SPRING 1994 EPA-745-N-94-001
                    Chemicals in Progress

    3  Profile of Lynn Goldman,
       EPA's Assistant
       Administrator for
       Prevention, Pesticides
       and Toxic Substances

   18  Green Chemistry:
       Benign by Design

   38  ECOSAR: New Ecotox
       Software Available
                               TRI  Releases Decline 6.6% in 1992

                               U.S. manufacturers reported releasing a total of 3.18 billion pounds
                               of toxic chemicals into the nation's environment in 1992, a decline of
                               6.6% since 1991. According to a summary of the Toxics Release
                               Inventory (TRI) data announced by Dr. Lynn Goldman, Assistant
                               Administrator for the Office of Prevention, Pesticides and Toxic
                               Substances (OPPTS) on April 19, industrial releases of toxic chemicals
                               have declined 35% since 1988.
                               Although reported releases decreased, the total amount of toxic chemi-
                               cals in waste generated by industry increased slightly since 1991, to
                               37.33 billion pounds. This increase was small in percentage terms (0.5%)
                               but represented an additional 170 million pounds of toxic chemicals in
                                                                           TRI continued on page 2
TSCA Section  21 Petitions

Since December 1993, EPA has received three citizens' petitions, two of
which relate to pollution in the New River in Imperial County, Califor-
nia. The New River flows north from Mexico into Imperial County. The
third petition is from the United Automobile Workers and relates to
machining fluids.
Section 21 of the Toxic Substances Control Act (TSCA) provides that
any person may petition EPA to initiate proceedings for the issuance of
rules under sections 4, 6, and 8 of TSCA.

A Section 21 petition must set forth the facts which the petitioner
believes establish the need for the rules requested.
EPA is required to grant or deny the petition within 90 days. If EPA
grants the petition, the Agency must promptly commence an appropriate
                                          TSCA continued on page 6
     VOL 15 / NO. 1  SPRING 1994

      Table of Contents
 1 TRI Releases Decline
   6.6% in 1992
17 TRI Chemical Expansion

 1 TSCA Section 21 Petitions
 3 Lynn Goldman Brings Medical,
   Health Service, Environmental
   Backgrounds  to OPPTS

Existing Chemicals
 9 Existing Chemical Program
   Establishes Priorities for FY94
10 Formaldehyde Exposure
   Testing in New Housing
12 ATSDR Chemicals Added to
   Master Testing List
14 RM2 and Post-RM2
   Activity Chart

New Chemicals
17 OPPT Establishes New
   Chemicals Pollution Prevention
   Recognition Project

Design for the Environment
18 Green Chemistry:
   Benign by Design
21 DfE Printing Project Enters
   Product Demonstration Phase
22 EPA Technology Innovation
   Strategy Emphasizes

Pollution Prevention
23 Proposed Pulp and Paper Rule
   Integrates Multi-Media Source
   Reduction Measures
23 33/50 Program Achieves '92
   Reduction Goal One Year Early
24  Fifty-Two Pollution
    Prevention Grants Awarded
25  Pollution Prevention
    Clearinghouse Receives High
    Marks for Information Services
26  National Roundtable of State
    Pollution Prevention Programs-.
    1994 Spring Conference
26  Conference to Promote
    Voluntary Initiatives
27  Environmental Management
    Standards-. Is EPA ISO-lated?

Lead, Asbestos, PCBs
29  PCB Petition Denied

30  International Community Steps
    Up Focus on Toxics Inventories
31  OECD Member Countries
    Consider Limiting Lead in
    Consumer Products
32  Report of the  3rd SIDS
    Review  Meeting
34  EPA and Environment Canada
    Exchange Information

35  Clinton  Administration
    Proposes Reforms in Nation's
    Pesticide and Food Safety Laws

36  Enforcement Reorganization

TSCA Hotline
37  Q&A-. Exporter Responsibilities

38  ECOSAR: New Ecotoxicity
    Software Available
1992 TRI  Releases

TRI from page 1
waste managed by facilities.

Reported transfers to off-site
locations for waste management
climbed nearly 17% in 1992, to
4.37 billion pounds. Most of this
increase was due to increased
transfers for recycling.

The top five states for total TRI
releases, including underground
injection, were Louisiana, Texas,
Tennessee, Ohio, and Indiana.

The top five industry categories for
total TRI releases were chemical
manufacturing, primary metals,
paper manufacturing, plastics, and
transportation  equipment.

A total of 23,630 facilities submit-
ted 81,016 individual chemical
reports to TRI  in 1992. The top 50
facilities reporting to TRI ac-
counted for 42% of total TRI

TRI data are collected and made
available to the public under the
provisions of the Emergency
Planning and Community Right-to-
Know Act of 1986 and the Pollu-
tion Prevention Act of 1990.

