Chemicals in Progress

      2 TRI Releases Decreased
        by 334 Million Pounds
        in 1991

     3  EPA Plans to Expand
        the TRI

     22 OPPT Proposes New
        Strategy for Information

     24 OPPT Assessing Health and
        Environmental Effects of
        Cleaning Products Used in
        Government Buildings
OPPT's Pollution Prevention  Strategy

For Toxic Chemicals

By Mark A. Greenwood
Director, Office of Pollution Prevention and Toxics

The Office of Pollution Prevention and Toxics (OPPT) prepared this
paper as a working draft for a discussion organized under the auspices of
the American Chemical Society. The paper lays out new directions that
OPPT is developing to carry out its responsibility for preventing pollu-
tion and reducing risks associated with the manufacture and use of exist-
ing chemicals. The paper does not present a comprehensive plan for all
OPPT work. The office's responsibilities in areas outside of existing
chemicals, such as for new chemicals and for the promotion of other pol-
lution prevention strategies (such as environmental cost accounting) are
not included.
The paper is in draft form and is presented to help initiate a broad-based
discussion with interested parties. OPPT hopes to learn from these dis-
cussions how to develop the ideas discussed below and to identify con-
structive follow-up actions.

I. Change to a mission-based definition of the OPPT program

The past several years have been a time of important change for OPPT.
Much of this change has been a result of OPPT's new responsibilities as
national program manager for pollution prevention in EPA. The focus  on
pollution prevention is the result of lessons learned from years of experi-
ence in carrying out the agency's statutory mandates. The changes in
OPPT also reflect new attitudes and strategies for environmental protec-
tion being embraced by industry, public interest groups, states, and other
elements of  the public. The tools of public policy must change to reflect
the changing expectations and capabilities of these customers.

The creation of a comprehensive pollution prevention program is the goal

OPPT continued on page 13
     VOL. 14 / NO. 3 NOVEMBER 1993

     Toxics Release Inventory
TRI Releases Decreased by 334 Million Pounds  in 1991
U.S. manufacturers managed or
released 38 billion pounds of toxic
chemicals during 1991, according
to data submitted to EPA's Toxics
Release Inventory (TRI). Of that
amount, more than 20 billion
pounds were recycled and about 13
billion pounds were treated or con-
verted into energy.

About  3-36 billion pounds of toxic
chemicals were released to the
environment—almost 10 percent
less than the quantity released in
1990. This decline in chemical
releases continues a trend: TRI
data show  that emissions to air,
water, and  land have dropped 30
percent from 1988 to 1991-
About  1.07 billion pounds of
wastes  were transferred off-site for
treatment  or disposal in 1991, a
decrease of 1.2 billion pounds
from 1990,

New TRI information
The TRI, which is available to the
public, includes detailed data on
the releases and transfers of toxic
chemicals from manufacturing
facilities across the nation. The
1991 reporting year was the first for
which EPA collected information
on how industry manages its
wastes. Thus, the 1991 TRI pro-
vides a more complete picture of
waste generation and management
than did previous inventories.

The TRI is required by section 313
of the 1986 Emergency Planning
and Right-to-Know Act (EPCRA).
The information on waste manage-
ment is required by the Pollution
Prevention Act of 1990. Required
information includes recycling,
energy recovery, and source-reduc-
tion activities.
Since 1987, about 24,000 indus-
trial facilities have reported annu-
ally on more than 300 chemicals,
including 20 chemical classes.
EPA received 81,545 reports for
the 1991 reporting year.
   TRI data show that
    emissions to air,
     water, and land
      have dropped
    30 percent from
      1988 to 1991.
Summary of 1991 TRt data
Releases to air. 1991 TRI data show
that 1.98 billion pounds of toxic
chemicals were released to the air,
a decrease of more than 13 percent
from the 1990 total of 2.28 billion
pounds. EPA attributes this
decrease to reduced emissions of
industrial solvents.
Releases to water. 1991 TRI data
show that about 244 million
pounds of toxic chemicals were
released to the nation's rivers,
streams, and other bodies of water,
an increase of almost 24 percent
from the 1990 total of 197 million
pounds. EPA attributes this
increase to runoff from an incident
involving four fertilizer facilities in
Louisiana. Without  this runoff,
water releases would have declined
7 percent, according to EPA.
Releases to land.  1991 TRI data
show thac about 421 million
pounds of toxic chemicals were
released to land, a decrease of 9
percent from the 1990 total of 463
million pounds.
Underground injection. 1991 TRI
data show that about 710 million
pounds of toxic chemicals were
injected underground, a decrease
of 5 percent from the 1990 total of
745 million pounds.

For more information
•  To obtain the 1991  Toxics
   Release Inventory: Public Data
   Release, EPA 745-R-93-003,
   contact the EPCRA Hotline
   at (800) 535-0202 or
•  For information on  obtaining
   access to the TRI database in
   the National Library of Medi-
   cine's TOXNET system, call the
   library's TRI representative at
•  For information about other
   ways to gain access to the TRI,
   contact the EPCRA Hotline at
   the number listed above.

                                       Toxics Release Inventory
EPA To  Collect More TRI  Data in the  Future
EPA plans a significant expansion
of the Toxics Release Inventory
(TRI). Early next year, the agency
expects to propose a rule that
would add more than 300 chemi-
cals to the TRI reporting list. By
next fall, the agency plans a sec-
ond proposed rule that would
require additional types of facili-
ties to report.
The additional data will provide a
more complete picture of chemical
releases in our nation's communi-
ties.  It will  also be useful for iden-
tifying further opportunities for
pollution prevention.

Why expand TRI?
The TRI was the first program
that  made information about
chemical releases and  transfers
readily available to the public.
Since the first year of reporting in
1987, the usefulness of TRI data
has become increasingly evident.
The public, the government, and
the regulated community use TRI
data to compare the levels of
releases and chemical  wastes
among states, industries, facilities,
and environmental media.

The  Emergency Planning and
Community Right-to-Know Act
(EPCRA), which established the
TRI, also defined the  manufactur-
ing facilities that are required to
report and the chemicals for which
reporting is required.  About 300
toxic chemicals and chemical com-
pounds are listed in section 313 of
EPCRA. The facilities required to
report are those manufacturers that
have 10 or more full-time employ-
ees and that are in the U.S. Com-
merce Department's Standard
Industrial Classification (SIC)
codes 20 to 39- Federal facilities
were not included.
EPCRA gives EPA the authority
to modify both the list of chemi-
cals and the type of facilities
required to report. Thousands of
chemicals in commerce, in fact,
may meet the criteria of the law
for TRI reporting. Furthermore,
many sectors of the economy
process, use, and even manufacture
many toxic chemicals that are cur-
rently reportable. It is as  appropri-
ate for the public to know about
these releases as it is for them to
know about releases from manufac-
turing facilities.

For 1991, the most recent year for
which EPA collected data, 83,000
TRI reports were submitted by
about 23,000 facilities. Despite the
large amount of data collected, envi-
ronmental groups have for many
years asked EPA and Congress to
add more chemicals to the report-
ing list. Last year, a legislative effort
by Senator Frank Lautenberg (D-NJ)
and former Representative Gerry
Sikorski (D-MN) to add almost 600
chemicals to the TRI failed. At the
same time, EPA began exploring
how to expand the TRI.

Two-phased approach
EPA plans to expand the  TRI in
two phases. In May 1993, EPA
Administrator Carol Browner
announced EPA would propose a

TRI Data continued on page 4
Chemicals Under

• Clean Air Act, section 112(b),
  as amended in 1990: Hazardous
  Air Pollutants
• Clean Air Act, section 602(b):
  Class II ozone-depleting
• Clean Water Act, section
  307(a): Priority pollutant list
• Federal Insecticide, Fungicide,
  Rodenticide Act (FIFRA), sec-
  tion 6: Special review, canceled/
  denied or suspended, and
  restricted use pesticides
• Resource Conservation and
  Recovery Act, section 3001 and
  chemicals listed at 40 CFR
  26l.33(f) and in appendix VIII
• EPCRA, section 302: Extremely
  hazardous substances
• Comprehensive Environmental
  Response, Compensation, and
  Liability Act, section 102
• Safe Drinking Water Act, sec-
  tion 1412, as amended
• The State of California Safe
  Drinking Water and Toxic
  Enforcement Act of 1986
  (Proposition 65): List of chemi-
  cals known to the state to cause
  reproductive toxicity
In addition, EPA considered chem-
icals designated as possible, proba-
ble, or known carcinogens in the
Monographs  of the International
Agency for Research on Cancer and in
the 6th Annual Report on Carcinogens
of the National Toxicology Program,
published by the U.S. Department
of Health and Human Services.
                                        VOL. 14/NO.3 NOVEMBER 1993

                             Toxics Release Inventory
 TRI Data continued from page 3

rule to add at least 170 chemicals
to the TRI list. Browner said that
EPA will announce a candidate list
of additional facilities by next
spring or by the time of the next
TRI data release.
This is not the first time that EPA
has modified TRI reporting
requirements. In 1989, for exam-
ple, EPA added nine chemicals to
the TRI list (54 FR 49948, Decem-
ber 1, 1989). In addition, EPA has
made a number of changes to the
TRI list in response to petitions
submitted to EPA under section
313(e). As of August 1993, in
response to these petitions, EPA has
deleted 12 chemicals from  the TRI
list and added 16.

Phase 1: Process for adding chemicals
to the TRI list. As a starting point,
EPA is examining the more than
                        1,000 chemicals regulated under
                        various statutes. To screen such a
                        large number of chemicals, EPA
                        developed a methodology and some
                        criteria for prioritizing chemicals
                        for further evaluation. According
                        to EPA's schedule, the newly desig-
                        nated TRI chemicals would be
                        reportable for the first time on TRI
                        reports due July 1, 1994.

                        The statutes that contain the
                        chemicals that  EPA is considering
                        for addition to  the TRI list are
                        shown in the list on page 3.
                        Phase 2:  Process for adding facilities
                        to the TRI list. EPA is considering
                        requiring facilities that perform
                        manufacturing-like activities to
                        report to the TRI. These facilities
                        mix, formulate, or distribute mate-
                        rials that contain TRI chemicals.
                        EPA is also examining treatment
                        and disposal facilities,  which are
                                   not required to report even though
                                   many receive wastes containing
                                   TRI chemicals. Newly listed facil-
                                   ities would have to provide TRI
                                   reports by July 1, 1995.
                                   Many federal facilities are also sig-
                                   nificant customers of the chemical
                                   industry. The process for obtaining
                                   TRI information from these facili-
                                   ties has already begun. In August
                                   1993, President Clinton directed
                                   federal facilities to submit TRI
                                   reports beginning with calendar
                                   year 1994. (See article on page 5.)

                                   For more information
                                   Call Maria Doa, of OPPT's Envi-
                                   ronmental Assistance Division, at
                                   (202) 260-9592, or Tim Crawford,
                                   of OPPT's Environmental Assis-
                                   tance Division, at (202) 260-1715.
                                   Or, write to them at the address on
                                   page 43.
Update on TRI  Section 313  Petitions
Anyone can petition EPA to add or
delete a chemical from the list of
toxic chemicals that are subject to
Toxics Release Inventory (TRI)
 Receipt Date  Chemical Name
                        reporting. The list on this page
                        shows petition activity occurring
                        from January 1993 through
                        August 1993.
                                   For more information, call Maria
                                   Doa at (202) 260-9592 or the
                                   EPCRA Hotline at (800) 535-0202
                                   or (709) 412-9877.
                                                   Action    180-Day Proposed Rule  Final Rule or
                                                  Requested   Deadline  FR Pub Date  Denial Pub Date
 Petitions Pending
 10/6/92      Cr, Mi, Cu, in Brass, Bronze
            and Stainless Steel
 03/05/93     Cl Pigment Blue 15:1
 Proposed Rules
Barium Sulfate
Barium Sulfate
Di-N-Octyl Phthalate
                        Stillwater Fasteners              Exempt   04/06/93     /  /          /  /

                        Color Pigments Manufacturers Assn.  Delist    09/08/93     /  /          /  /
Chemical Products Corp.           Delist      /  /     06/11/93        /  /
Dry Color Manufacturers Assn.      Delist      /  /     06/11/93        /  /
Vista Chemical Company           Delist      /  /     01/13/93        /  /
                                          CHEMICALS IN PROGRESS

                                       Toxics Release Inventory
Clinton Tells  Federal  Agencies to Reduce Pollution,
Report  to  TRI
On August 3, 1993, President
Clinton signed an executive order
that requires federal facilities to
comply with planning and report-
ing provisions of the Emergency
Planning and Community Right-
To-Know Act and the Pollution
Prevention Act of 1990. The exec-
utive order goes beyond these laws'
requirements, though, asking fed-
eral facilities to lead the nation in
preventing pollution and adhering
to right-to-know principles.

Here is a summary  of the executive
order's major requirements:

• Federal agencies are required to
   submit Toxics Release Inventory
  (TRI) reports beginning with
  the 1994 calendar year. The sub-
  mission deadline for the 1994
  calendar year is July 1, 1995.

  Federal agencies are required to
  establish voluntary goals to
  reduce all TRI chemical releases
  and transfers for treatment and
  disposal. The goal for reductions
  is 50 per cent by 1999. Some
  agencies are expected to broaden
  their voluntary goals and reduce
  other pollutants as well.

  Federal agencies are required to
  develop and make public their
  plans for reducing or eliminating
  the manufacture, processing, and
  use of toxic chemicals and
  extremely hazardous substances.
  As part of this effort, agencies are
  to review and modify procure-
  ment and acquisition practices
  and generally employ source
  reduction as a first method of
  choice to reach their goals.

EPA will be responsible for moni-
toring compliance for this executive
order and will also set up an incen-
tives program. The Federal Govern-
ment Environmental Challenge
Program will recognize outstanding
environmental management by fed-
eral agencies and their employees.
California Asks U.S. Facilities to File TRI Reports
U.S. military bases and Depart-
ment of Energy facilities located in
California were asked by the state
to report their releases of toxic
chemicals to the California Depart-
ment for Environmental Protec-
tion. Federal facilities are exempt
from the federal law that requires
industrial facilities to report releas-
es of toxic chemicals to the U.S.
EPA. EPA compiles the data in the
Toxics Release Inventory (TRI).
Many states also require TRI
reporting and maintain their own
TRI databases.

"This action puts the government
on the same footing as private
companies," said Jim Strock, Sec-
retary of the Department for
Environmental Protection. On
March 1, Secretary Strock asked 42
military bases and six U.S. Energy
Department facilities to file TRI
forms no later than July 1, 1993.

State TRI coordinator Steve Hanna
said that two military bases have
agreed to submit TRI reports by
the deadline, two bases plan to
submit reports by July 1, 1994,
one base is preparing guidance for
submitting data, and 13 bases
refused to report. One base said it
is closing and another said it does
not process or use any TRI sub-
stances in the threshold amounts
required for reporting. Other
responses are expected in the
Two Department of Energy facili-
ties agreed to report, Mr. Hanna
said. One facility said it is below
the reporting threshold, one stated
it would not report, and two did
not respond. About the same time,
the Department of Energy
announced it would file TRI forms
for all of its facilities starting on
July 1, 1994.
The state request parallels similar
activities occurring at the federal
level. In August 1993, President
Clinton issued an executive order
requiring all federal facilities to
file TRI reports by July 1, 1995.
(See article on this  page.)
      VOL. 14/NO.3 NOVEMBER 1993

     Existing Chemicals Program
TSCA  Chemical Testing Program: Implementing  a  Program
for the '90s
By Joseph S. Carra
Deputy Director, Office of Pollution Prevention and Toxics
The Chemical Testing Program
was established in EPA's Office of
Pollution Prevention and Toxics
(OPPT) to carry out the policy
expressed in section 2 of the Toxic
Substances Control Act (TSCA)
that adequate data be developed
with respect to the health and
environmental effects of chemical
substances and that the develop-
ment of these data is the responsi-
bility of chemical manufacturers
and processors. In recent years,
OPPT has received criticism (e.g.,
from the Government Accounting
Office, Congress, environmental
groups) for a general "lack of pro-
ductivity" in its TSCA Chemical
Testing Program. While criticism
of past productivity is deserved,
OPPT's TSCA Chemical Testing
Program has made substantial
progress and the prognosis for the
future is positive.

