost effective as well
as acceptable to the public.
23. Batons. The halon research is well conceived. However, two of the proposed
research areas (brominated dimethylfluoroethers as halon substitutes and alternatives
to chlorofluorocarbons and methyl chloroform) might be better accommodated within
the private sector.
24. Anticipatory Research. The Strategic Plan lacks a viable framework for preventing
future pollution problems. Pollution prevention is proactive in principle, and more
emphasis needs to be given to anticipatory research.
In summary, the Subcommittee believes that the Strategic Plan is a significant early
step along the path to establishing Pollution Prevention as an Agency paradigm. We
understand that ORD has already begun to respond to our recommendations for improvement
of the ORD draft document, and look forward to your response.
Sincerely,
Raymond C. Loehr, Chair Richard A. Conway, C
Executive Committee Environmental Engineering Committee
Science Advisory Board Science Advisory Board
ayne M. Kachel, Chair
Pollution Prevention Subcommittee
Environmental Engineering Committee
Science Advisory Board
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NOTICE
This report has been written as a part of the activities of the Science Advisory Board,
a public advisory group providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency. The Board is
structured to provide a balanced, expert assessment of scientific matters related to problems
facing the Agency. This report has not been reviewed for approval by the Agency; hence,
the comments of this report do not necessarily represent the views and policies of the
Environmental Protection Agency or of other Federal agencies. Any mention of trade names
or commercial products does not constitute endorsement or recommendation for use.
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ADVISORY BOARD
ENVIRONMENTAL ENGINEERING COMMITTEE
POLLUTION PREVENTION SUBCOMMITTEE
Dr. Wayne M. Kachel, Technical Advisor, Pilko & Associates, Inc. Houston, TX
Vice-Chairman
Dr. Robert B. Pojasek, Vice President, GEI Consultants, Inc., (formerly of Geraghty &
Miller, Inc.) Andover, MA
MEMBERS & CONSULTANTS
Mr. David M. Benfbrado, Senior Environmental Specialist, 3M, St. Paul, MN
Dr. Joan *ierkowitz, Farkas Berkowitz & Company, Washington, DC
Ms. Cnristine Ervin, Oregon Department of Energy, Salem, OR
(Formerly of the World Wildlife Fund and The Conservation Foundation)
Dr. Frederick G. Pohland, Weidlein Chair of Environmental Engineering, University of
Pittsburgh, Pittsburgh, PA
Dr. GeraJ" V. Ppje, Green Seal, Washington, DC
Dr. Walter M. Shaub, Solid Waste Association of North America, (SWANA), (Formerly,
U.S. Conference of Mayors, Technical Director of the Coalition on Resource Recovery and
the Environment, CORRE), Washington, DC
Dr. John D. Spengler, Department of Environmental Health, Harvard University School of
Public Health, Boston, MA
Science Advisory Board Staff
Dr. K. Jack Kooyoomjian, Designated Federal Official
Mrs. Diana L. Pozun, Staff Secretary
Dr. Donald G. Barnes, Staff Director, Science Advisory Board
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