Releases and  Transfers

Releases to Air: Reported air
emissions totalled 1.84 billion
pounds in 1992,  representing
about 58% of all  TRI releases. Air
emissions declined 9.4% since
1991, largely due to decreased
emissions of a variety of solvents,
ammonia, and chlorine.

                 TRI continued on page 8

Goldman  Brings Medical,  Health Service,
Environmental Backgrounds to OPPTS
Dr. Lynn R. Goldman, a pediatri-
cian and epidemiologist who most
recently served as the Acting Chief
of the California Department of
Health Services' Division of Envi-
ronmental and Occupational
Disease Control, has been ap-
pointed EPA's Assistant Administra-
tor for Prevention, Pesticides and
Toxic Substances. She assumed her
position at EPA in October 1993.

Among her duties with the
California Department of Health
Services, Dr. Goldman was
responsible for environmental
investigation, occupational health,
childhood lead poisoning preven-
tion,  and birth defects monitoring.
She has published extensively in
the areas of environmental epide-
miology and the prevention of
childhood lead poisoning.
Dr. Goldman earned a bachelor's
degree in Conservation of Natural
Resources and a master's degree
in Health and Medical Sciences
from the University of California,
Berkeley. She also earned an
M.P.H. from Johns Hopkins
University and an M.D. from the
University of California, San
Francisco. She trained in pediat-
rics at Children's Hospital in
Oakland, California, and com-
pleted a preventive medicine
residency at the University of
California, Berkeley.
Dr. Goldman is a fellow of the
American Academy of Pediatrics
(AAP), where she served on the
Environmental Health Committee.
She has served on the National
Research Council (NRC) Water
Science and Technology Board,
the NRC Committee on Environ-
mental Epidemiology, and the
U.S. Centers for Disease Control
Advisory Committee on Child-
hood Lead Poisoning Prevention.

Clarifying the goals and priorities
of OPPTS was the  first job Dr.
Goldman took on when she
assumed her position with EPA.
She identified OPPTS's primary
goals as "the protection of health
and the environment through
pollution prevention; promoting
the use of safer chemicals and
processes; management of high
priority chemicals; and providing
clear, useful information to the
public." The programs created by
EPA, Dr. Goldman feels, should
seek not only to reduce risks to
workers and the public, but also
serve to prevent such risks wher-
ever possible. The key to achiev-
ing the goals, Dr. Goldman
points out,  lies in  adhering to
three basic principles: good
science, good management, and
good communication.

"Good science is the underpin-
ning of all successful work by

          Goldman continued on next page
Dr. Goldman identified
OPPTS's primary goals
as "the protection of
health and the
environment through
pollution prevention;
promoting the use of
safer chemicals and
processes;  management
of high priority
chemicals;  and providing
clear, useful information
to the public."
                                   VOL 157 NO. 1 SPRING 1994

Goldman from previous page
EPA," stresses Dr. Goldman. "It
has led us to some remarkable
advances here in the United
States, and it is a principle which
needs to be extended into the
international arena, where issues
of pollution prevention, sustain-
able development, chemical
management, pesticide use, and
trade have become paramount."
Concerning the principle of good
management, Dr. Goldman has
expressed her favorable impres-
sions of the capabilities of EPA
managers at all levels. "Their
expertise in a number of areas —
physical science, policy, manage-
ment science, and the law —
increases my expectations for  this
division and the entire Agency."

The third principle, good  commu-
nication reinforces and magnifies
the effects of the other two, says
Dr. Goldman: "We communicate
with so many very different
groups — congressional members
and committees, other federal
agencies, state and local govern-
ments, chemical producers and
users, the food industry, farmers,
labor, public interest groups,
academic researchers, the public
health and medical communities,
and most importantly, the general
public, We know all about the
serious friction between the
environmental groups and various
regulated industries. I believe  we
can find some common ground
among these various groups and I
will do all in my power to find it
where possible."
In a number of specific areas of
concern to OPPTS, Dr. Goldman
has already laid out a broad agenda
for review and action. Some of the
most important of these areas are
briefly described below.

Pollution Prevention
and Toxics
OPPTS is now working with other
federal agencies to ensure their
proper and effective compliance
with the Pollution Prevention Act
and the Emergency Planning and
Community Right to Know Act
(EPCRA). This effort, begun last
August is now being carried
forward as quickly as possible.
The expansion of the TRI list was
announced last May by Adminis-
trator Browner. Dr. Goldman is
aggressively supporting the
addition of 313 chemicals to the
TRI this year.  Dr. Goldman also is
urging the inclusion of additional
categories of facilities required to
report under section 313 of the
Community Right-to-Know Law.

There are many programs in
place in which specific industries
have achieved voluntary reduc-
tions in targeted chemicals and
have developed environmentally
friendly technologies and pro-
cesses. Many of these technolo-
gies have been promoted
through EPA's Design for the
Environment  program.