The early years
Since the enactment of TSCA in
1977, OPPT and the Interagency
Testing Committee (ITC) have
reviewed a large number of the
70,000 chemicals listed on the
TSCA Chemical Substances Inven-
tory to determine the need for
health and/or environmental test-
ing. (The ITC is a federal intera-
gency body established by TSCA
that makes recommendations to
EPA about testing.) For example,
the ITC, in fulfilling its mandate
under section 4 of TSCA, has
reviewed in excess of 50,000
chemicals to determine if testing is
needed to characterize potential
health and/or environmental risks.

As a direct result of years of chem-
ical screening efforts, OPPT has
determined that its efforts to iden-
tify candidates for testing or risk
assessment should focus primarily
on the approximately 14,000 non-
polymeric TSCA Inventory chemi-
cals that are produced at levels of
over 10,000 pounds per year.
OPPT has employed and will con-
tinue to employ reactive and
proactive hazard-based and expo-
sure-based screening techniques to
identify priority testing candi-
dates from among this 14,000
chemical subset.
Since 1977, OPPT has published
over 30 TSCA section 4 final test
rules covering more than 60 chem-
icals and is currently in the process
of promulgating final Test Rules on
more than 30 additional chemicals.
OPPT expects to receive completed
test data sets on approximately  60
chemicals by October 1993. Once
received, the total number of
chemical substances that will have
completed health and/or environ-
mental testing under the TSCA
Chemical Testing Program since
1977 will be about  160.
Meeting the future
In order to increase productivity,
OPPT is now seeking testing
through mechanisms other than
the time-consuming "notice and
comment" rulemaking procedures
of section 4 of TSCA.  Recently,
OPPT has instituted two strategic
changes in the TSCA testing pro-
gram that should accelerate testing

First, OPPT has redefined its test-
ing program to include the devel-
opment of testing actions by
means other than TSCA section 4
test rules, namely negotiated
enforceable consent agreements
(EGAs) under TSCA, and volun-
tary testing programs. ECAs are
used in those situations in which
chemical manufacturers or groups
of manufacturers agree to conduct
testing under the potential sanc-
tions of TSCA. The EGA mecha-
nism was established in accordance
with the procedures specified in
the U.S. Code of Federal Regula-
tions. In July of 1992, OPPT
announced an open season to
encourage chemical manufacturers
and processors to submit offers to
conduct ECA-based testing on
chemicals for which OPPT had not
yet issued final testing actions.
OPPT received and evaluated  22
testing offers covering 12 individ-
ual chemicals and four chemical
categories. In March 1993, OPPT

      Existing Chemicals Program
solicited interested parties and
negotiations are now under way on
submitted offers; negotiations are

The second strategic change OPPT
made to its Chemical Testing Pro-
gram involves the development of
a Master Testing List (MTL). The
MTL establishes for OPPT a clear
agenda of priority testing needs
identified by EPA, other federal
agencies, and the international
community as represented by the
Organization for Economic Coop-
eration and Development (OECD).
The MTL also allows OPPT to
focus its limited resources on the
highest priority testing needs. In
addition, OPPT uses the MTL to
keep the public informed of
OPPT's testing priorities and to
solicit public input into OPPT's
Chemical Testing  Program. Final-
ly, OPPT uses the MTL to encour-
age chemical industry initiatives to
conduct testing designed to
address and fill the priority data
needs identified on the MTL.
With regard to voluntary testing
initiatives, one program in partic-
ular is of major importance to
EPA—the OECD Screening Infor-
mation Data Set (SIDS) program.
Under the auspices of the OECD,
of which the United States is a
member along with 23 other coun-
tries, member countries "share the
burden" of chemical testing. The
OECD/SIDS program is focused on
obtaining needed test data for
international high-production-vol-
ume chemicals and allocates chem-
icals among the OECD countries
for testing using a formula based
on each nation's gross national
product. The United States is
responsible at the present time for
conducting the testing on 25 per-
cent of the SIDS chemicals while
the other OECD member countries
cover the balance. Prior to the
SIDS program, the United States
was conducting more than 90 per-
cent of the world's chemical test-
ing; the OECD/SIDS program
offers the opportunity for sharing
the testing burden and dramatical-
ly increasing  the amount of world-
wide testing of those chemicals
posing the greatest potential for
harm to health and/or the environ-
ment. Since the OECD/SIDS pro-
gram began several years ago, test-
'ing has been completed on 30
chemicals and testing will be initi-
ated on an additional 120 chemi-
cals by the end of 1993; testing on
another 30 to 50 chemicals will be
initiated in 1994. The fact that
most of the OECD/SIDS chemicals
are in U.S. commerce makes this
voluntary international testing
program a very important compo-
nent of EPA's domestic chemical
testing program.

By establishing a TSCA Chemical
Testing Program that utilizes a
variety of available tools, the
development  of test data is acceler-
ated and a greater number of
chemicals can be tested. EGAs and
voluntary testing agreements
clearly offer OPPT and the regu-
lated community less resource
intensive and less time-consuming
alternatives for obtaining test data.
Another major benefit of using
EGAs and voluntary testing agree-
ments is that these mechanisms
provide opportunities for industry
to offer balanced programs
addressing OPPT's concerns about
a chemical by combining testing
activities with pollution preven-
tion and product stewardship
efforts designed to reduce or elimi-
nate chemical exposures leading to
reduced potential health and/or
environmental risks.

Into the future
It is clear that  OPPT's TSCA
Chemical Testing Program is
viable and is becoming more pro-
ductive. As OPPT moves forward
under the new administration, the
strategies outlined above are
expected to significantly increase
the pace and scope of OPPT's
chemical testing actions. Using a
mix of regulatory, voluntary and
consent agreement actions, OPPT
now has active projects to obtain
testing on almost all of the more
than 300 chemicals currently list-
ed on the MTL. OPPT intends to
ensure that its Chemical Testing
Program represents the best efforts
of EPA to meet the data needs of
the agency and others and at the
same time achieve success in these
efforts by using the most effective
balance of TSCA regulatory and
non-regulatory tools available.
      VOL. 14/NO.3 NOVEMBER 1993

   Existing Chemicals Program
Update of Existing Chemicals Program  RM1  and RM2 Activity
EPA's Existing Chemicals Program
screens those chemicals currently
in production or in use to deter-
mine their potential health and
environmental risks. If potential
risks are identified, a further
assessment is performed and risk
reduction strategies are developed.
These activities occur in two dis-
tinct stages.

• In the first stage, Risk Manage-
  ment One (RM1), chemicals are
  screened to identify those that
(1) require additional testing,
(2) present potentially signifi-
cant risk-management concerns,
or (3) do not currently require
further review.

In the second stage, Risk Man-
agement Two (RM2), chemicals
that present significant risk-
management concern are further
assessed. Strategies to reduce or
eliminate the potential risks
posed by exposure to these
chemicals are developed.
For more information
The Office of Pollution Prevention
and Toxics (OPPT), which admin-
isters the Existing Chemicals Pro-
gram, encourages public participa-
tion throughout the RM process.
RM materials are available from
the RM administrative record,
located in the TSCA Non-Confi-
dential Information Center. For
information about the center,
call (202) 260-7099 or
RM Risk Management (RM) Activity
from January 1,1993, through September 15,1993
Chemical Name
Why is it in RM?
Acrylamide/ In 1991, EPA pro-
N-rnethylacrylamide : posed a rule to (1)


immediately ban
acrylamide from all
grouting uses; (2)

Cancer concerns for
workers exposed to
acrylamide and NMA
during grouting.

immediately ban ,
NMA from all grout-
ing uses except sew-
er applications; and
(3) ban the sewer
applications use in
three years.
High-production vol-
ume chemical with
large environmental
releases as reported
to the Toxics Release

Acrylonitrile is classi-
fied by EPA as a B1
"probable human

Stage in Process

Evaluating comments
to 1991 proposed

Next Steps

Developing response
and preparing final

Anticipate issuing a
final rule in early


OPPT has concluded
that the chemical
industry has taken
EPA's concerns for
acrylonitrile very
seriously. No further
OPPT action is war-
ranted at this time,
although EPA will
provide technical
support to other EPA
offices evaluating the
risks posed by acry-

OPPT is writing let-
ters to acrylonitrile
encouraging them
to continue their
pollution prevention

Project closure
anticipated by
fall 1993.


Existing Chemicals Program
RM Risk Management (RM) Activity
from January 1,1993, through September 15,1993, cont'd
Chemical Name

Aerosol Spray Paints

Benzidine Dyes

Chlorinated Paraffins


Cultural Uses of

Why is it in RM?
To investigate pollu-
tion prevention

Benzidine is a known
human carcinogen
and benzidine con-
geners are animal

Designated for test-
ing by the Inter-
agency Testing
Committee for
both human health
and environmental

High production vol-
ume chemical with
significant releases
to air and water as
reported to the Toxcs
Release Inventory.

Referral from state of
California that certain
ethnic groups were
using mercury in
some of their reli-
gious practices.

Some chemicals
Stage in Process

Developing project
found in aerosol : scope.
spray paint are
carcinogenic. Con-
cern for consumers
Next Steps

Perform substitute
analyses and new
technologies assess-
ments, hold informa-
tional exchange
and workers who ; meetings with
use aerosol spray
paints in indoor air

Cancer concerns 1or
workers exposed to
these chemicals.

Short-chain CPs and
alpha olefins used in
metai-working fluids
are hazardous to
aquatic lite.

All CP chain lengths
are of concern to
human health.
Chloroethane is an
Preparing for negoti-
ations with industry,
labor unions, and

Preparing for risk
management deci-
sion making.

OPPT negotiated a
animal carcinogen labeling program with
based on a 1989 Chloroethane manu-
National Toxicology facturers to warn
Program study. workers who install
: chloroethane-con-

Neurotoxicity and
potential lethality to
individuals who use
mercury in these
taining foam boards
of the hazards and to
provide recommen-
dations on how to
reduce exposure.
Developing outreach
and education cam-
paign targeting affect-
ed communities.

Hold negotiation

Select risk manage-
ment strategy.

Develop radio public
service announce-
ments and distribute
fact sheets to com-
munity organizations.

Complete RM2 by the
middle of 1994.

Hoping to complete a
SNUR for benzidine-
based dyes and an
MOU in principle by
December, 1993, for
non-metalized diani-
sidine-based dyes.
Expect to complete
RM2 by September

Project completed.

Anticipate completion
of program by
November 1993.

VOL. 14/NO.3 NOVEMBER 1993

Existing Chemicals Program
RM Risk Management (RM) Activity
from January 1,1993, through September 15,1993, cont'd
Chemical Name
Glycol Ethers Update
and Follow-on
Why is it in RM?
High-volume feed-
stock chemical that is
an EPA B2: "probable
human carcinogen."
reporting preliminary
results that expo- I
sures to these chemi-
cals could be linked
to an increased inci-
dence of sponta-
neous miscarriages
in women working in
semiconductor man-
ufacturing plants.
Evaluation of envi-
ronmental exposures
from the disposal of
consumer products
containing mercury.
Referral from the
Consumer Product
Safety Commission.
Animal carcinogen
with possible high
exposures to
i Request from the
United Rubber Work-
ers Union to evaluate
the potential risks
posed by these
Cancer risk to indi-
viduals living near 4
specific facilities.
Reproductive toxicity
to workers.
Mercury is a highly
toxic chemical, caus-
ing serious neurolog-
ical effects at very
low exposure levels.
Reproductive toxicity
to workers and to
users of consumer
"do-it-yourself" paint
stripping products.
Cancer and liver toxi-
city concerns for
Cancer concerns for
workers in the rubber
manufacture and
leather tanning
Stage in Process
Finalizing draft |
report. ]
Evaluating data
Under most circum-
stances, human
exposure to mercury
is negligible.
Discussing risk man-
agement strategies
with industry groups,
labor unions, and
consumer groups.
Completed RM2
Stakeholder's dia-
logue held in July
1993. Currently
i incorporating new
information into
Next Steps
Distribute final report
to interested parties.
Complete data
hazard and risk
identify potential
OPPT may provide
technical support to
EPA's Office of Solid
Negotiate a glove
testing and product
warning program.
Informal referral to
the Occupational
Safety and Health
Administration. 2-NP
may be added to
OPPT's Master
Testing List.
Further review, and
discussion of risk
reduction methods
; with stakeholders.
Anticipate completion
of project by
December 1993.

Project closed in
August 1993.
Work on this project
will be incorporated
into OPPT's activities
on a consumer/small
shop paint stripping
use cluster analysis.
Project closed in
September 1993.


    Existing Chemicals Program
RM  Risk Management (RM) Activity
from January 1,1993, through September 15,1993,  cont'd
Chemical Name

Non-Residential Lead

Land-Applied Sludge

Source/ Concerns
Why is it in RM?

In 1991 EPA pro-
posed a rule to gov-
ern the land applica-
tion of pulp and
paper mill sludge
contaminated with
dioxins and furans.

Concerns for occupa-
tional exposures and
general population

Dioxins and furans
are very toxic to

Stage in Process

Held stakeholder
dialogues to discuss
substitutes and
possible abatement
Negotiating a volun-
tary agreement which
will set up guidelines
for land application
dioxin/fu ran stan-
dards and manage-
ment practices and to
obtain data to
improve our under-
standing of the eco-
logical risks of sludge
land application.
Next Steps ! Projected
Finalizing EPA

Develop the actual
agreement with

Completion of project
is likely in fall 1993.

Voluntary agreement
expected to be
signed by January,

PCB Rules Revised to Update RCRA References
EPA has updated references to reg-
ulations that govern the marketing
and burning of used oil containing
polychlorinated biphenyls (PCBs)
at levels of less than 50 parts per
million (ppm). The technical
amendment became effective on
March 23, 1993 (58 FR 15435).
Under the Toxic Substances Con-
trol Act (TSCA), EPA allowed
waste oil with fewer than 50 ppm
PCBs to be burned and marketed
for purposes of energy recovery. In
the TSCA PCB regulations, the
agency referenced Resource Con-
servation and Recovery Act
(RCRA) requirements. However,
the RCRA requirements were
repositioned on September 10,
1992, when EPA published a final
rule that established standards for
used oil. Specifically, the provisions
at 40 CFR Part 266 were moved to
the newly created 40 CFR Part 279
(57 FR 41566). To reflect this
change, EPA amended TSCA PCB
regulations at 40 CFR 76l.20(e).
The amendment does not change
the substantive requirements of the
TSCA PCB regulations and does
not affect the burden on the regu-
lated community to comply with
TSCA used oil requirements.

In addition, EPA published a cor-
rection to the March 23 technical
amendment (58 FR 32060). The
correction addressed the omission
of a citation found in paragraph (4)
of the definition for a "qualified
incinerator" at section 761.3- The
reference to industrial furnaces and
boilers in 40 CFR 266.4 l(b)
should have been changed also to
read 40 CFR 279.6l(aXD and (2).
     VOL. 14 / NO. 3 NOVEMBER 1993

                                    Existing Chemicals Program
                               Efforts to Replicate Anderson Laboratory
                               Carpet  Study Point to More Work Ahead
"Failure to replicate
 the findings does
    not prove that
 carpet emissions
  do not pose any
adverse effects...."
EPA has been unable to indepen-
dently reproduce the findings of a
1992 private study in which mice
died after being exposed to carpet
emissions. Failure to replicate the
findings does not prove that carpet
emissions do not pose any adverse
effects, said Victor J. Kimm, acting
administrator for EPA's Office of
Pollution Prevention and Toxic
Substances, in testimony before the
House of Representatives' Subcom-
mittee on Environment, Energy,
and Natural Resources in June
1993. At the same time, he said,
EPA does not have a sound basis for
concluding that exposure to carpet
emissions presents a health risk.