Lead poisoning prevention will
receive  the very highest priority
under Dr. Goldman's leadership.
She and her staff are working on
a set of health standards that will
establish training and certification
guidelines to enable communities
to remove lead from the environ-
ment of children.
Another high priority is the reau-
thorization of TSCA. This will be
part of an overall strengthening of
the chemical testing and existing
chemicals programs.

Since last June, EPA has been
working on ways to achieve an
announced commitment to
reducing the use of pesticides and
promoting sustainable agriculture.
To date, that effort has involved:
strengthening existing legislative
authorities; upgrading the science
related to pesticides and food
safety,  especially as it relates to
children; and preventing prob-
lems at the source through pesti-
cide use reduction.
One  of the most controversial
sides of the  pesticide use reduc-
tion debate has been the
Delaney clause of the Federal
Food, Drug  and Cosmetic Act
(FFDCA) governing the carcino-
genic residues of pesticides in
processed foods and animal
feeds.  Under Delaney, if the
pesticide concentrates from the
raw agricultural commodity to
the processed food, then no
residue levels can be tolerated.
In the  past, EPA interpreted "no
residue" to mean a minimal risk
level. Under a court decision
rendered last January, "no
residue" is deemed to mean
"zero residue." Dr. Goldman has

called this new interpretation
"unreasonable public health
A more sensible approach, says
Dr. Goldman, is to "limit all
exposures to below levels that
cause a reasonable certainty of no
harm, or a negligible risk standard
for carcinogens."However, she
and the Administration are pro-
posing that the law address
concerns about setting tolerances
that are safe for children.  She also
supports stronger enforcement
capabilities for the Food and Drug
Administration (FDA), "I well
remember the situation in Califor-
nia in 1985 when we had a
problem with hundreds of people
ill from eating pesticide contami-
nated watermelons. Every water-
melon in the state had to  be
destroyed, because there  was no
way for the FDA to find the
source. Everyone  was hurt. The
food industry is well served by
the ability to pinpoint and deal
with these problems."
Another key area requiring
urgent attention is the need to
reform the Federal Insecticide,
Fungicide and Rodenticide Act
(FIFRA). Fundamental changes in
this program are urgently needed
and will be strongly supported
by Dr. Goldman.
One of the ways  in which the
program  can be improved,
believes Dr. Goldman, is  to
"sunset" the registrations  every
15'years. This will enable the
EPA to evaluate ail pesticides in
the light of changing technologi-
cal methods and new scientific
insights, Another change she is
proposing is a streamlining of the
process of restricting the use of
problem pesticides, providing a
more rapid response to public
health crises or problems.
Stronger enforcement procedures,
including record-keeping require-
ments for all farm pesticide use,
would also improve EPA's authori-
ties. Additional reregistration fees
are needed to enable the federal
agencies to provide needed
research, testing, and enforcement
These proposed changes  can
benefit all parties involved. The
public can enjoy the additional
health safeguards such efforts will
bring about; the industry can
receive faster service and better
rewards for genuine product
improvement; and the agencies
can obtain the resources needed
to make improvements in all
phases of its programs.

NAS  Children's Study
Follow-Up Initiative
One of the  most important pesti-
cide issues of the 90s is the
regulation of food-use pesticides
in the diet of children. The report
by the National Academy of
Sciences (NAS) recommends
changes in all three basic ele-
ments of the traditional approach
to evaluating food safety: toxicity
testing, exposure analysis and risk
assessment. The report argues for
a re-evaluation of our tolerance
setting procedures because
children and adults have mark-
edly different susceptibilities to
many toxic agents, based on their
biological differences.

NAS has recommended modifying
current reproductive, develop-
ment toxicity, and carcinogenicity
tests, as well as the addition of
studies to test for pesticide neuro-
toxicity, immunotoxicity and
hormonal effects. The Academy
also recommended that federal
authorities (1) gather better food
consumption data on specific age
groups; (2) consider all routes of
exposure in assessing risk; (3)
assess the effects of multiple
exposures to pesticides that act
via  similar pathways; and, (4)
where the data are incomplete,
make use of an additional uncer-
tainty factor in deriving accept-
able exposures.

These and other great challenges
lie ahead for the Office of Preven-
tion, Pesticides and Toxic Sub-
stances. Under the leadership of
Dr.  Lynn  Goldman, the staff is
prepared to make the 1990s a
decade of success by employing
better science, better manage-
ment, and better communication.
     VOL 15/NO. 1 SPRING 1994

TSCA §21 Petitions

TSCA from page 1
proceeding. If EPA denies the
petition, the Agency must publish
its reasons in the Federal Register.