In a 1992 announcement, Ander-
son Laboratories, of Dedham, Mass-
achusetts, described neurotoxicity,
pulmonary irritation, and death in
mice exposed to emissions from
certain carpets. The lab's findings
seemed to support complaints asso-
ciating health problems with expo-
sure to emissions from carpets.

In January 1993, EPA scientists
traveled to Anderson Laboratories,
where, using a combination of
EPA and Anderson apparatuses,
they conducted a carpet emissions
test in which some mice died.
However, a scientific finding is
considered reliable only when it
can be independently replicated.
In a replication study in EPA labs,
EPA scientists were unable to pro-
duce severe toxicity in mice, nor
did EPA's tests produce any con-
vincing signs of even mild toxicity.

Details of study replication
The replication study was conduct-
ed simultaneously by EPA and
Anderson Laboratories. EPA collab-
orated with Anderson Laboratories
in designing and executing the
study. Both EPA and Anderson
Laboratories agreed to the protocol
for performing the study. Each lab
received pieces from the same car-
pet to test, and scoring procedures
for neurotoxicity were developed
by EPA and Anderson Laboratories.
EPA found no deaths in 24 tested
animals, no severe or moderate
sensory irritation, and no clear evi-
dence of neurotoxicity. By con-
trast, Anderson Laboratories found
five test-related deaths, pulmonary
irritation, and neurotoxicity in 24
tested animals.
Both labs sent draft reports of their
findings to a panel of independent
scientists for peer review. At the
conclusion of the peer review, it
was clear that  there  was virtually
nothing in common between the
two sets of findings. EPA con-
cludes that an essential difference
between the conditions of its
experiments and those of Anderson
Laboratories exists but has not
been identified.

EPA  addresses indoor air quality
At this point, EPA is continuing
research to determine the cause  of
Anderson Laboratories'  findings.
Carpet continued on page 13

      Existing Chemicals Program
Carpet continued from page 12
EPA is addressing carpet-related
issues as part of its indoor air qual-
ity strategy. Descriptions of some
EPA activities follow.

• EPA  has scheduled a workshop
   at which scientists working on
   carpet emissions will present
   data on their experience with
   Anderson Laboratories' test pro-
   cedure. Scientists from the car-
   pet industry, Anderson Labora-
   tories, and EPA, in addition to
   independent peer reviewers, will
   participate in the workshop.
   EPA  will consider the outcome
   of the workshop in deciding
   what steps are necessary to fur-
   ther understanding of concerns
   about carpets.

• EPA  is continuing efforts to
   develop better methodologies
   for detecting and studying the
   potential health effects of emis-
   sions from indoor sources. For
   instance, toxicology tests to
   detect health effects associated
   with indoor air complaints are
   being developed by EPA's
   Office of Research and Develop-
   ment's Health Effects Research

   EPA is continuing to follow the
   voluntary testing of emissions
   from carpet and carpet products.
   The testing is being performed
   by the Carpet and Rug Insti-
   tute, the Carpet Cushion Coun-
   cil, and the Floor Covering
   Adhesive Manufacturers Com-
   mittee. The voluntary testing
   programs were one  of the many
   agreements that came out of a
   carpet policy dialogue, convened
   by EPA in 1990 as part of its
   general pollution prevention
   strategy to minimize indoor
   exposures to total volatile
   organic chemical emissions
   where reasonable.
   EPA is working toward defin-
   ing exposures and risks caused
   by indoor pollution sources.
   The ongoing Indoor Air Source
   Characterization Project will
   provide a mechanism for EPA
   to identify indoor air source
   categories that warrant further

   EPA is assessing the health and
   environmental risks of selected
   cleaning products  that the U.S.
   General Services Administration
   (GSA) purchases for use in gov-
   ernment buildings. OPPT will
   assist GSA in developing pro-
   curement criteria based on effi-
   cacy, health, and environmental
   considerations. (See article on
   page 24.)
OPPT continued from page 1

of the changes and initiatives in
OPPT. The new approach is
designed to maximize the utility
of three key OPPT assets—the
expertise of the staff, the assem-
bled information on chemicals,
and the statutory authorities1 of
the office—to achieve  results in
prevention and risk reduction.

The change to a comprehensive
pollution prevention program rep-
resents a shift away from an activi-
ty-based definition of the OPPT
program to a broad, integrated,
mission-based definition. In the

1 For example, TSCA, EPCRA, PPA
(Pollution Prevention Act of 1990)
past, OPPT work was primarily
organized around section-by-sec-
tion implementation of the Toxic
Substances Control Act (TSCA).
The organization of programs for
the TSCA inventory,  chemical test-
ing, new chemicals, existing chem-
icals, and Toxics Release Inventory
(TRI) reporting, etc., while pro-
viding the needed foundation for a
toxics program, has made it diffi-
cult to articulate and pursue more
broadly based and cross-cutting
environmental goals.

The articulation of the broad office
mission by OPPT's management
and staff, has been a key to the
shift to a mission-based definition
of the OPPT program. The OPPT
mission has been defined as:
• Promoting pollution prevention
  as a principle of first choice to
  achieve environmental steward-
  ship throughout society.
• Promoting the design, develop-
  ment, and application of safer
  chemicals, processes, and tech-
  nologies in the industrial sector
  of the economy.

• Promoting risk reduction and
  responsible risk management
  practices throughout the
  life cycle of major chemicals of

• Promoting public understand-
  ing of the risks of chemicals and
  public involvement in environ-

OPPT continued on page 14
      VOL. 14/NO.3 NOVEMBER 1993

      Existing Chemicals Program
OPPT continued from page 13

  mental decisionmaking through
  dissemination of information on
  toxic chemicals.

The changes and initiatives that
characterize recent OPPT activi-
ties reflect an attempt to ensure
that OPPT efforts effectively pro-
mote the denned mission. A mis-
sion-based definition of the OPPT
program places the specific imple-
mentation of sections of the
statutes in the context oflong-
term goals. The focus on the broad
OPPT mission enables the office
to use its resources more flexibly
and effectively. This approach has
allowed the office to blur the lines
between new chemical and exist-
ing chemical activities to find new
and creative ways to integrate our
risk assessment and management
experience with our new pollution
prevention mandate. For example,
test data, expertise in structure-
activity relationships, and  other
assessment tools acquired in the
development of the New Chemi-
cals Program now frequently con-
tribute to decisionmaking in the
Existing Chemicals Program. The
shift to a mission-based definition
of the OPPT program has  not
weakened the base activities; it
has strengthened them by  measur-
ing their progress in terms of
movement toward  significant
long-term goals, such as reduced
risk and pollution prevention.

The origins and the outline of the
strategy for dealing with chemicals
in commerce that have emerged
from this new focus on the OPPT
mission are discussed below,
II. Background and strategy
for a common approach to
pollution prevention and
Finding a means to comprehen-
sively address the issues surround-
ing "chemicals in commerce" has
been the central problem for the
EPA toxics program. Dealing with
such a large number of chemi-
cals—either the 70,000 chemicals
on the inventory or, sharpening the
focus, the approximately 14,000
nonpolymer chemicals produced in
amounts above 10,000 pounds per
year—has been a significant chal-
lenge. The challenge is especially
apparent when one recognizes that
the almost countless facilities, use
applications, and exposure scenar-
ios expand the task beyond the
realm of traditional chemical risk
management solutions. Moreover,
we cannot responsibly assume that
all of these chemicals present sig-
nificant risk. Clearly, the develop-
ment of an adequate method for
sorting  through these chemicals is
one of the central tasks facing
OPPT and the nation.
OPPT's  evolving agenda for toxics
OPPT's efforts over the past sever-
al years  has made considerable
progress in the development and
implementation of a process for
evaluating and making decisions
on toxic chemicals. These efforts
have been successful in helping to
set an agenda for the OPPT Exist-
ing Chemicals Program. The
OPPT agenda has been developed
from reactive, collaborative, and
proactive elements.
The reactive element of the OPPT
agenda, the traditional TSCA
agenda, is made up of chemicals
brought to the attention of OPPT
through TSCA statutory authori-
ties such as TSCA section 8(e) sub-
missions or recommendations  from
the Interagency Testing Commit-
tee. In the collaborative element of
the agenda, OPPT uses TSCA
tools and approaches to help other
EPA programs on important parts
of their environmental agendas.
Examples of the collaborative part
of the OPPT agenda include work
on phosphoric acid production
waste, a joint project with EPA's
Office of Solid Waste and Emer-
gency Response, and the testing of
Clean Air Act Amendment chemi-
cals. In the proactive element  of
the OPPT agenda, the office devel-
ops its own agenda focused on par-
ticular policy or risk concerns  in
which the agency has otherwise
shown an interest. Recent exam-
ples include the work with indoor
air contaminants, high-release TRI
facilities, and persistent bioaccu-
mulators. The recently instituted
Design for the Environment (DfE)
program is also a major component
of this proactive agenda.

OPPT intends to continue these
types of efforts but believes they
need to be placed in a larger
framework of work on chemicals in
commerce. We need to assure our-
selves and the constituencies the
program serves that we have devel-
oped a rational overall agenda for
our work on existing chemicals
that maximizes pollution preven-
tion and risk reduction.

      Existing Chemicals Program
Role of government
Any effort to address existing
chemical issues must also recog-
nize that even the most optimistic
projection of OPPT resources
would allow direct government
action on only a handful of the
thousands of existing chemicals.
Recognition of OPPT's limitations
is crucial to any realistic approach
to existing chemicals.

It is also important to recognize
that for many, if not most, chemi-
cals of concern significant pollu-
tion prevention or other risk
reduction gains can be realized
with relatively small adjustments
in chemical use and management
practices. These are the kinds of
adjustments that can effectively
occur only on an industry-by-
industry, community-by-commu-
nity, plant site-by-plant site,
process-by-process, or chemical
application-by-chemical applica-
tion basis.

The integration of the pollution
prevention mandate into the
OPPT and EPA programs offers a
challenge similar to the task of
managing existing chemicals. Pol-
lution prevention cannot be dis-
tilled into a few big issues. Preven-
tion is characterized by large
numbers of positive and specific
actions by those who understand
the details of the manufacture and
use of chemicals. Pollution preven-
tion opportunities need to be pur-
sued for each of the issues of con-
cern, large and small, that
surround the chemicals in com-
merce. The limited resources of
government can only be applied
directly to a limited number of
these transactions. OPPT must, as
in addressing toxics issues, recog-
nize the limits of its resources and
face the problem of determining
which of the countless pollution
prevention opportunities to target
with its limited resources.

At the same time, however, OPPT
has recognized the growing inter-
est and involvement of other par-
ties in dealing with toxics issues
and in pursuing pollution preven-
tion outcomes. Included under this
heading are  numerous state toxics
and pollution prevention pro-
grams, industry initiatives such as
the Chemical Manufacturers Asso-
ciation's Responsible Care Pro-
gram, and community-level efforts
(based in many cases on the right-
to-know premise). Despite their
different starting points, OPPT
and these other parties have over-
lapping objectives.

New OPPT strategies

The challenges facing  OPPT in its
attempt to integrate its toxics and
prevention programs,  lead to some
common solutions. Clearly, any
realistic plan to address the over-
whelming issues and prevention
opportunities surrounding chemi-
cals in commerce must be designed
to facilitate initiative in the private
sector, in state and local govern-
ments, in labor unions, and in the
public. Just  as clearly, the overall
strategy must include the identifi-
cation of priorities so that
resources, both of OPPT and of
others, can be effectively targeted.
Based on these key points, the new
OPPT approach for accomplishing
its mission is organized around the
following three strategies:

1. Empowering the broadest possi-
  ble initiative from industry, the
  public and government agencies
  by providing information and

2. Establishing, in conjunction
  with others, national goals and
  measures of progress for address-
  ing toxic chemical issues.

3. Targeting direct OPPT action to
  areas of high priority to aug-
  ment ongoing public and pri-
  vate sector efforts or require
  activity in areas where initiative
  is either lacking or insufficient.

In carrying out the above strate-
gies, OPPT will give special priori-
ty to collection and dissemination
of environmental information. The
OPPT focus on information follows
from the recognition of the critical
role of information access to the
success of others' plans for address-
ing toxics issues. The OPPT focus
on collecting and disseminating
information is not a retreat from
government regulation; there will
always be a need to use government
regulatory processes to address sit-
uations where private parties are
not responding  to environmental
issues responsibly. The emphasis on
information dissemination is sim-
ply a recognition that in the cur-
rent environment a large number
of private and other public organi-
zations are able  to develop and
implement sound pollution pre-
vention strategies to reduce risk.
                                                                       OPPT continued on page 16
                                         VOL 14/NO.3 NOVEMBER 1993

                                         Existing Chemicals Program
OPPT continued from page 15

III. Empowering the public
with information

The most effective way for OPPT
to encourage and empower private
initiative is to deliver key environ-
mental information to industry
and the public. The public release
of important environmental data
gives everyone the ability to par-
ticipate in the broader national
effort to address chemical issues.
The TRI clearly illustrates the
ability of information to dramati-
cally promote and empower initia-
tives by the toxics community.
TRI has helped industry to identi-
fy problems and target actions, and
it has given the public an opportu-
nity to learn about problems and
become involved in their solution.

OPPT will work to provide access
to information on facilities, chemi-
cals, and uses. For facilities, OPPT
will continue to publish and
improve the TRI. The recent  addi-
tion of site-specific pollution  pre-
vention information will increase
the usefulness of this tool. Publica-
tion of the Existing Chemicals
Program's Risk Management  (RM)
analysis of targeted high-release
facilities will continue. For the
future, OPPT has begun a major
effort to expand the TRI, which
will at a minimum include the
addition of chemicals and industri-
al sources to the TRI. OPPT  will
also explore integration of its data-
base with others in the agency to
provide as complete a picture as
possible of releases from facilities.

For information on the chemicals
of greatest concern, OPPT will
continue to make public the chem-
ical-related data and information
collected and generated through
the various authorities of the office
such as TSCA section 8 reporting,
the testing program, the New
Chemicals Program, and the Exist-
ing Chemicals Program's RM
process. Efforts to improve infor-
mation collection and make it
more accessible to the public are
ongoing. CBI reform to improve
public accessibility, exploration of
methods for disseminating the 8(e)
CAP information, and efforts to
work with industry to collect bet-
ter exposure information for the
RM process are currently in

The collection and dissemination
of information on chemical use
will be a priority for OPPT.
Details of the OPPT proposal for
collecting use information through
a Chemical Use Inventory are dis-
cussed in later sections of this

In each of the above areas, the  col-
lection and dissemination of pollu-
tion prevention information is
essential. Pollution prevention
information added to TRI by the
Pollution Prevention Act will  help
to identify prevention opportuni-
ties at the facility level.  For chemi-
cals of concern, the assembly of
more complete hazard and expo-
sure information will ensure that
where prevention is denned as
chemical substitution, the public
can be more  confident that safer
materials are being used. Perhaps
most importantly, the OPPT focus
in the RM and DfE programs  on
chemical uses instead of individual
chemicals will provide an effective
means for uncovering and promot-
ing pollution prevention opportu-
nities. Further development of the
pollution prevention clearinghouse
and dissemination of DfE informa-
tion will also encourage pollution
prevention in the private sector.

Analytical tools developed by
OPPT will also be made available
to the public. Details of the risk
management screening analyses
and the DfE chemical substitute
assessment methodology are now
being packaged for public use.
Other tools and models, such as
software to estimate  the aquatic
toxicity of chemicals, are being
modified so they can be used by
others outside EPA.

IV. Establishing national goals
and measures of progress

Defining the chemicals, facilities,
processes, and chemical uses of
most concern and setting national
goals are essential to a successful
toxics program. Current OPPT
efforts to set goals and  measures of
progress include the TRI and the
33/50 Program, as well as the
Master Testing List.  The proactive
agenda of the RM process,  dis-
cussed above, has also helped to
clarify national goals with its cur-
rent focus on indoor air pollutants,
high-release TRI facilities, and
persistent bioaccumulators. Based
on these efforts, it now seems
appropriate to develop a more
systematic, collaborative and com-
prehensive approach to this
goal-setting process.

OPPT is not now in the position

                                         Existing Chemicals Program
to articulate comprehensive,
broadly applicable, specific goals
for chemical risk reduction. OPPT
is, however, engaged in a major
strategic effort that will provide
EPA with a sound technical basis
for setting priorities and denning
environmental goals. Specifically,
OPPT has  under way two projects:

• Developing a method to screen
   chemicals in commerce to iden-
   tify those of most concern.

• Identifying the patterns of
   chemical use that are of most

The effort to screen chemicals
begins by identifying high-
and moderate-volume chemicals
with significant hazard concerns.
Use information will then be
used to identify chemicals with
high-exposure potential, such as
those used in consumer products
or handled by large numbers of
workers. To collect information
on exposure potential, OPPT is in
the process of evaluating how the
TSCA Inventory Update Rule can
be amended to generate a Chemi-
cal Use Inventory.  (Details of pro-
posals for a Chemical Use Invento-
ry and a comprehensive screening
method can be found in the final
section of this paper.)

Following the identification of the
chemicals of most concern, OPPT
will work to assure that basic
information on the hazards and
exposures associated with these
chemicals is available to the pub-
lic. OPPT will also work to pro-
vide the public,  through a combi-
nation of government and private
efforts, with analyses of the risks
associated with these chemicals
and with pollution prevention and
risk management strategies that
can be adopted to mitigate con-
cerns. Identification of the chemi-
cals of most concern and the col-
lection and dissemination of
information on these chemicals
will help to focus national efforts
to areas where they can be most
As a complement to this effort,
OPPT will also work to identify
the patterns of chemical use that
are of most concern. OPPT has
already developed the basics of a
scoring system that ranks potential
concerns associated with chemicals
used in the same application or use
clusters. This system accesses read-
ily available information on expo-
sure and hazard. An algorithm,
based on past OPPT risk screening
experience, is then used to gauge
potential concerns. Using the scor-
ing system to help identify the
chemical uses of most concern will
help to focus pollution prevention
and risk management efforts to
priority areas. The identification of
priority uses will also help to
direct research and other private
and public efforts to areas where
they can be most effective.

V. Targeting  government
Current OPPT direct actions are
usually targeted using risk, expo-
sure, and hazard criteria. Actions
can be organized by specific chem-
icals, by clusters of chemicals
defined by concern or use, or by
facilities and industries. Targeted
concerns are analyzed in the RM
process of the Existing Chemicals
Program and appropriate pollution
prevention or other risk manage-
ment approaches, either voluntary
or regulatory, are developed.

Use clusters

While review of individual chemi-
cals of concern will continue,
OPPT currently emphasizes the
targeting of use clusters for review.
Use clusters, which focus on a spe-
cific chemical use and the alterna-
tives available for that use, pro-
mote consideration of major factors
that are needed for the develop-
ment of pollution prevention or
other risk management plans. As a
result, use cluster reviews can be
more helpful to chemical users
than single chemical reviews. The
current RM review of aerosol spray
paints illustrates this point. The
cluster was chosen to address the
Science Advisory Board's choice of
indoor air as a potential  priority
risk area. Focus on the use of
aerosol spray paints as a  group
allows the review process to gather
all the necessary information on
chemicals and alternatives that
will provide the basis for pollution
prevention or other risk  manage-
ment approaches.

OPPT's DfE program builds on
the use cluster approach by focus-
ing on specific uses and expands
beyond the RM process to include
the active involvement of a willing
industry. In DfE efforts,  OPPT
works with all sectors of an indus-
try to develop a long-range plan
for the identification and imple-

OPPT continued on page 18
                                         VOL 14/WO.3 NOVEMBER 1993

                                        Existing Chemicals Program
OPPT continued from page 17
mentation of pollution prevention
or other risk reduction plans. The
printing, dry cleaning, and com-
puter industries are working with
OPPT on Dffi projects.
In addition to  direct work with
chemical manufacturers and users,
OPPT targets  its own resources,
through the Source Reduction
Review Project, to assist other
EPA program  offices in identifying
opportunities for incorporating
pollution prevention into regula-
tions affecting 17 industrial source
categories. (See article on page 28.)
In the future, direct OPPT actions
will be able to take advantage of
public tools, such as the Chemical
Use Inventory comprehensive
screening, to more clearly identify
high-priority use patterns, facili-
ties, and chemicals for RM action.
OPPT will continue to select such
cases for entry into its Existing
Chemicals Program, where we can
achieve risk reduction through a
combination of regulatory and vol-
untary actions.

VI. Chemical use inventory
and  comprehensive screening
The Chemical Use Inventory
would amend the current TSCA
Inventory Update Rule to include
basic information  on chemical use.
This inventory proposal is a clear
 example of the kinds of initiatives
 that develop out of the combina-
 tion of the toxics, pollution pre-
 vention, and information perspec-
 tives of the new OPPT strategy.
 The  OPPT toxics program has
from its inception been faced with
the need to find an adequate
process to sort through the 70,000
chemicals on the inventory to
identify the chemicals of greatest
concern. The current inventory
update rule collects some of the
key information, such as produc-
tion volumes, to identify the
chemicals of concern, but informa-
tion on  the use of chemicals, which
is essential to determining possible
exposure routes and scenarios and
potential safer substitute chemi-
cals, is not covered by the Inven-
tory Update Rule. With modifica-
tions to include basic information
on chemical uses, the inventory
update could supply information
essential to an effective TSCA
inventory screening program. To
enhance the value of the data,
OPPT is considering broadening
the scope of the industries that
report, increasing the frequency of
reports  (e.g., every two years) and
placing the reporting cycle on the
same timeframe as TRI reporting.

The proposed screening would
identify chemicals of concern via
the following criteria:
• High-volume chemicals (those
   produced annually in amounts
   greater than 1 million pounds a
   year) of more that low hazard.
• Moderate-volume chemicals
   (those produced annually in
   amounts of 10,000 pounds to 1
   million pounds) of relatively
   high potential hazard, potential
   consumer use, or high potential
   occupational exposure.

 Appropriate criteria for the high-
 and low-hazard  points, consumer
use, and high potential occupa-
tional exposure would also need to
be developed.
Agreement of the toxics communi-
ty on a screening tool based on the
Chemical Use Inventory would
produce a list of chemicals of
greatest concern that could serve as
the basis for a national agenda for
toxics. Instead of an unmanageable
list of 70,000 chemicals, the
nation would have a list of the sev-
eral thousand chemicals of greatest
concern. This would  help to focus
limited resources to the areas of
greatest need. Based  on this agen-
da, clear and measurable national
goals for information collection,
pollution prevention, and  other
forms of risk management could
be established.

The evolution of the OPPT infor-
mation strategy also  leads to the
Chemical Use Inventory. TRI
emissions information has empow-
ered industry and the public to
identify problems and set  clear
goals for addressing toxics con-
cerns in the areas of the manufac-
ture and processing of chemicals.
Progress in this area has led natu-
rally to consideration of the areas
of concern not covered by TRI, in
particular, the exposures and risks
associated with chemical use. The
Chemical Use Inventory would
provide the basic use information
 necessary to expand  the public ini-
 tiatives around the TRI to the area
 of chemical use.

 The issue of confidential business
 information (CBI) will be a key
 consideration in implementing a
 Chemical Use Inventory initiative.
 While accommodating legitimate

      Existing Chemicals Program / Export Notification
CBI concerns, the Chemical Use
Inventory, in order to achieve the
objectives of empowering the pub-
lic, would emphasize public access.
One possible way to accommodate
competing interests would be to
require reporting at a more
detailed level to allow EPA to use
the data for chemical screening
while providing public disclosure
at a more aggregated level that
would overcome most CBI issues
while still providing the level of
information needed for public

The ability to use the Chemical
Use Inventory to identify trends
and patterns of chemical use are
also key to pollution prevention.
Pollution prevention gains in the
area of chemical use require
detailed consideration of specific
chemical applications. The Chemi-
cal Use Inventory would help to
identify the use areas of greatest
concern and allow for the effective
targeting of pollution prevention
efforts. The Chemical Use Invento-
ry could also be used to set goals
and measure the progress of pollu-
tion prevention for chemicals in

In sum, the Chemical Use Inven-
tory and the accompanying screen-
ing proposal are examples of the
kinds of initiatives that result from
the new OPPT strategy. The pro-
posals are designed to assist with
setting goals, empowering private
initiative, and targeting OPPT
actions. They also provide key
building blocks for the advance-
ment of pollution prevention.
EPA Amends Notification Rule for
Chemical Exports
EPA has changed one of the annual
reporting requirements of its
export notification rule. The
change affects reporting on chemi-
cals subject to test rules under sec-
tion 4 of the Toxic Substance Con-
trol Act (TSCA).

As of January 1, 1994, companies
are required to provide a one-time
notice to EPA for each country to
which they export a TSCA section
4 chemical. Previously, companies
were required to provide annual
notices. At the same time, EPA
will begin notifying foreign gov-
ernments of the import of each
chemical only once, instead of
annually. Reporting  requirements
for sections 5, 6, and 7 of TSCA
remain unchanged.

Background of TSCA section
12(b) program
In 1980, EPA began requiring
notification for the export of cer-
tain chemicals, as mandated by
section 12(b) of TSCA. In addition
to chemicals that are subject to
TSCA section 4 test  rules, notifica-
tion is required for chemicals that
are subject to:
• Submission of test data under
  TSCA section 5(b)
• Consent orders issued under
  TSCA section 5
• Significant new use rules
  (SNURs) or proposed SNURs
  under TSCA section 5
• Rules or proposed rules under
  TSCA section 6
• Pending actions or granting of
  relief under TSCA section 5 or
  section 7
EPA sends the notices to the
importing country to alert it that a
chemical is subject to regulatory
actions in the United States. Since
the program started, the volume of
notices submitted to EPA has
increased significantly, as have the
notices EPA sends to foreign gov-
ernments. By the end of 1993, EPA
expects to receive more than 15,000
notices; about 12,000 of these are
for TSCA section 4 chemicals.

The increasing number of notices
is making it difficult for foreign
governments to review and moni-
tor imported chemicals. Decreas-
ing the number of notices for
TSCA section 4 chemicals will
allow foreign governments to focus
their efforts on imported chemicals
that are subject to restrictive regu-
lations or proposed restrictive reg-
ulatory actions.

For more information
• Call or write to the TSCA
  Hotline (see page 43).

• See 40 CFR part 707 for the
  TSCA section 12(b) export
  notification rule.
• See 58 FR 40238, July 27,
  1993, for the amendments to
  the reporting requirements of
  the TSCA section 12(b) export
  notification rule.
                                        VOL14/N0.3 NOVEMBER 1993

     Existing Chemicals Program
States  Support Efforts on Forming Voluntary Agreement on
Pulp and  Paper  Mill Sludge
EPA is negotiating a voluntary
agreement with the American For-
est and Paper Association to estab-
lish dioxin and furan standards and
management practices for the use
of sludge as a soil conditioner. The
association is representing pulp
and paper mills that currently
land-apply the sludge.
The proposed  agreement would
establish three standards for dioxin
and furan concentrations in pulp
and paper mill sludge. The stan-
dards  are:
• A maximum dioxin and furan
  concentration, or "cap," for
  sludge that can be land-applied
• A dioxin and furan concentra-
  tion at or below which sludge
  would be exempted from most
  provisions of the agreement
• A maximum dioxin and furan
  soil concentration that may not
  be exceeded for land on which
  sludge is applied.
EPA is interested in setting dioxin
standards that are acceptable to
states that allow land application.
At  the June 1993 meeting of the
Forum on State and Tribal Toxics
Action,  representatives from 10 of
these  states said they agreed with
the standards' framework. Some
states also expressed interest in
incorporating dioxin and furan
standards into their existing efflu-
ent regulations for mills. Pulp and
paper mills would be required to
meet these standards to remain in
compliance with effluent permits.

Concern about contaminated
In 1985, EPA found that the man-
ufacture of chlorine-bleached pulp
and paper produces dioxins and
furans. These chlorinated organics
are highly toxic and are classified
by EPA as a probable human car-
cinogen. While pulp and paper
    EPA believes that
      improper land
   application of  pulp
      and  paper mill
    sludge can pose  a
    significant risk to
products themselves contain negli-
gible levels of dioxins and furans,
EPA determined that pulp and
paper mill sludge produced in
manufacturing these products may
be of concern. In the United
States, 104 facilities use chlorine
or chlorine derivatives to manufac-
ture bleached pulp.
In 1991, EPA proposed a regula-
tion under the Toxic Substances
Control Act (TSCA) to (1) limit
the concentration of dioxins and
furans in soil to 10 parts per tril-
lion and (2) establish site-manage-
ment practices for land application
of the sludge.

EPA deferred finalizing the rule
until issuance of integrated regula-
tions for effluent guidelines and
Most Achievable Control Technol-
ogy (MACT) standards. These reg-
ulations will require bleach plant
process changes in the pulp and
paper industry and are expected to
reduce the concentration of dioxins
and furans in sludge. Concentra-
tions may be reduced to a level
that would make TSCA rulemak-
ing unnecessary.

EPA believes that improper land
application of pulp and paper mill
sludge can pose a significant risk
to wildlife. The voluntary agree-
ment would be the first part of an
environmental stewardship pro-
gram that  EPA is proposing for the
pulp and paper industry. The stew-
ardship program would ensure
responsible land application and
greatly reduce potential risks from
land-applying pulp and paper mill
                                       CHEMICALS IN PROGRESS

     Existing Chemicals Program
Public Meeting  Held  on TSCA CBI Reform
About 60 people attended a public
meeting in July 1993 on reform-
ing confidential business informa-
tion (CBI) policies for data sub-
mitted under the Toxics
Substances Control Act (TSCA).
In May 1993, EPA's Office of Pol-
lution Prevention and Toxics
(OPPT) proposed a series of short-
and long-term actions to address
the problem of inappropriate CBI
claims. OPPT sponsored the pub-
lic meeting to elicit comment on
its proposed actions.
At the public meeting, 16 repre-
sentatives from various constituen-
cies spoke about the proposed
actions to address inappropriate
claims. Among the speakers were
representatives from the Illinois
EPA, the Chemical Manufacturers
Association, the Sierra Club, the
AFL-CIO, the Dow Chemical
Company, and the World Wildlife
Federation. By and large, the
speakers recognized that CBI
claims made without regard to
statutory and regulatory right are
not desirable. Several industry
speakers noted that there are some
improper filings and that these
need to be limited. There was dis-
agreement, however, about the
number of these improper filings.
All parties agreed that it would be
helpful if EPA would issue clear
guidelines on making CBI claims
and that education courses on the
subject would be useful. But the
speakers disagreed on the appropri-
ateness of regulatory amendment.
OPPT will consider all public
comments before publishing a final
TSCA CBI action plan.
      EPA's  Office of
      Prevention and
      Toxics (OPPT)
    proposed a series
   of short- and  long-
      term actions to
        address the
        problem of
    inappropriate CBI
Background of CBI reform
Over the past several years, OPPT
has sought broad participation in
toxics management. To understand
the risks from chemical substances,
however, the public requires access
to TSCA data. There is wide agree-
ment that dissemination of these
data is consistent with the lan-
guage and intent of the statute.
Inappropriate CBI claims limit the
toxics data available to the public
and hamper efforts (1) to promote
public education about chemicals
and (2) to encourage public partic-
ipation in toxics control. OPPT
has committed itself to making
toxics data available to the public
and states.