New River Petitions
EPA received the first petition
from the Imperial County, Califor-
nia, Board of Supervisors on
December 16, 1993. The peti-
tioner requested that EPA take the
following actions under TSCA:
require monitoring of the New
River to determine  the presence
and level of contaminants under
Section 4 of TSCA;  require health
and environmental effects testing
of detected chemicals under
Section 4 of TSCA;  and take
appropriate action under TSCA or
other appropriate federal laws to
protect human health and the
environment, based on the results
of the testing. The petitioner
requested this action because the
Board believes there are insuffi-
cient monitoring data on  the
chemicals in the River as  well as
insufficient health and environ-
mental effects data.
On Wednesday, March 16, 1994,
Assistant Administrator Lynn
Goldman signed a Federal Regis-
ter Notice responding to the
petition. In the response, EPA
acknowledges that the New River
appears to have serious pollution
problems that have resulted from
pollution coming across the
border from Mexico and from
within Imperial County, Califor-
nia. EPA believes that additional
monitoring of the New River is
necessary to adequately character-
ize the chemical contamination in
the River, and that obtaining such
information is an important step
in addressing New River pollu-
tion. To expedite EPA's review of
the New River situation, EPA will
fund work with the California
Regional Water Quality Control
Board (CRWQCB) to develop the
monitoring data that, along with
other currently available informa-
tion, will allow EPA to determine
with a reasonable level of confi-
dence the identities and amounts
of chemical pollutants in the New
River and whether additional
testing is necessary.

In light of the decision to fund
the CRWQCB monitoring, EPA
has determined that  initiating a
rulemaking proceeding to require
monitoring of the River is unnec-
essary. The Agency will obtain
the data requested by the peti-
tion by more expeditious means.
Promulgating a test rule could
require several years due to the
notice-and-comment procedures
required for agency rulemaking
and the complexity of the New
River situation.
With regard to the petitioner's
request to impose testing to
evaluate the ecological and health
risks of the river pollutants, the
Agency has decided that it is not
currently in a position to con-
clude that the requisite Section 4
criteria have been met. This is
true even for the pollutants
identified in the petition or in
existing monitoring data.  EPA
believes it will be better able to
evaluate whether it is necessary
and appropriate to promulgate a
Section 4 test rule for ecological
and health effects testing after the
Agency has received and evalu-
ated up-to-date monitoring infor-
mation on the identities, levels
and environmental partitioning of
pollutants in the  river.

EPA is also continuing and/or
taking a number of additional
initiatives which  are described in
detail in the Federal Register
Notice. These activities are aimed
at addressing the pollution prob-
lems in the New River that appear
to result from both international
pollution coming from Mexico
and pollution contributions from
Imperial County.

On February 23,  1994, EPA re-
ceived a second  petition on the
New River from members of the
environmental justice community:
Environmental Health Coalition
(EHC), the Comite Ciudadano Pro
Restauracion del Canon del Padre
y Servicios Comunitarios (Comite
Ciudadano), and the Southwest
Network for Environmental and
Economic Justice (SNEEJ). This
petition supports the petition
submitted by Imperial County and
requests additional actions on the
part of EPA. EPA is evaluating the
petitioners' request, and is also
gathering and reviewing addi-
tional available materials, to
determine what,  if any, action is
appropriate in response to the
petition. In addition to either
granting or denying the petition,
              TSCA continued on next page

TSCA §21 Petitions

TSCA from previous page
EPA may decide  to take additional
actions under TSCA or other
federal statutes to address the
concerns raised by the petitioners.
EPA's deadline for responding to
the new petition is May 24,  1994.
On March 21, 1994, EPA pub-
lished a Federal Register Notice
requesting comments from inter-
ested parties on this second
petition. Persons commenting are
encouraged to provide EPA with
information regarding the nature
of possible contamination of the
New River, including available
monitoring data or other informa-
tion which might assist EPA in
characterizing possible pesticide
or industrial chemical pollution.
Commenters are also encouraged
to provide their views regarding
the petitioners' description of the
problem, the remedies sought by
the petitioners, and the legal
arguments put forth by the peti-
tioners. In addition, persons
commenting are encouraged to
provide any information they may
have on the import, export, or
release of toxic chemicals into
communities in either Southern
California or Baja California.

UAW Petition
EPA also received a Section 21
petition on December 22, 1993
from the United Automobile,
Aerospace, and Agricultural
Implement Workers of America
(UAW). The UAW petition asked
EPA to issue rules under Section 4
of TSCA to develop information to
aid in the  determination of
whether machining fluids pose an
unreasonable risk to public health
or the environment. The UAW
also petitioned the Occupational
Safety and Health Administration
(OSHA) to lower the current
exposure limit for oil mist. The
petition to EPA requested that EPA
work with OSHA and the National
Institute for Occupational Safety
and Health (NIOSH) to determine
the need for testing specific
ingredients of machining fluids.

Machining fluids are used to cool
and lubricate metals during
cutting and stamping operations.
The UAW  requested the testing
because it believes that although
the available epidemiology data
are sufficient to establish the
hazards of machining fluids as
mixtures, more and better toxicol-
ogy data are needed to character-
ize  the health and environmental
risks resulting from exposure to
particular  components or partial
mixtures of machining fluids.

The UAW  petition identified
categories of machining fluids
such as straight oils, soluble and
synthetic fluids, and drawing
compounds for stamping opera-
tions. The petition included a
broad request for  tests addressing
mutagenicity, respiratory irritancy,
and sensitization bioassays for
selected classes of components,
combinations, and in-use fluids. It
also mentioned carcinogenisis
bioassays  for selected classes of
components, and  chemical analy-
ses of bulk fluids and aerosols for
nitrosamines, bacterial degrada-
tion products, and polyaromatic
hydrocarbons. The petition also
mentioned the need for testing
(monitoring) the release of ma-
chining fluid components into the
workplace air.

The EPA response to the petition
was published in the Federal
Register on April 19, 1994. EPA
believes that additional testing of
machining fluids may be neces-
sary, but that it is not in a position
at this time to conclude that the
requisite Section 4 criteria have
been met  for the hundreds of
chemicals and mixtures to which
the petition can be applied. EPA
will work  with OSHA and NIOSH
in a specially convened Inter-
agency Workgroup to identify
specific components of machining
fluids, and to determine which
substances have  been adequately
tested in the past, or are currently
undergoing testing. The
workgroup will recommend
testing candidates to the OSHA/
NIOSH/EPA (ONE) Committee for
additional discussion. The ONE
committee will then refer data
needs to EPA for development of
test rules.  EPA will select those
chemicals and mixtures that can
support Section 4 findings for a
test rule.

EPA believes that this coordina-
tion will enable  it to achieve the
results sought by the UAW in a
reasoned  and expeditious way.
EPA anticipates that a year will
be needed to complete this
screening process.
      VOL 15 / NO. 1 SPRING 1994

1992 TRI Releases

TRI from page 2
Releases to Water: Reported
surface water discharges in-
creased 12.2%, from 243 million
pounds in 1991 to 273 million
pounds in 1992. This increase
was due to increased run-off
releases of phosphoric acid from
four fertilizer manufacturing
facilities in Louisiana and Texas.
Excluding releases from these
four facilities, all other surface
water discharges declined about
11.5% since  1991.
Releases to Land: Reported
releases to land totalled 338
million pounds in 1992, a de-
crease of 18.6% since 1991.
Underground Injection: About
726 million pounds  of toxic
chemicals in waste were injected
underground in 1992. This
represents an increase of 2.2%
since  1991.
Off-site Transfers: Transfers off-
site for recycling in  1992 totalled
2.84 billion pounds, an increase
of 25% since 1991. Transfers  for
recycling represented 65% of all
off-site transfers. Transfers for
energy recovery and treatment
also increased in 1992. Transfers
for disposal constituted less than
6% of all off-site transfers, or
about 259 million pounds.

Waste Management
In the second year of waste
management reporting under the
provisions of the Pollution
Prevention Act, facilities re-
ported generating 37.33 billion
pounds of toxic chemicals in
waste in 1992. This includes
amounts recycled, burned for
energy recovery, treated, and
released or disposed, both on-
site and off-site.
An additional 34 million pounds
of toxic chemicals in waste were
generated as a result of non-
routine incidents, such as acci-
dents and remedial activities.

More than 50% of the quantity of
toxic chemicals generated in
waste was recycled by facilities,
either on-site or  off-site. Only
about 9% was released to the
environment on-site or disposed

Projected data provided by
facilities indicates that the re-
ported total quantity of waste
generated by facilities may
continue to rise slightly in 1993
and  1994.

Thirty-six percent of all facilities
reported implementing at least
one source reduction activity to
reduce the quantity of toxic
chemicals in waste.

For  More Information
1992 Documents: The 1992
Toxics Release Inventory: Public
Data Release (.EPA 745-R-94-001)
summarizes the national TRI
data. The 1992 Toxics Release
Inventory: Public Data Release:
State Fact Sheets (EPA 745-F-94-
001) provides state-specific TRI
data and a summary of State TRI
programs. To obtain these docu-
ments, contact the EPCRA
Hotline at (800) 535-0202, or
(703) 412-9877.
Database Access: The complete
TRI database is available to the
public through the National
Library of Medicine's TOXNET
system. For access information,
contact the library's TRI repre-
sentative at (301)  496-6531. The
TRI database, along with other
environmental databases, is also
available through the Right-to-
Know Network. For access
information, contact the Unison
Institute at (202) 797-7200.
Additional Information: For
information about other TRI
products and services, contact
the TRI User Support Service at
(202) 260-1531, or the EPCRA
Hotline at the telephone numbers
listed above.