For more information
•  Two documents are available by
   calling the TSCA Hotline at
   (202) 554-1404 or by writing
   to the address on page 43:  (1)
   OPPT's Proposed Actions to Reform
   TSCA Confidential Business Infor-
   mation and (2) Influence of CBI
  Requirements on TSCA Implemen-
   tation, a contractor study com-
   missioned by OPPT.
•  Public comments on the TSCA
   CBI reform effort are contained
   in the administrative record,
   docket number OPPTS 00124,
   in OPPT's Non-Confidential
   Information Center. To contact
   the information center, call
   (202) 260-7099.
•  For additional information, con-
   tact Scott Sherlock, in OPPT's
   Information Management Divi-
   sion; telephone, (202) 260-1536
   or (202) 260-1657; or, write to
   him at the address on page 43.
      VOL 14/NO.3 NOVEMBER 1993

                                       Information Management
OPPT Proposes  New Strategy for Information Management
Written Comments Sought
Making toxics information avail-
able to the public is integral to
both the management of toxic
chemicals and the promotion of
pollution prevention. EPA's Office
of Pollution Prevention and Toxics
(OPPT) recently drafted a strategy
for improving the management
and accessibility of toxics data.
OPPT is soliciting  comments on
the strategy through this article
and meetings with  industry, public
interest groups, state officials, and
other EPA offices. The final strate-
gy will be based on careful consid-
eration of all comments.

The strategy is organized around
six goals and provides a broad
framework for all the activities
that OPPT plans to undertake. A
summary of the six goals follows.

7.  Increase awareness throughout
    EPA of the importance of informa-
    tion collection, processing, and dis-
    semination; incorporate an infor-
    mation product focus in all OPPT

OPPT has a storehouse of useful
toxics data collected under various
federal laws. The data include
exposure, hazard, risk, and other
relevant information and are essen-
tial for making decisions about
chemical risk reduction, risk man-
agement, testing needs, and pollu-
tion prevention. Also essential is
how these data are managed,
including how they are compiled,
stored, and delivered. The impor-
tance of data management must be
clearly expressed to OPPT staff,
managers, and outside parties to
ensure the success of OPPT pro-
grams. To maximize the benefits of
the information, OPPT must orga-
nize it in useful and accessible
products, such as computer
diskettes, written reports, and CD-
ROMs. At every stage of OPPT
programs, from start to finish, the
information products must be con-
sidered and understood. This
awareness must be conveyed
throughout EPA as OPPT works
to integrate its data with other
data sources in EPA.
2.  Expand and enhance OPPT's
    relations with constituents.
To achieve the goals of OPPT,
there  must be a true partnership
between OPPT, other EPA offices,
the federal government, other
countries, the states and tribes,
industry, and the public. To
achieve that partnership, it is
essential that OPPT adopt a cus-
tomer-oriented focus, communi-
cating with both the providers and
users  of information. OPPT must
continually evaluate its services
and products with both suppliers
and customers in mind.
3-  Widely distribute and provide easy
    public access  to meaningful infor-
    mation, thereby providing a model
    for government,
Information is truly power. OPPT
must take all necessary steps to
ensure meaningful access to its
  Statutes Under Which
  OPPT Collects Data
  • Toxic Substances Control
  • Emergency Planning and
    Community Right-to-
    Know Act
  • Pollution Prevention Act
substantial stores of information
and tools. They should be pack-
aged in user-friendly and accessible
products that are marketed and
distributed to the public. Where
possible, information should be
integrated with other pertinent
data. The information must be dis-
seminated in a manner consistent
with OPPT's statutory mandates,
including  the adequate protection
of confidential information.

4.  Establish standards for informa-
    tion  quality and establish a
    process for achieving them.

OPPT strives to provide informa-
tion that is reliable, accurate, and
up to date. The data collected and
disseminated must be of sufficient
quality  for the intended purposes,
with consideration for  broader uses
over its  entire lifecycle. OPPT will
establish appropriate data-quality

New Strategy continued on page 23
                                        CHEMICALS IN PROGRESS

     Information Management
New Strategy continued from page 22

standards and let users know how
well the data meet the standards.

5.  Develop enhanced capabilities to
   allow OPPT and its constituents
   to analyze and use information
   more effectively.

Analytical capabilities are essential
for OPPT to accomplish its pro-
gram goals. These  tools must be
scientifically credible, current, and
well documented. Tools and infor-
mation systems must be developed
and maintained in accordance with
accepted standards for information
resources management.

6.  Invest in and apply human
   and technological resources to
   achieve efficiency in information

OPPT must increase its efficiency
by investing in information tech-
nology, including computer plat-
forms, applications, and mainte-
nance. Most importantly, however,
OPPT must invest in people.
OPPT must continually evaluate
information management responsi-
bilities to ensure adequate staffing
and training. Because contractors
represent a large part of OPPT's
total information management
resources, it is essential that OPPT
continually improve management
of them.

To provide written comments
OPPT will base its final informa-
tion-management strategy on care-
ful consideration of all comments.
Written comments can be submit-
ted to Andrew Wheeler, of OPPT's
Information Management Division
(7407), 401 M Street, S.W.,
Washington, D.C. 20460
Workshops on Confidential Business Information Offered
The Chemical Manufacturers Asso-
ciation (CMA) is offering work-
shops on how to make effective
confidential business information
(CBI) claims on submissions to
EPA under the Toxic Substances
Control Act (TSCA). EPA's Office
of Pollution Prevention and Toxics
(OPPT) is participating in the

The workshops will cover the sig-
nificance of CBI; its value to
industry, EPA, and the public;
how inappropriate CBI claims lim-
it public access to information;
applicable law and regulations;
allowable claims content; criteria
for substantiation; procedures to
assure claim validity; generic nam-
ing; and EPA screening practices.

In 1992, EPA determined that
some CBI claims in TSCA submis-
sions do not appear  to be fully sup-
portable under the statute. EPA
subsequently identified CBI claim
procedures as an area that could be
improved through voluntary
industry actions, public dialogue,
and education.

Locations and dates. Two-day
workshops are planned for
Washington, D.C., on December 1
and 2, 1993; for Houston, Texas,
on February 23 and 24, 1994; and
for Newark, New Jersey, on June
16 and 17, 1994.
Who should attend. Anyone who
submits TSCA section 5
premanufacture notices (PMNs),
TSCA section 8(e) notices of
substantial risks, TSCA section
8(d) health and safety studies, or
data under TSCA 8(a), the
inventory update rule.

For more information
For additional information, call
Charles Walton, of the CMA, at
                                       VOL. 14 /N0.3, NOVEMBER 1993

                                       Design for the Environment
Before Buying, GSA to Check Custodial Products'
Health and Environmental  Effects
Products  Could Be Used In Thousands of Government Buildings
At least one U.S. agency plans to
use its purchasing power to
advance pollution prevention. The
General Services Administration
(GSA) plans to buy cleaning prod-
ucts for the government buildings
it services only if the products meet
certain efficacy, health, and envi-
ronmental standards.
EPA's Office of Pollution Preven-
tion and Toxics (OPPT) is helping
GSA's Public Buildings Service
(PBS) to organize and  implement
this effort. Using the Existing
Chemicals Program's Risk Manage-
ment process, OPPT is assessing
the health and environmental risks
of selected cleaning products. Later,
OPPT  will assist PBS in develop-
ing procurement criteria based on
efficacy, health, and environmental

Leading edge in acquisition
This effort may have long-term
implications. On October 20,1993,
President Clinton signed an execu-
tive order requiring the federal gov-
ernment to incorporate environmen-
tal considerations in its acquisition
policies. GSA's Federal Supply Ser-
vice will be required to use environ-
mental criteria to select the prod-
ucts  that it supplies throughout the
federal government. While the full
implications of their efforts within
the context of the executive order
must still be determined, OPPT
and PBS expect that their selection
criteria will be suitable for incorpo-
ration into the Federal Supply Ser-
vice system.

Cleaning products that meet the
selection criteria will reduce pollu-
tion that now occurs during manu-
facturing, packaging, use, or dis-
posal. If the U.S. government buys
these cleaning products, so the
thinking goes, other parts of the
public and private sectors will
demand products that meet similar
standards. The demand would
motivate manufacturers to design
into their products steps that will
prevent pollution. This approach is
at the core of OPPT's Design for
the Environment (DfE) program.

Project phases
OPPT and PBS are following a
multiphased process to develop
environmental and health criteria
for custodial products. PBS select-
ed all-purpose cleaners, floor care
products, carpet cleaning products,
snow removal products, and sweep-
ing compounds for evaluation first.
An example of how the criteria will
be developed is described below.
1. OPPT is currently assessing
   the environmental and health
   effects of three sets of cleaning
   products. These products are
   also being tested at a building
   that GSA services. Among the
   considerations in selecting
   these products is that they are
   concentrates. From PBS's point
   of view, a one-gallon container
   of a concentrated product is
   easier to store and handle than
   a 55-gallon drum. From an
   environmental point of view,
   concentrated products dramat-
   ically decrease packaging and
   disposal needs.

2. In conjunction with the prod-
   uct assessments, OPPT and
   PBS are developing criteria for
   selecting custodial products
   that have the most favorable
   combinations of efficacy,
   human health, and environ-
   mental safety. Interested par-
   ties will be invited to partici-
   pate in the development of

Development of voluntary
OPPT's DfE program and PBS are
encouraging manufacturers of all
products to develop and imple-
ment voluntary criteria to prevent
pollution. The OPPT/PBS teams
may work with the American
National Standards Institute to
develop voluntary criteria that
would meet the needs of the federal
civilian and military  supply sys-
tems. All interested parties are wel-
come to participate in this effort.

For more information
To find out more about the activi-
ties described in this article, call
Conrad Flessner, of OPPT's Exo-
nomics, Exposure, and Technology
Division, at (202) 260-3918, or
write to him at the address on
page 43.

                                        Design for the Environment
Update:  Design for the Environment  Program
EPA's Design for the Environment
(DfE) program is stimulating pri-
vate sector efforts to design prod-
ucts and services that reduce
potential risks from chemicals.
DFE programs involve industry,
trade groups, and environmental
groups in cooperative projects to
promote environmental protec-
tion. Current DfE programs focus
on the printing industry, the dry
cleaning industry, and the finan-
cial business community. The
Office of Pollution Prevention and
Toxics (OPPT) administers the
DfE program.

Risk ranking workshop
A summer workshop kicked off
DfE efforts to identify a framework
for ranking the health and envi-
ronmental risks from chemicals
and products used in printing. The
workshop was the first step in
coordinating the different ranking
methods being developed by
industry, universities, and EPA.
Currently, the lack of standardized
methods for comparing chemicals
and product formulations impedes
efforts to (1) design products and
services that are better for the
environment and (2) quickly
screen and rank environmental
impacts of existing products and
services. Workshop proceedings
are available from the Pollution
Prevention Information Clearing-
house (PPIC) at (202) 260-1023.

Printing project
The printing project is focusing on
developing comparative informa-
tion on the risks, exposures, per-
formance, and costs of cleaning
products and inks used in three
methods of printing: lithography,
screen printing, and flexography.

The project has become involved
with the Great Printers Project,
sponsored by the Environmental
Defense Fund, Printing Industries
of America, and the Council of
Great Lakes Governors.  The Great
Printers Project will communicate
DfE information to lithographers
in eight Great Lake states as part
of a larger effort to develop region-
al and local outreach contacts with
craft shops and local printers who
are making environmental strides.

Screen Printing
Screen printers use a process called
screen reclamation to remove the
ink, stencil, and ghost image from
screens.  During this process, recla-
mation chemicals and residue ink
are often washed directly down the
drain. The DfE printing project is
evaluating the health and environ-
mental risks associated with differ-
ent  chemicals (including those
labeled "biodegradable" or "drain
safe"), work practices, and techno-
logical alternatives.

Several preliminary meetings with
the  flexography sector of the print-
ing  industry have been held to
begin investigating alternatives for
work practices involving inks and
for chemicals used in inks.
Financial business community
Three DfE projects are concerned
specifically with integrating envi-
ronmental factors into general
business practices. These projects
focus on the financial business
community, since financial consid-
erations drive nearly all business
Pollution prevention financing
New pollution prevention tech-
nologies cannot be developed and
implemented without the avail-
ability of financing. EPA is form-
ing a pilot program to test the fea-
sibility of including financial
counseling in state technical assis-
tance programs for pollution pre-
vention. This will aid businesses,
especially small and mid-sized
firms, that lack the resources to
package their loan requests in a
convincing manner. The DfE pro-
ject also plans to begin  outreach
to the financial community—
which tends to associate environ-
mental investments with liability
—on the opportunities and value
provided by pollution prevention
Accounting and capital budgeting
Experts who are active in improv-
ing managerial accounting and
capital budgeting practices will
meet at a December workshop.
The objective of the workshop is to
discuss issues involved in incorpo-
rating environmental factors into
managerial accounting and capital

Update continued on page 26
                                        VOL. 14/NO.3 NOVEMBER 1993

     Design for the Environment
Update continued from page 25

budgeting practices and to develop
a strategy to promote needed
changes in these fields. The work-
shop is sponsored by EPA, the U.S.
Chamber of Commerce, the Amer-
ican Institute of Certified Public
Accountants, the Institute of Man-
agement Accountants, and AACE
International, which is an associa-
tion for cost engineers.

Insurance and risk management

EPA is working with the American
Insurance of Chartered Property
and Casualty Underwriters
(AICPCU) to incorporate pollution
prevention into its certification
program for Associates in Risk
Management. AICPCU offers edu-
cation and professional certification
to people in the property and lia-
bility insurance field. EPA is also
examining other opportunities to
incorporate pollution prevention
into the risk management profes-
sion and the insurance industry.

For more information
For information about DfE speak-
ers or to obtain materials about
DfE projects, contact EPA's Pollu-
tion Prevention Information Clear-
inghouse (PM-211 A),
U.S. EPA, 401 M Street, S.W.,
Washington, D.C. 20460;
telephone, (202) 260-1023;
FAX, (202)260-0178.
New case studies are available about
the successful pollution prevention
efforts of a Minnesota lithographer
and a Wisconsin screen printer.
New materials about integrating
pollution prevention into account-
ing systems and capital budgeting
practices are also available.
EPA Completes Study of Dry Cleaning
Demonstration  Project
EPA has completed a study com-
paring the cost and performance of
dry cleaning with an alternative
process that uses heat, steam, and
natural soaps to clean clothes. In
general, the results of the study
indicate that the alternative
process—called wet cleaning—is a
viable option for some segments of
the dry cleaning industry.

The purpose of the study was to
evaluate a process that could
decrease exposures to perchloroeth-
ylene, often referred to as "perc."
Perc is a chemical solvent used by
most dry cleaners. Dry cleaners are
one of the largest groups of chemi-
cal users that come in direct con-
tact with the public.

In November and December 1992,
EPA's Design for the Environment
(DfE) program and the dry clean-
ing industry collaborated on a
demonstration in which 1,500 gar-
ments were cleaned using either
the standard dry cleaning method
or wet cleaning. After cleaning,
both sets of clothes were pressed
on the same equipment and
returned to the consumer. Includ-
ed with each garment was a
postage-paid form for consumers
to use to indicate their satisfaction
with the cleaning of their garment.
Consumers were not informed of
which process was used to clean
their clothes.
Comparisons of customer satisfac-
tion and fabric wear found little
statistical difference between the
two processes, aside from a slight
customer preference for the lesser
odor from clothing cleaned with
the wet cleaning process. Effects of
the wet process over the long term
were not tested and are unknown.

The total estimated costs of the
wet cleaning process are slightly
less than the standard dry cleaning
process. Although the wet clean-
ing process requires more than
three times the skilled labor in the
cleaning phase, this cost is offset
by the  higher annualized costs of
equipment, hazardous waste dis-
posal, electricity, and supplies
needed in the dry cleaning process.

In addition, EPA projections show
that converting an existing dry
cleaning plant to a facility capable
of using both cleaning methods or
building a new wet cleaning facili-
ty are both technically feasible and
economically competitive.

For more information:
For more information about the
EPA's study of the dry cleaning
demonstration, call the Pollution
Prevention Information Clearing-
house at (202) 260-1023.
                                        CHEMICALS IN PROGRESS

                                       Design for the Environment
 Consideration of Alternate Synthetic Pathways  Is Incorporated
 Into Some  PMN Reviews
EPA has expanded its analysis of
new chemicals to include a source-
reduction review of synthetic path-
ways. The objective is to find ways
to reduce the use of toxic feed-
stocks and to prevent production
of toxic byproducts. This approach
is in sync with the objective of the
Pollution Prevention Act of 1990
to prevent pollution or reduce it at
its source whenever possible.

In its assessment of a chemical's
synthetic pathway, EPA uses infor-
mation provided by manufacturers
in premanufacture notices (PMNs).
Federal law requires PMNs for
new chemicals before production
or marketing.

Determining which chemicals
are reviewed
In assessing new chemicals for
source-reduction opportunities,
EPA's Office of Pollution Preven-
tion and Toxics (OPPT) focuses on
nonpolymer chemicals produced in
volumes of at least 25,000 kilo-
grams a year. Excluded from the
source-reduction review are com-
plex reaction mixtures and sub-
stances that qualify for test mar-
keting exemptions, low-volume
exemptions, and polymer exemp-
tions. During a two-stage screen-
ing and assessment, OPPT per-
forms the following steps:
• Determines the sources, identi-
  ties, and quantities of the wastes
  generated during chemical syn-
   thesis prior to treatment or
• Determines if any of these wastes
   are regulated substances or are
   classified as extremely toxic.

• Determines if the solvent used
   in synthesizing the chemical is
   potentially hazardous and if it is
• Assesses whether any of the
   byproducts generated during
   production are potentially
• Determines whether the amount
   of any single Toxics Release
   Inventory chemical present in
   any process stream is equal to or
   exceeds 11,340 kilograms each
If specific conditions are met, the
PMN chemical is sent to the next
stage of assessment. During this
stage, OPPT examines possible
causes for the generation of haz-
ardous wastes and ways to elimi-
nate or significantly reduce the
volume of those  wastes to a level at
which they no longer pose poten-
tial risks to human health or the
Examples of options for reducing
wastes include the use of:
•  In-process recovery and recy-
   cling of the solvent.
•  Recovery and  recycling of
   unconsumed reactants.
• Purer reactants and solvents.
• More selective catalysts that
   create fewer byproducts or

• Lower temperatures or longer
   time periods to increase yields.
• more efficient separation
   processes to purify the new

• Alternate feedstocks or alternate
   synthetic pathways.

Early results
Between January 1993 and June
1993, EPA conducted a source-
reduction review for about 5 per-
cent, or 75, of the approximately
1,500 PMN chemicals reviewed.
In these 75 cases, EPA's chemists
specifically evaluated how synthe-
sis of the chemical would generate
pollution.  They developed alter-
nate methods of synthesis or found
ways to apply new pollution-pre-
vention technologies in a number
of these cases.

EPA has notified the manufactur-
ers of the chemicals by letter that
source reduction is  possible. In
the letter,  EPA specified  its con-
cerns on the particular chemical
and the options that can  be
implemented  to prevent  pollution
at its source. It is up to the manu-
facturer to put these options into
practice since the program is
completely voluntary.
                                       VOL. 14/NO.3 NOVEMBER 1993

     Pollution Prevention Activities
New EPA Project Integrates Source Reduction  into Rulemaking
EPA's new Source Reduction
Review Project is laying the
groundwork for building pollution
prevention into rulemaking. The
project is analyzing 24 proposed
standards to determine how to
develop regulations that will
encourage industry to use source-
reduction options. The 24 stan-
dards affect 17 industrial cate-
gories. (See accompanying list.)
EPA's Pollution Prevention  Senior
Policy Council initiated the Source
Reduction Review Project after
Congress passed the Pollution Pre-
vention Act of 1990. The act
directed EPA to determine how
proposed regulations would affect
source reduction. The term  "source
reduction" refers to reducing the
amount of pollutants that enter a
waste stream or are otherwise
released into the environment pri-
or to recycling, treatment, or dis-
posal. The Source Reduction
Review Project is scheduled to
complete analysis of the 24  pro-
posed rules in 1999.

This is not the first time that EPA
has incorporated source reduction
into rulemaking. It is the first
time, however, that EPA has estab-
lished an agencywide process for
examining the entire picture
before writing rules. This process
includes two important factors:

• Using rigorous technical and
  economic analysis to compare
  source-reduction techniques to
  other controls.

• Taking into account any cross-
Standards Affect 17  Industrial  Categories

The Source Reduction Review Project is analyzing source-reduction
options for 24 proposed rules. The proposed rules include the air toxic
standards—known as MACT standards—set by the Clean Air Act, efflu-
ent guidelines set by the Clean Water Act, and the hazardous waste list-
ings set by the Resource Conservation and Recovery Act.
The proposed rules will affect the following 17 industrial categories:
  Pesticide formulating

  Pharmaceuticals production

  Degreasing operations


  Styrene butadiene latex and
  rubber production

  Reinforced plastic composites

  Plywood and particleboard

  Acrylic fibers/modacrylic fibers
  Wood furniture manufacturing
  Pulp and paper production
  Paint Stripper Users
  Polystyrene production
  Rubber chemicals manufacturing
  Integrated iron and steel
  Machinery manufacturing and
  Paints, coatings, and manu-
  Adhesives manufacturing
  Paper and other webs coating
  media effects and possible
  impacts on the use of energy
  and other resources.

Review process
The project's review process con-
sists of three steps.
1.  Conduct source-reduction
    analyses. EPA identifies and
    evaluates source-reduction
    measures and other controls
    through industry surveys,
    studies, and other means of
    collecting data. Factors that
   are considered include confor-
   mance with statutory authori-
   ty, performance in all media,
   cost, energy requirements, and
   raw materials requirements.
2. Use the analyses to develop
   regulations. When consistent
   with its statutory mandates,
   EPA uses the information from
   its analyses to develop regula-
   tions that encourage source
   reduction. The analyses sup-
   port development of:
Source Reduction continued on page 29
                                       CHEMICALS IN PROGRESS

      Pollution Prevention Activities
 Source Reduction continued from page 28

 • Standards that are based on or
   met through source reduction
   (although specific source-reduc-
   tion technologies would not be

 • Regulatory incentives for
   adopting source-reduction mea-
   sures as an alternative means of

 • Guidance materials that accom-
   pany the final rulemaking to
   educate permit writers and
   industry about the performance
   and cost of source-reduction

 3.  Implement the regulation.
    EPA will provide permit writ-
    ers with training and assistance
    to expedite the review and
    approval of source-reduction
    measures as a means of compli-
    ance. EPA will offer targeted
    assistance to industry to help
    identify and implement
    source-reduction techniques
    that offer the most cost-effec-
    tive means of compliance.
 Pollution  Prevention  Curricula

 Developed for  Higher Education
 The National Pollution Prevention Center for Higher Education, located
 at the University of Michigan, was established in 1991 to help incorporate
 pollution prevention principles into undergraduate and graduate courses
 throughout the nation. The national center conducts a range of activities.
 However, development and dissemination of curriculum modules on pol-
 lution prevention are its first order of business. The modules can be easily
 integrated into existing graduate and undergraduate courses.
 The center has completed and distributed curriculum modules for courses
 in accounting, business law, industrial and operations engineering, and
 chemical engineering. Near completion are modules for architecture, cor-
 porate strategy, operations management, chemistry, and environmental
 Other programs
 The center has organized a National Pollution Prevention Internship Pro-
 gram. The summer program allows qualified students to work on pollu-
 tion prevention projects for different organizations. Representatives from
 the center also participate  in conferences to spread information about pol-
 lution prevention and its place in education. This dialogue helps in dis-
 tribution of pollution prevention modules to interested parties as well as
 in ensuring that necessary information is included in the modules.
 Directory is available
 A national network of university faculty involved in various aspects of
 pollution prevention is being used in the dissemination, development,
 and review of pollution prevention modules. The network is listed in a
 directory, developed by the University of California at Los Angeles and
 the National Pollution Prevention Center for Higher Education. To
 obtain the directory, call the center at (313) 764-1412.
OPPT Puts First-Time Integrated  Report on Hold
In January 1993, EPA's Office of
Pollution Prevention and Toxics
(OPPT) announced it was integrat-
ing a range of information about
toxic chemicals into the report
Industrial Toxics and Pollution Pre-
vention: A National Report. Howev-
er, OPPT found integration of
these data to be quite complex and
decided against trying to develop a
single document at this time.
Individual components of the
report are available to the public in
other documents. For example, the
analysis of selected Toxics Release
Inventory data normalized with
economic data is in chapter 3 of
the 1991  Toxic Release Inventory:
Public Data Release. The document
is available from the Emergency
Planning and Community Right-
to-Know Hotline; telephone,
(800) 535-0202; for the Washing-
ton, D.C., area, (703) 412-9877;
for TDD callers, (800) 553-7672.
In addition, several case studies
developed for the report were pub-
lished in the July/September 1993
issue of the EPA Journal, which
became available in October 1993.
These case studies show the con-
nections between pollution pre-
vention and good business. The
EPA Journal is available from
EPA's Public Information Center
at (202) 260-7751.
                                       VOL. 14/NO.3 NOVEMBER 1993

     Pollution Prevention Activities / 33/50 Program
33/50  Program Achieves 1992 Reduction  Goal  One Year Early
Releases and transfers of 17 toxic
chemicals declined by 34 percent
from 1988 to 1991, meeting the
interim goal of EPA's 33/50 Pro-
gram a year early.

The interim goal of the program
was to reduce nationwide releases
and transfers of 17 chemicals by 33
percent, or about 486 million
pounds, by the end of 1992.
According to data reported by
facilities to EPA's Toxics Release
Inventory (TRI), releases and
transfers of the 17 chemicals
declined 501 million pounds, from
1.47 billion pounds in 1988 to
973 million pounds in 1991. (The
1991 figures provided here exclude
categories of reporting that were
not required in 1988.)

An analysis of the facilities' pro-
jected emissions indicate the 33/50
Program could reach its 1995 goal
of a 50 percent reduction of releases
and transfers by the end of 1993.

EPA began the 33/50 Program to
encourage companies to prevent
pollution rather than continue to
release wastes to the environment
or transfer them to waste manage-
ment facilities. When companies
agree to participate in the 33/50
Program, they provide EPA with a
commitment letter detailing their
reduction targets. TRI data from
1991 show that more than 200 of
the participating companies and
individual facilities have met or
exceeded their target reductions.

Progress reflects many levels of
EPA views the  33/50 Program as
an umbrella under which the fed-
eral government, states, industry,
and local communities work in
partnership to achieve common
goals. Any progress in reducing
emissions reflects the efforts of all
these partners.

Many states,  a number of industry
associations, and numerous indi-
vidual companies include 33/50
Program chemicals in their reduc-
tion programs. Twenty-six states
established toxics use reduction
and pollution prevention programs
prior to establishment of the 33/50
Program, contributing to its
design. Other states have modeled
their pollution prevention pro-
grams on the 33/50 Program.

For more information
• Call or write the 33/50 Program
  Coordinators in EPA's ten
  regional offices. For information
  about the closest regional office,
  call the TSCA Hotline at

• Written communications from
  companies are maintained in a
  publicly available 33/50 Pro-
  gram Administrative Record.
  To view these communications
  or to obtain other information,
  call the 33/50 Program at
  (202)  260-6907 or write to
  it at the address on page 43.
Industry and EPA Find MERIT  in  Partnership
to Prevent  Pollution
On October 4, 1993, EPA's region-
al office in San Francisco
announced a new partnership
between industry and government
to reduce the level of emissions in
southwest Los Angeles County.
The MERIT Partnership for Pollu-
tion Prevention emphasizes multi-
media prevention and the mutual
goals of economic and environ-
mental well-being. MERIT is an
acronym for Mutual Efforts to
Reduce Industrial Toxics.

The ultimate goal of the MERIT
partnership is to develop a pollu-
tion prevention technology enter-
prise zone in southwest Los Ange-
les County. This zone would foster
innovative methods for reducing
releases to the environment.
Carl O. Weisinger, of Dow Chemi-
cal Company, is co-chairing the
MERIT Partnership with Dan
Reich, of EPA. About 16 compa-
nies, representing a cross-section of
manufacturing industries, have
joined the partnership, as have rep-
resentatives from federal facilities
in the area and from state, region-
al, and local agencies.
                                       CHEMICALS IN PROGRESS

     Lead Activities
EPA Developing Four Rules on  Lead-Based Paint
EPA is developing four rules to
meet the requirements of the Resi-
dential Lead-based Paint Hazard
Reduction Act of 1993. A summa-
ry of these rules follows.

Training, accreditation, and
contractor certification
In July 1993, EPA submitted to
agency review a proposed rule that
• Require that people who engage
  in lead-based paint activities are
  properly trained, that training
  programs are accredited, and
  that contractors are certified.

• Set standards for performing
  lead-abatement activities.

• Establish a model state program
  for accrediting and training
  lead-abatement professionals
  in accordance with federal
• Establish a federal program for
  accrediting and training lead-
  abatement professionals in states
  that do  not set up their own

• Provide grants to states to carry
  out authorized accreditation and
  training programs.
By law, EPA must publish the
final rule in the Federal Register
by April 28, 1994.

identification of dangerous
levels of lead
EPA is developing a rule to identi-
fy lead-based paint hazards, lead-
contaminated dust, and lead-cont-
aminated soil. To develop lead
standards for the rule, EPA is rely-
ing on the integrated exposure
uptake biokinetic model, which
estimates blood lead levels for peo-
ple exposed to different environ-
mental sources of lead.
      Final  rules for
     lead-based paint
    will  be published
     by EPA in  1994.
The agency is now documenting
the model, using blood lead stud-
ies for validation, and is perform-
ing independent review of epi-
demiological studies. EPA
anticipates that the proposed rule
will go to EPA's Office Directors'
Lead Committee for review in
December 1993.
The proposed rule would:
• Identify hazardous conditions
  for lead-based paint—for
  instance, paint in deteriorated
  condition, paint on surfaces
  accessible to children, or paint
  that is exposed to friction or
  high impacts.
• Develop health-based standards
  for determining hazardous levels
  of lead in dust and soil.
By law, EPA must publish the
final rule in the Federal Register by
April 28, 1994.

Renovation information
In August 1993, EPA submitted
to agency review a proposed rule
that would require renovators and
remodelers to furnish customers
with a copy of an EPA brochure
about lead hazards before starting
work. By law, EPA must publish
the  final rule in the Federal Register
by October 28, 1994.

Disclosure of lead-based paint
hazards to home-buyers and
In August 1993, EPA submitted
to agency review a proposed rule
that would:
• Require that people selling or
  leasing housing disclose all
  known lead-based paint hazards
  to homebuyers and renters.
• Require that people selling or
  leasing housing provide to
  homebuyers and renters EPA's
  pamphlet describing lead-based
  paint hazards.
• Allow homebuyers 10 days
  in which to obtain a lead
• Require the purchasing contract
  for a home to contain a warning
  that  the property may contain
  lead-based paint.
By law, EPA must publish the
final rule in the Federal Register by
October 28, 1994.
                                       VOL. 14/NO.3 NOVEMBER 1993

     Lead Activities
Lead  Legislation Gets Attention on Capitol Hill
Congress is expected to consider
new lead legislation this session,
some of which would expand the
requirements of the Residential
Lead-based Paint Hazard Reduc-
tion Act of 1993. As this article
went to print in September 1993,
Senator Harry Reid (D-NV), Sena-
tor Bill Bradley (D-NJ), and Rep-
resentative Ben Cardin (D-MD)
had introduced key lead bills.

Senate activity
Senator Reid's bill (S. 729)
requires EPA to promulgate
restrictions on the lead content of
certain products such as industrial
paint and children's toys. S. 729
would also require states to inspect
schools and daycare centers for lead
hazards, using grant funding to be
distributed by EPA.