   Existing Chemicals
Existing Chemicals Program
Establishes Priorities for FY94
The Existing Chemicals Program
has established a list of high
priority projects for Fiscal Year
1994. While budget constraints
have pared down the number of
projects as compared to last year,
OPPT fully intends to achieve the
goals established for these projects.
  The following projects are  key
priorities of the Existing Chemi-
cals Program in FY94:
• OPPT will complete the Multi-
  Chemical Developmental/
  Reproductive Toxicity Endpoint
  Test Rule. The data that will be
  generated by this rulemaking
  activity and subsequent testing
  are expected to enable EPA to
  assess reproductive and devel-
  opmental health risks due to
  exposure to these chemicals.
  Through the development  and
  dissemination of this informa-
  tion, OPPT will be able to
  promote public understanding
  of the health risks posed by
  exposure to the chemicals
  covered by the final rule.
• OPPT plans to  negotiate
  Enforceable Testing Consent
  Agreements (EGAs) with
  industries on testing, possible
  product stewardship programs,
  and pollution prevention
  initiatives for a number of
  chemicals. These chemicals
  include, but are not limited
  to, the  diglycidyl ether of
bisphenol A, cyclohexane,
glycidyl methacrylate, alkyl
C12-14 glycidyl ether, several
silicone-based glycidyl ethers,
phenol, a number of bromi-
nated flame retardants, and
several aryl phosphates.
Through a Cooperative Re-
search and Development
Agreement (CRDA) with the
formaldehyde industry, OPPT
will be conducting a pilot study
on formaldehyde exposure
testing in new housing (see
box on page 10).

In coordination with the Orga-
nization for Economic Coopera-
tion and Development (OECD),
OPPT is using its Risk Manage-
ment (RM) process to review
approximately 70 chemicals
which have complete SIDS
(Screening Information Data
Set) dossiers. OPPT plans to
complete all the reviews by
September 1994. OPPT will
thus realize the full integration
of the 1994 OECD SIDS pro-
gram into the domestic testing
and RM assessment efforts. The
office will also begin to collect
information on 50 additional
chemicals and will develop or
review testing proposals for
chemicals with incomplete
SIDS dossiers under the OECD
effort. The OECD program will
eventually lead to an extensive
data base which may be used
While budget constraints
have pared down the
number of projects
as compared to last year,
OPPT fully intends to
achieve the goals
established for these
by member countries (and
others) to create possible risk
reduction opportunities for
these chemicals.
The Interagency Testing Com-
mittee (ITC) designated a need
for dermal absorption data for a
total of 58 chemicals in its 31st
and 32nd reports. These data
are needed by the Occupational
Safety and Health Administra-
tion (OSHA) for worker protec-
tion standards development.
Only one EGA was offered to
the agency; therefore, OPPT
plans to move forward with
Section 4 rulemaking while
possibly pursuing the EGA with
the 58th.

    Existing Chemicals continued on page 11
   VOL. 15/NO. 1 SPRING 1994

     Existing Chemicals
Formaldehyde Exposure Testing  in New Housing
The Office of Pollution Preven-
tion and Toxics (OPPT) has
begun to implement a formalde-
hyde exposure testing project
that focuses on the indoor air of
newly constructed housing. The
effort is linked to OPPT's regula-
tory investigation of formalde-
hyde emissions from certain
pressed wood building materials,
which is being conducted under
TSCA. The initial testing work
will be supported and assisted
by the National Particleboard
Association (NPA); it will consist
of a pilot study designed to
evaluate the experimental
methodology  for use in a sys-
tematic testing effort to be
conducted subsequently in a
variety of housing types. The
overall testing effort should
provide data that OPPT can use
to determine if there is a need to
reduce permissible formalde-
hyde emissions from interior
pressed wood building materials,
such as particleboard flooring
and wall paneling, and from
related products, including
cabinets and furniture.
In December 1993, NPA Execu-
tive Vice  President William J.
McCredie wrote to OPPT Direc-
tor Mark  Greenwood informing
him of NPA's  intent to support
the pilot  study effort under an
EPA-NPA Cooperative Research
and Development Agreement.
Under that agreement, which is
expected to be finalized in May
1994, EPA will conduct the pilot
study. NPA will fund the experi-
mental effort in the amount of
$460,000, supply pressed wood
products that will be used in
the effort, and provide testing
services that will characterize
the formaldehyde emissions of
the products used in newly
constructed housing. The pilot
study is expected to last about
one year.