Senator Reid is not new to lead
legislation. Over  the last few years,
he has introduced a number of lead
bills. An element common to each
of the bills, including S. 729, is an
inventory of lead uses that EPA
would be required to compile and
update periodically. This inventory
provision has faced strong opposi-
tion from industry. Another ele-
ment of Senator Reid's bills in the
past was training requirements for
those conducting lead-based paint
abatement activities. These train-
ing provisions were worked into
the lead bill  that passed last year
and are being implemented by
EPA. While the schools and day-
care provisions are new to the Reid
bill this year, Congressmen Henry
Waxman (D-CA) and Al Swift (D-
WA) included them in lead legis-
lation last year. Several committees
acted on the legislation, but it
never saw action on the House
floor. As of September 1993, no
lead bills similar to the Reid bill
had been introduced in the House.

On June 29, the Toxic Substances
Research and Development Sub-
committee of the Senate Environ-
ment and Public Works Committee
held a hearing on S. 729- Senator
Reid chairs the subcommittee.
Victor Kimm, acting assistant
administrator for EPA's Office of
Prevention, Pesticides and Toxic
Substances, testified for EPA. Also
testifying were representatives from
the National PTA, the Alliance to
End Childhood Lead Poisoning, the
National School Boards Associa-
tion, and the Lead Industries Asso-
ciation, among others.

Senator Bradley's lead bill was
introduced earlier in the summer
and has not seen any activity. The
bill is very similar to Representa-
tive Cardin's bill, which is
described in the next section.

House activity
The lead bill introduced by Repre-
sentative Cardin has strong sup-
port from the environmental com-
munity. Representative Cardin's
bill (H.R. 2479) would create a
lead-abatement trust fund by levy-
ing an excise tax on lead and lead-
containing products. The Depart-
ment of Housing and Urban
Development would allocate mon-
ey from the trust fund to public
organizations in urban areas to
conduct inspections and abate-
ments of lead hazards. Representa-
tive Cardin introduced a bill with
the same concept last year. The
Bush Administration, represented
by the Department of the Treasury
and the Department of the Interi-
or, opposed the bill at a hearing in
the summer of 1992 before a sub-
committee of the House Ways and
Means Committee.

For more information
To obtain more information on
activity surrounding these lead
bills, call Ruth Heikkinen, of
OPPT's Environmental Assistance
Division, at (202) 260-1803-
Pamphlet on Lead
Hazards Being
EPA expects to distribute more
than 25 million copies a year of a
pamphlet for homeowners and ten-
ants about lead risks in housing and
how to assess and avoid those risks.
The pamphlet is being prepared by
EPA, in cooperation with the
Department of Housing and Urban
Development and the Department
of Health and Human Services.
The Residential Lead-based Paint
Hazard Reduction Act of 1993
directed that the pamphlet be
published and distributed. The
pamphlet will be ready for distrib-
ution in October 1994.
                                        CHEMICALS IN PROGRESS

                                        Lead Activities
OPPT Begins 'Check Our Kids for  Lead'  Program
Employee Program To Serve as Public, Private Model
By Joseph J. Breen, Sineta Wooten, and Cindy Stroup
Office of Pollution Prevention and Toxics
In the Office of Pollution Preven-
tion and Toxics (OPPT), we have
had many reasons to feel good about
our activities to protect children
from lead poisoning. These good
feelings were bruised a bit, however,
when staff members attending a
national conference on lead poison-
ing in children overheard some
comments to this effect: "All these
government people ever talk about
are their programs and statistics.
What does it mean to my sister that
200,000 children are at risk? She
wants to know about her boy."

When we returned from the confer-
ence, these comments prompted us
to question  how much our col-
leagues knew about preventing or
reducing their children's exposures
to lead. We decided to encourage all
OPPT personnel with children
under the age of 7—which is when
children are at increased risk—to have
them screened for lead poisoning.

OPPT management wholeheartedly
supported the idea of a Check Our
Kids for Lead Program. Check Our Kids
for Lead brings a strong personal ele-
ment into OPPT's strategy to
reduce lead poisoning and serves as
a model for business and govern-
ment. In developing the program,
we were helped  by EPA's strong vol-
unteer spirit and the special techni-
cal talents found in OPPT.

The Check Our Kids for Lead work-
group obtained  support for the pro-
gram from EPA's Office of Human
Relations and Management, EPA's
Office of Safety and Health, and the
labor unions. EPA's Safety, Health
and Environmental Management
Division was already considering a
staff educational program on child-
hood lead poisoning. The division
welcomed the idea of OPPT pilot-
ing a lead screening and education

The primary goals of Check Our Kids
for Lead are to educate OPPT staff
on lead exposure issues and to
encourage OPPT employees to have
their children's blood lead levels
tested. Once the program is success-
fully piloted, we would like to make
it available to other offices at EPA
headquarters, EPA regional offices,
other federal agencies, and the pri-
vate sector. Toward that end, we are
developing an education program
that can be packaged and provided
to other groups.
Some of the components of Check
Our Kids for Lead that we have devel-
oped and implemented are
described below.
• A baby card to celebrate the birth
   of a child in an OPPT family was
   designed by an OPPT staff mem-
   ber. The card welcomes the new
   arrival and includes a copy  of the
   EPA  brochure Lead Poisoning and
   Your Children. The baby card
   comes in pink or blue.
• A brochure listing blood lead
   screening laboratories that service
   Washington, D.C., and its  sur-
   rounding areas in Maryland and
  Virginia was produced.
• An information package about
  lead poisoning and how to mini-
  mize exposures was distributed to
  every OPPT staff member. The
  package included a cover memo-
  randum signed by  the OPPT
  deputy director and the presi-
  dents of the National Federation
  of Federal Employees, Local
  2050, and American Federation
  of Government Employees,
  Local 3331.
• Public outreach activities have
  included a presentation to Lead-
  ership Washington, a group of
  public and private sector execu-
  tives working to support the
  Washington, D.C., community; a
  lead awareness seminar for EPA
  employees; distribution of the
  information packages at EPA's
  Wellness Fair; and participation
  in the Public and Community
  Health Program of the Howard
  University College of Nursing.
• Discussions have been held with
  private sector institutes and cor-
  porations to develop Check Our
  Kids for Lead programs as part of
  their employee health care and
  wellness programs.

For more information
To obtain OPPT's Check Our Kids for
Lead information packet, call Sineta
Wooten, of OPPT's Chemical
Management Division, at
(202) 260-3888 or write to her at
the address on page 43.
                                        VOL. 14/NO.3 NOVEMBER 1993

                                      Lead Activities
Lead Activities  at the State Level Are Growing
Since Congress passed the Residen-
tial Lead-based Paint Hazard
Reduction Act in 1992, states have
increased  their activities to reduce
lead exposures. During the 1993
legislative sessions, 12 states intro-
duced comprehensive bills relating
to reduction of lead hazards. Four
of these bills passed, five failed,
and three others are pending.
Most of the state legislation
includes development of certifica-
tion programs for lead-abatement
professionals. In the Residential
Lead-based Paint Hazard Reduc-
tion Act, Congress set aside funds
for states to use for developing
these programs.
Before the Residential Lead-based
Paint Reduction Act was passed,
eight states already had laws aimed
at preventing lead poisoning: Cali-
fornia, Connecticut, Illinois,
Maine, Maryland, Massachusetts,
Minnesota, and Rhode Island.
Since passage of the act, four states
have passed similar laws: Louisiana,
Missouri, New Hampshire, and
Vermont, Legislation is pending in
New Jersey, Ohio, and Wisconsin.
The chart on this page identifies
the basic elements of each state's
lead-hazard reduction laws.
State Lead Hazard Reduction Statutes: September 1993






must be
reported to







required for




Disclosure of
lead hazards
in real estate


and education




Lead Task





Lead Activities
State Lead Hazard Reduction Statutes: September 1993, cont'd.







must be
reported to














required tor






Disclosure of
lead hazards
in real estate





and education







Lead Task




                             VOL 14/NO.3 NOVEMBER 1993

     Lead Activities / International Activities
Lead  Update

Clearinghouse Provides
Technical  Information
about Lead

The U.S. government has a clear-
inghouse to provide federal publi-
cations, selected journal articles,
and other technical information on
lead. The clearinghouse is staffed
by trained information specialists
who can answer specific questions
on lead-related issues. The clear-
inghouse serves interested citizens;
people in  the medical, health care,
and public health fields; people in
the housing construction and resi-
dential renovation sectors; people
in the retail, financial, real estate,
and insurance sectors; the news
media; and public agencies at the
federal, state, and local levels.
The telephone number for the
National Lead Information Clear-
inghouse is (800) 424-LEAD
(424-5323). In the Washington,
D.C., metropolitan area, the num-
ber for the clearinghouse is
 (202) 833-1071. Hearing-
impaired persons can reach the
clearinghouse by calling TDD
number (800)  526-5456; the TDD
number for the Washington, D.C.,
area is (202) 293-0113.
U.S. Attends OECD Meetings
on Chemicals
The Organization for Economic
Cooperation and Development
(OECD) held a series of meetings
concerning chemicals the week of
May 23, 1993. Representatives
from the United States and the 23
other OECD member nations
attended the meetings, which took
place in Paris. Summaries of the
meetings are below.

SIDS update
The nations that participate in
OECD's Screening Information
Data Set (SIDS) program agreed to
update and expand the list of
chemicals for which  it is develop-
ing test data. Among the chemi-
cals that will be considered are
those on the European Communi-
ty's list of existing chemicals that
are produced or imported in excess
of 1,000 tons each year. The Euro-
pean Community is using the list
to identify chemicals of concern.

The SIDS program is an effort to
develop a base set of test data for
existing chemicals produced in the
largest quantities worldwide. In
1990, the SIDS program identified
for initial action 154 chemicals
that are produced in large quanti-
ties worldwide. Since then, the
SIDS program has worked with
industry in its 24 member nations
to voluntarily test the chemicals
for toxicity potential. Prior to this
effort, few test data were available
publicly on these substances.

EPA's Office of Pollution Preven-
tion and Toxics (OPPT) represent-
ed the United States at the meet-
ing. Also in attendance were repre-
sentatives from the European
Community, Mexico, the Interna-
tional Registry of Potentially Tox-
ic Chemicals, and the Business and
Industry Advisory Committee.
   The SIDS prog ram
      is an effort to
   develop a base set
     of test data for
   existing chemicals
     produced  in the
    largest quantities
A meeting was held in September
1993 to determine testing needs
for the 58 chemicals in Phase 3 of
the SIDS program. In the future,
only those chemicals identified as
needing discussion will be put on
the agenda for SIDS review meet-
ings. Other reviews will be con-
ducted through written communi-

Risk reduction pilot project
The risk reduction pilot project is
                                      CHEMICALS IN PROGRESS

      International Activities
exploring how to reduce the risks
from exposure to lead, mercury,
cadmium, methylene chloride, and
brominated flame retardants. Each
participating nation is developing
a monograph that explains how it
regulates each chemical. The
monographs will be analyzed to
identify risk reduction activities
for the nations to act on, either
individually or collectively.

Lead is the first chemical to under-
go this process. The monograph
was recently completed and mem-
ber nations are developing collec-
tive activities  for implementation.
These activities will be incorporat-
ed into the OECD Council Lead
Act. Drafting  of the act will begin
in November  1993.

The OECD renewed the mandate
for the Good Laboratory Practice
Panel and endorsed  a document
clarifying procedures for develop-
ing test guidelines that meet
OECD harmonization standards.
The United States and European
Community nations are analyzing
how each nation's industry will be
affected economically by harmo-
nization of health effects classifica-
tions. The OECD's long-term
plans include harmonizing the
classification of reproductive
effects and carcinogenicity.

New chemicals assessments
The United States and Canada are
conducting a pilot study on the
feasibility of exchanging new
chemicals assessments. The Aus-
tralian delegation reported on the
results of a survey they conducted
on new chemicals assessment pro-
grams. The study shows that
nations agree on the need for
increased exchange of assessments
and notes existing barriers may
prevent more sharing.

Intergovernmental forum on
chemical safety
The Swedish delegation hosted an
informal meeting to prepare for
the first session of the Intergovern-
mental Forum on Chemical Safety,
scheduled for April  1994. The
forum will oversee implementation
of the toxic chemicals program
areas identified in UNCED Agen-
da 21, chapter 19. The program
areas are risk assessment, risk
reduction, information exchange,
strengthening national capabilities
for managing chemicals, and stan-
dardizing the way chemicals are
classified and labeled.
At the meeting, the United States
emphasized the need to move
toward organizing risk-reduction
activities around specific process or
use patterns rather than on a
chemical-by-chemical basis. This
approach would allow risk compar-
isons, which helps assessors to
identify safer products and process-
es that can prevent pollution. The
United States also advocated that
developing countries build their
capacity for chemicals manage-
ment by first implementing low-
cost, high-benefit programs and
moving to more sophisticated pro-
grams as resources permit.
Regulations Are
In a survey of its member nations,
the Organization for Economic
Cooperation and Development
found many similarities among the
nations' biotechnology regulations.
The results of the survey were
reported in the Workshop on the
Environmental Aspects of Biotech-
nology held in  Brussels on May 3
and 4, 1993. A second workshop is
scheduled for May 1994.

OECD Forms
Pesticide Forum
In June 1993, the OECD estab-
lished a forum  to support efforts to
harmonize requirements for pesti-
cide licensing programs. The new
Environment Pesticide Forum will
work on test guidelines, data
requirements, hazard/risk assess-
ment, re-registration, information
exchange, risk reduction, and har-
monization of classification sys-
tems.  Forum members agreed that
whenever its work overlapped with
work being done by OECD's ongo-
ing chemical program, the two
programs would integrate their
efforts. Two areas in which this is
likely to occur are development of
test guidelines  and harmonization
of classification systems.
     VOL 14/NO.3 NOVEMBER 1993

EPA and Environment Canada Address Bioremediation
Risk Assessment
A workshop on risk assessment
issues related to use of bioremedia-
tion to clean up hazardous waste
sites in the United States and
Canada was held June 17 to June
18 in Duluth, Minnesota. The
workshop was attended by about
90 people, representing universi-
ties, industries, federal organiza-
tions, and state and provincial gov-
ernments in both nations.

The workshop targeted 10 groups
of biodegradable wastes commonly
found at U.S. and Canadian sites,
including trichlorethylene (TCE),
polychlorinated biphenyls (PCBs),
and munitions. It was sponsored
by Environment Canada's Com-
mercial Chemicals Branch and two
EPA offices—the Office of Pollu-
tion Prevention and Toxics
(OPPT) and the Office of Research
and Development (ORD).

At the workshop, a private firm,
Southern Bioproducts, gave a
detailed presentation on its pro-
posal to test the TCE-degrading
capabilities of a strain of
Pseudomonas cepacia at a Canadi-
an site. The test would involve the
first North American release of a
recombinant bacterium for on-site
cleanup. The U.S. Department of
Defense's laboratory at Fort Det-
rick, Maryland, also gave a presen-
tation on a set of biological assays
for toxicity screening of remedia-
tion site effluents.

Workshop participants received a
detailed issue paper, prepared by
the University of Tennessee and
EPA, summarizing the available
literature in five areas:

• risk assessment schemes
• major metabolic pathways of
  selected hazardous pollutants

• human health protocols for
  metabolite and pathogenicity

• ecological effects protocols for
  metabolite and pathogenicity

• fate protocols and issues for
  microorganisms and metabolites

The workgroups' key findings and
recommendations in  these areas will
be considered by EPA and Environ-
ment Canada as they continue to
develop guidance for bioremedia-
tion product evaluations.