Formaldehyde is a gas that is
emitted by the urea-formalde-
hyde (UF) glue that is used in
manufacturing most pressed
wood products intended for
indoor use. Although formalde-
hyde is normally  present at low
concentrations in both indoor
and outdoor air, higher concen-
trations of the gas are sometimes
experienced in new conven-
tional and manufactured (mo-
bile) housing due to pressed
wood products emissions. A key
question concerns the levels that
are initially encountered by
occupants of new housing.
Exposure to levels above 0.1
parts per million can cause the
occupants of these homes to
experience irritation  of the eyes,
nose and throat or to have
difficulty breathing.
Indoor levels of formaldehyde in
new homes can be reduced by
home buyers insisting that
builders use low formaldehyde-
emitting building materials, by
limiting the amount of UF
pressed wood that is used in
construction, and by ensuring
that the house has adequate
ventilation. With time, formalde-
hyde levels in new homes
should decrease, but the speed
with which this  occurs is also in

Thus, the important exposure
questions for which OPPT's
testing initiative  seeks answers
1) What formaldehyde levels can
  residents of new, single-family
  homes typically expect to

2) How long do elevated levels

The pilot study  itself will not
provide definitive answers to
these questions. These ques-
tions can only be answered
through more extensive, system-
atic testing. The pilot study is,
however, expected to determine
how,  in the complex and
interactive indoor air environ-
ment, formaldehyde levels can
be measured reliably and
reproducibly, and how  these
levels correlate  with the amount
and emission'strengths  of the
UF pressed wood present.

                                       Existing Chemicals
FY94 Program
Existing Chemicals from page 9
• An RM1 review will be con-
  ducted this summer on a
  cluster of 30+ chemicals which
  have been identified as poten-
  tial persistent bioaccumulators.
• OPPT will develop a Section 4
  test rule on a group of 12
  chemicals for the Agency for
  Toxic Substances and Disease
  Registry to support Superfund
  site risk assessments in Fall 1994.
• A TSCA Section 4 rulemaking
  has been requested by the
  Offices of Air and Radiation
  (OAR) and Research and Devel-
  opment (ORD) to generate
  information needed for a
  residual risk assessment on over
  20 Hazardous Air Pollutants
  (HAPs). The testing is needed to
  support analyses required under
  the Clean Air Act Amendments.
  The proposed test rule should
  be out by Fall 1994.
• OPPT will estimate the relative
  risks and efficacy of four sets of
  general purpose cleaning
  products as a portion of the
  EPA/General Services Adminis-
  tration (GSA) Product Evalua-
  tion. GSA requested OPPT's
  assistance in January 1993 to
  develop criteria for cleaning
  product selection based on
  health and environmental
  considerations. An evaluation
  under the RM1 process is
  expected this summer.
I A relative risk assessment will
 be completed for the paint
 stripping use cluster in Fall
 1994. This risk assessment will
 be distributed to industry for
 comment. Also, the paint
 stripping industry has agreed to
 do glove testing and improved
 consumer information pro-
 grams this winter. EPA ap-
 plauds the efforts of the
 N-methylpyrrolidone (NMP)
 Producers Group for taking a
 leadership role on this project.

 Given the large numbers of
 individuals exposed, OPPT will
 be developing options for
 reduction of risk to consumers
 and workers who use spray
 paints indoors. A workgroup
 will also conduct an analysis of
 substitutes. The substitutes
 analysis and risk assessment
 will be available in Fall 1994.
 OPPT plans to publish a final
 Section 6 rule this Spring
 addressing issues associated
 with the use of acrylamide and
 N-methylacrylamide in grout-
 ing. These materials pose
 health risks to workers using
 grouts. The grouts are typically
 used to seal sewer lines and
 manhole covers.

 The ethylene glycol ethers
 post-RMl process was com-
 pleted in February 1994. The
 results of the workgroup's data
 assessment and an OSHA
 proposed rulemaking prompted
 the decision  to reach closure
 on the case.  OPPT's concern
 stems from TSCA §8(e) reports
   from the IBM Corporation and
   the Semiconductor Industry
   Association indicating a pos-
   sible linkage between expo-
   sures to ethylene glycol ethers
   and increased spontaneous
   abortions in female workers.
   An information product is
   being developed which will
   notify interested parties of the
   additional data which contrib-
   utes to the weight of evidence
   regarding the hazards of ethyl-
   ene glycol ethers.

•  OPPT is working towards a
   voluntary phase out of benzi-
   dine congener-based dyes
   through ongoing negotiations.
   The phase out is intended to
   control potential risks of cancer
   to individuals who work with
   and manufacture these dyes. If
   negotiations fail to achieve a
   voluntary phase out, EPA will
   explore regulatory options.
   OPPT is planning to propose  a
   Significant New Use Rule
   (SNUR) this winter to control
   the reintroduction of benzidine-
   based dyes into commerce.

•  OPPT closed out the RM2
   review for EDC (1,2 Dichloro-
   ethane) in  Fall 1993. The
   objective of this analysis was to
   evaluate the pattern of EDC
   releases and their associated
   risks and to identify facilities
   where pollution prevention
   activities are recommended.
   Four facilities were identified
   for Regional follow-up, based
   on the OPPT analyses.  In fact,
   EPA's Region 5 office used the
      Existing Chemicals continued on page 13
                                       VOL. 15/NO. 1  SPRING 1994

Existing Chemicals
ATSDR Chemicals Added to  MIL
EPA is adding 12 chemicals to the
Master Testing List in response to a
request for testing by the Agency
for Toxic Substances and Disease
Registry (ATSDR). The chemicals
are: benzene, beryllium, chloro-
ethane, chromium, cyanide, di (2-
ethylhexyl) phthalate, mercury,
methylene chloride, tetrachloro-
ethylene, toluene,  trichloroethyl-
ene, and vinyl chloride.