Summary of key findings
Risk assessment schemes. The risk
assessment workgroup developed a
general flow diagram for  health
and environmental risk assessment
relevant to bioremediation sites.
Information on microorganisms,
site pollutants and their physical
and chemical properties,  and gen-
eral site characteristics were identi-
fied as necessary components of a
risk assessment. Participants rec-
ommended that laboratory and/or
greenhouse efficacy studies (such as
mass balance or other microcosm
tests)  and information on metabol-
ic pathways also could be useful for
identifying metabolites and assess-
ing metabolite toxicity.
Metabolic pathways. The goal of this
workgroup was to determine the
combinations of pollutants, path-
ways, and environmental factors
that lead to generation of signifi-
cant quantities of hazardous
metabolites. The group concluded
that the intermediates for some
compounds (such as aromatics) and
specific organisms are predictable
given certain site information.
Often, however, the presence of
complex mixtures complicates the
process. For metabolites of known
structure, quantitative structure-
activity analysis techniques can be
useful in predicting toxicity. The
workgroup discussed specific
metabolites of concern for metals,
aromatic hydrocarbons, phenolics,
halogenated organic compounds,
alkanes, pesticides, sulfur- and
nitrogen-containing heterocyclics,
complex mixtures, and munitions.
Human health protocols. This work-
group determined that metabolite
toxicity should be tested separately
from pathogenicity and toxin pro-
duction. Participants acknowl-
edged that reliable tests already
exist for assessing metabolite toxi-
city but that techniques for extrac-
tion of chemicals sorbed to sedi-
ments need further development.
Exposure routes for microorgan-
isms depend on the specific biore-
mediation process, but pathogenic-
ity tests might need to consider
oral, intravenous or intraperi-
toneal, and pulmonary exposures
                                        CHEMICALS IN PROGRESS

when the microorganism is
unknown. When some information
is available, rapid screening tests,
such as gene probes, are needed.
The group also recommended fur-
ther research on the allergenicity
effects of microbial antigens,  and
their effects when combined with
chemicals  at a site.  The group also
developed a decision tree for tiered
mammalian health  effects.

Ecological effects. Like the human
health workgroup,  the ecological
effects workgroup also concluded
that metabolite toxicity and path-
ogenicity should be addressed
using separate tests, with patho-
genicity tests dependent on the
availability taxonomic informa-
tion. The decision tree developed
by the workgroup began with
tests for pathogenicity, followed
by single species tests with both
positive and negative controls.  For
pathogenicity testing, the work-
group recommended using, for
aquatic vertebrates and mammals,
EPA Pesticides Program's Subdi-
vision M tests and, for plants, in
vitro screening tests, such as
enzyme tests.

For toxicity testing, the group
concluded that protocols such as
EPA's Office of Water's short-term
chronic tests would be appropriate,
but that tests for terrestrial organ-
isms might need refinement. The
decision tree also included the
selection of toxicity tests based on
exposure and ecosystem tests,
where applicable.

Fate protocols and issues. This work-
group felt  that the microcosms
currently used for efficacy studies
are simplistic relative to field con-
ditions. Participants recommended
the following test endpoints for
risk assessments: mass balance for
parent compounds, accumulated
metabolites, and gaseous end prod-
ucts; persistence; and residual den-
sity of organisms mediating the
bioremediation process. The work-
group also identified site informa-
tion critical to determinations of
chemical and microbial fate and
transport. The workgroup exam-
ined the applicability of some
mathematical models to determin-
ing metabolite and bacterial/fun-
gal fate and transport in the sub-
surface, and found them
inadequate for risk assessment.
Items recommended for inclusion
in risk assessment models were
microorganism growth and death
rates, dissemination and transport,
persistence of boundary values
such as lower survival levels of
degradative organisms, sensitivity
analysis, potential for formation
and exposure, contaminant strate-
gy under site conditions, potential
for genetic exchange, predation
rate quantitation, and net metabo-
lite formation and decay.

For more information
Workshop findings will be
detailed in an ORD report that
will be available in early 1994.
For more information, call  Philip
Sayre, OPPT's Health and Envi-
ronmental Review Division, tele-
phone, (202) 260-9570, or write
to him at the address on page 43.
Or, call Terry Mclntyre, of
Environment Canada, at


 Scheduled for

 A workshop to develop ecological
 tier testing schemes for micro-
 organisms used in biotechnology
 applications will be held January
 11 through 13, 1993, in
 Washington, D.C.
 The applications on which the
 workshop will focus are bioremedi-
 ation, biomining, mineral leach-
 ing, coal transformations,  desulfur-
 ization of petroleum products, oil
 recovery, biomass conversion, fuel
 production, waste treatment,
 nitrogen fixation, and closed sys-
 tem fermentation.
 Key findings and recommendations
 from the workshop will be consid-
 ered by EPA and Environment
 Canada as the agencies develop
 guidance for using microorganisms
 in these applications for the United
 States and Canada, respectively.
 The workshop is jointly sponsored
 by EPA's Office of Pollution Pre-
 vention and Toxics, EPA's Office of
 Research and Development, and the
 Commercial Chemicals Branch of
 Environment Canada.

 For information about attending
the workshop
To arrange to attend the confer-
ence, call Lou Borghi, telephone,
(703) 934-3255 or Jennifer Wei-
ham, telephone, (703) 218-2639,
at Clement International
                                        VOL. 14/NO.3 NOVEMBER 1993

                                       Enforcement/General Information
Roundup: Enforcement Activity
  In a brief supporting its petition
  for review before the U.S. Court
  of Appeals for the District of
  Columbia Circuit, the Minneso-
  ta Mining and Manufacturing
  (3M) Company argued that the
  federal five-year statute of limi-
  tations should apply to assess-
  ment of civil penalties under the
  Toxic Substances Control Act
  (TSCA). Last year, EPA's Envi-
  ronmental Appeals Board
  upheld a  1988 administrative
  law judge's decision against the
  3M Company for importing
  chemicals not on the TSCA
  Inventory and for incorrect
  import certification between
  1980 and 1986. The 3M Com-
  pany is headquartered in Min-
  neapolis,  Minnesota.

  Hall-Kimbrell Environmental
  Services and EPA have signed
  consent agreements to settle cas-
  es brought by four EPA regional
  offices. The cases resolved the
  issue of whether dry wall and
  hard plaster are  suspect materi-
  als under the Asbestos Hazard
  Emergency Response Act
  (AHERA). Under the consent
  agreements in EPA regions 2, 7,
  8, and 9, Hall-Kimbrell, an
  asbestos contractor, will pay
  penalties amounting to
  $285,000. In EPA regions 7 and
  8, Hall-Kimbrell will also send
  to every school district for
which it prepared an asbestos
management plan a letter stat-
ing that EPA instructs the dis-
trict to assume that any drywall
and hard plaster in schools con-
tain asbestos. EPA acknowl-
edged in the agreements for
regions 2 and 7 that Hall-Kim-
brell had voluntarily re-per-
formed $5  million of work in
schools. Hall-Kimbrell is based
in Lawrence, Kansas. EPA's
region 2 office is in New York,
New York; the region 7 office is
in Kansas City, Kansas; the
region 8 office is in Denver, Col-
orado; and the region 9 office is
in San Francisco.

EPA and the Ciba-Geigy Com-
pany have  entered into a consent
agreement that requires Ciba-
Geigy to pay a civil penalty of
$62,000 and to perform an
audit to ensure compliance with
EPA regulations. Penalties stip-
ulated as a result of this volun-
tary audit cannot exceed $1 mil-
lion. EPA filed suit against
Ciba-Geigy and 21 other com-
panies for failing to submit pre-
manufacture notices (PMNs)
before manufacturing or
importing  new chemical sub-
stances, as  required by section 5
of the Toxic Substances Control
Act (TSCA). The Ciba-Geigy
case was the first of these cases
to be settled.
Schools Awarded

$76.2 Million for



EPA has awarded $76.2 million in
grants and loans to schools for use
in abating asbestos. The funds were
offered to public school districts
and private nonprofit schools for
abatement projects in 239 schools.
More than 400 local education
agencies had applied for the funds.
The awards consist of about $5.7
million in grants and $70.5 mil-
lion in interest-free loans. They
constitute the largest appropria-
tion in the history of EPA's
asbestos abatement program,
established by the Asbestos  School
Hazard Abatement Act (ASHAA).
The schools that were offered
awards met two conditions: They
demonstrated financial need, and
they contained asbestos posing a
high degree of hazard. ASHAA
directs EPA to rank each school's
proposed projects according to the
type of asbestos-containing build-
ing materials in the school and the
materials' condition.
Since 1985, EPA has provided
$422 million to 2,377 schools for
asbestos abatement. EPA estimates
these abatement projects, once
completed, will eliminate 28 mil-
lion exposure hours per week.
Public school districts and private
nonprofit schools will be notified if
Congress appropriates funds for
awards in fiscal 1994.

Availability  of 8(e)  Notices and  FYI  Submissions
Under section 8(e) of the Toxic
Substances Control Act (TSCA),
anyone who obtains information
that indicates a chemical may pose
a substantial risk of injury to
human health or to the environ-
ment must report that information
to EPA within 15 working days of
obtaining it.

From October 1, 1991, to August
27, 1993, more than 7,900 TSCA
section 8(e) notices were submitted
to EPA's Office of Pollution Pre-
vention and Toxics (OPPT). The
majority of these were submitted
by companies participating in
EPA's Compliance Audit Program
(CAP), which provides reduced
penalties for companies submit-
ting late studies.

FYI submissions
EPA received 10 For Your Infor-
mation (FYI) submissions from
April 1, 1993, to August 31,
1993. FYIs are voluntary submis-
sions and may include data on
chemical toxicity and exposure,
epidemiology, monitoring, and
environmental fate.

How to obtain 8(e)  notices and
FYI submissions
• Section 8(e) and FYI submis-
  sions can be reviewed and
  photocopied at EPA headquar-
  ters, in the TSCA Non-Confi-
  dential Information Center,
  telephone (202) 260-7099 or
  (202) 260-0660.
  A copy of a full section 8(e) or
  FYI submission can be obtained
  by writing to Freedom of Infor-
  mation Office (A101), U.S.
  EPA, 401 M Street, S.W.,
  Washington, D.C. 20460.
  Duplication of the first 166
  pages of any document is free.
  At the 167th page, there is a
  $25 fee and an additional $0.15
  charge for each page.

  Chronological indices of section
  8(e) and FYI notices are avail-
  able from the TSCA Hotline
  two to three months after the
  end of each fiscal quarter. The
  fiscal quarters end on September
  30, December 31, March 31,
  and June 30. Information on
  contacting the hotline is on
  page 43.
Overview of TSCA
Section 8(e) Notices
October 1,1991 to August 27,1993
Total number received     7,965
Number entering
initial screening
Number completing
initial screening
Hazard concern
Number on
TSCA Inventory*



* Once a CAP submission enters initial
  screening, OPPT determines whether the
  chemical substance is listed on the TSCA
  Inventory. Thus, the numbers in this col-
  umn do not include submissions that have
  not entered screening.
New Databases Available to the Public

The Office of Pollution Prevention and Toxics is making available
the Toxic Substances Control Act (TSCA) section 8(e) database and the
TSCA section 4 abstracts database.
Section 8(e) of TSCA requires manufacturers, importers, and distributors
of chemical substances and mixtures to inform EPA of risk of injury to
human health or the environment. The TSCA section 8(e) database con-
tains the ranking system that EPA uses to prioritize section 8(e) submis-
sions by toxicity concern.

Section 4 of TSCA requires industry to submit to EPA unpublished test-
ing data on the health and environmental effects of specific chemicals.
This database contains abstracted summaries of the full studies submitted
under section 4.
Both databases can be used as pointer systems to access full studies of
interest to users. For copies of the databases, please call the TSCA Hot-
line at (202) 554-1404.
     VOL 14/NO.3 NOVEMBER 1993

                                       TSCA Hotline/IRIS
TSCA  Hotline: Question  & Answer
Q: What are my responsibilities
for providing updates to the TSCA
inventory data base?
A: The Toxic Substances Control
Act (TSCA) Chemical Substances
Inventory is a comprehensive list
of chemical substances that can
legally be manufactured in the
United States or imported. Every
four years, EPA requires companies
to report certain information to
update the TSCA inventory. You
will be required to report in 1994
if you import or manufacture
10,000 pounds or more of a
reportable substance at any single
site during the last fiscal year com-
pleted prior to the reporting peri-
od. The reporting period begins
August 25, 1994, and runs to
December 23, 1994.
All substances on  the TSCA inven-
tory are subject to the rule's
reporting requirements, with the
exception of polymers, inorganic
substances, microorganisms, and
naturally occurring substances.
Substances in these excluded cate-
gories are reportable, however, if
they are subject to proposed or
final rules under sections 4, 5(b),
5(e), 6 of TSCA, or if they are the
subject of relief granted under a
civil action under sections 5 or 7
of TSCA.

Exemptions from reporting
Exempted from reporting are cer-
tain small  businesses and those
that manufacture or import under
limited circumstances (such as,
nonisolated intermediates or small
quantities of a substance for
research and development).
Also exempted from reporting is
anyone who has already submitted
the information required for the
inventory  update to EPA under
section 8(a) of TSCA. To qualify
for this exemption during the next
reporting period, the information
would have to be submitted  on or
after August 25, 1993.

To submit information for the
Information for the update must
be reported on an original copy of
Form U or by magnetic media.
Complete instructions for com-
pleting the reporting form or
preparing a magnetic media report
are in the booklet Instructions for
Reporting for the Partial Updating
of the TSCA Chemical Inventory
Data Base.
Reporting forms and the instruc-
tion booklet for the 1994 report-
ing year will be available from the
TSCA Hotline; telephone, (202)
554-1404. Anyone who reported
for the last reporting period will
automatically be mailed reporting
Late reporting. The last reporting
period began August  23, 1990,
and was extended to February 21,
1991. If you were required to sub-
mit information for that period
and did not do so, call Scott
Sherlock, of OPPT's Information
Management Division, at (202)

For more information
For more information about the
Partial Updating of the TSCA
Chemical Inventory Data Base, see
40 CFR 710.25 to 710.39.
 IRIS  Is Accessible to the Public
 The Integrated Risk Information
 System (IRIS) is an EPA database
 containing health effects informa-
 tion and regulatory  information on
 about 400 chemical sustances. The
 database is accessible to the public
 through the National Library of
 Medicine's Toxicology Data Net-
 work. Disketttes containing the
 database can be purchased from
 National Technical Information
 Service (NTIS) (order number
 PB91-591331). For more informa-
 tion, call the National Library of
 Medicine at (301) 496-6531; the
 NTIS at (703) 487-4650; or IRIS
 User Support at (513) 569-7254.
                                        CHEMICALS IN PROGRESS

        For More Information
Send All Correspondence to

Environmental Assistance Division (7408)
Office of Pollution Prevention and Toxics
401M Street, S.W.
Washington, D.C, 20460
Would You  Like to Receive the

Chemicals-in-Progress Bulletin?

The Chemicals-in-Progress Bulletin is published by EPA's Office of Pol-
lution Prevention and Toxics. If you are not currently receiving the
Bulletin and would like to become a subscriber, or if you would like
to stop receiving the Bulletin, please fill out this form or tape a mail-
ing label onto it, and mail it to the address on this page.

D Please add my name to the mailing list.

D Please change my address.

D Please take my name off the mailing list.

D Please send me the following publication(s):
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TSCA Hotline:

Call (202) 554-1404

The TSCA Hotline operates Mon-
day through Friday, from 8:30
a.m. to 5 p.m., Eastern time. To
speak to an information specialist,
call (202) 554-1404.  FAX requests
for documents are received every
day, at all times, on (202) 554-
5603.  Documents can also be
requested by deaf persons who
have TDD equipment by calling
To request assistance  by mail,
write to the Environmental Assis-
tance Division at the address at
the left.

Lead  Hotline:  Call

(800) LEAD-FYI

Parents can obtain information
about protecting their children
from lead poisoning by calling the
National Lead Information Center
Hotline at (800) LEAD-FYI (532-
3394), The hotline operates 24
hours a day, seven days a week, in
English and in Spanish.

The line is answered  by a record-
ing that asks callers to leave their
name and address. Callers are then
sent information on reducing chil-
dren's  exposure to lead, testing a
home for lead, getting blood-lead
levels tested, and the possible lead
hazards generated by home repairs
and renovations. A list of state and
local agencies that can provide
additional information is also
included. Materials are available in
English or Spanish.
                                   VOL. 14/NO.3 NOVEMBER 1993