ATSDR is required to identify the
hazardous substances most
commonly found at Superfund
sites, prepare toxicological pro-
files, and identify priority data
needs for those substances.
ATSDR is also required to  initiate
a research program to meet the
priority data needs it identifies.

In October 1992, ATSDR requested
EPA to use its authorities under
TSCA and FIFRA to fill some of the
data needs it identified on  37
chemicals. In its response to
ATSDR, EPA agreed to develop a
test rule under section 4 of TSCA
to obtain data on 12 of the chemi-
cals, but noted that a TSCA test
rule would not be an appropriate
mechanism for obtaining data on
the other 25 chemicals. Before
initiating rulemaking, EPA is
inviting manufacturers of the 12
chemicals listed in the following
table to submit testing plans and
enter into consent agreements for
testing. EPA intends to issue a test
aile in late 1994 for any of the 12
substances which are not covered
by a consent order or a voluntary
testing agreement.
Vinyl chloride
Methylene chloride
Testing to be Proposed
Chronic oral
Reproductive oral
Acute oral
Reproductive inhalation
Developmental inhalation
Subchronic oral
Subchronic oral
Neurotoxicity oral
Acute oral
Reproductive oral
Reproductive inhalation
Neurotoxicity inhalation
Immunotoxicity inhalation
Developmental inhalation
Acute inhalation
Subchronic inhalation
Developmental inhalation
Fate in soil
Acute inhalation
Subchronic inhalation with reproductive
and pulmonary pathology
Developmental inhalation
Immuotoxicity inhalation
Fate in air
Comparative Pharmacokinetics
Immunotoxicity oral
Subchronic oral
Immunotoxicity oral
Developmental oral
Neurotoxicity oral
Comparative Pharmacokinetics
Immunotoxicity oral
                                      CHEMICALS IN PROGRESS

      Existing Chemicals
FY94 Program

Existing Chemicals from page 11
   RM2 analysis as part of an
   enforcement case against one
   of these facilities in Indiana.
   EDC was chosen for review
   because it is a high volume,
   high release, TRI chemical that
   is also a carcinogen.
•  Hydrazine was also identified
   during TRI screening as a high
   volume, high release chemical
   which is a potent carcinogen.
   The RM2 workgroup completed
   its evaluation of the chemical in
   Fall 1993. OPPT will work with
   the Regions, OSHA and indus-
   try to address issues associated
   with hydrazine, with an empha-
   sis on pollution prevention,
   product stewardship, and
   worker protection.
•  A Voluntary Agreement has
   been negotiated with the pulp
   and paper industry which
   specifies dioxin/furan limita-
   tions, loading rates, site man-
   agement practices, testing
   standards, and reporting and
   record-keeping requirements for
   Kraft and sulfite mills which are
   land applying dioxin-contami-
   nated sludge as a soil amend-
   ment. The voluntary agreement
   will limit human and environ-
   mental exposure to dioxins/
   furans. The Memorandum of
   Understanding is expected to be
   signed this winter.
• An integrative testing policy is
   being developed which will
   present considerations and
   criteria for requiring different
   levels of testing. The policy will
   develop an array of testing
   menus ranging from screening
   (i.e., SIDS) to comprehensive
   characterization. The policy will
   also outline the factors to be
   considered in selecting the
   testing menu needed for a
   given chemical. This policy
   would allow the industry to
   better anticipate OPPT/EPA's
   testing needs and work toward
   increasing the amount of
   voluntary or negotiated testing.

• OPPT will be working to
   identify two Source Reduction
   Review Project (SRRP) rules
   which lend themselves to
   pollution prevention and could
   benefit from RM1/RM2 analysis.
   The goal of SRRP is to foster the
   use of source reduction by
   industry as a primary means of
   achieving compliance with the
   rule in question. Work has
   begun on  a solvents SRRP
   project which should be com-
   pleted by the end of the year.

In upcoming Bulletin editions,
OPPT will provide updates on
these Existing Chemicals priority
projects. In addition to letting
Bulletin readers know where we
stand on key projects, the updates
will enable readers to know how
and when they can play a role.
Stay tuned.
                                       VOL. 157 NO. 1 SPRING 1994

                        Existing Chemicals
RM2 and Post-RM2 Activity Chart

Chemical Name
is it in RM?
In 1991, EPA
proposed a rule to
(1) immediately ban
j acrylamide from all


Aerosol Spray

Benzidine Dyes

grouting uses; (2)
immediately ban
NMA from all
grouting uses except
sewer applications;
and (3) ban the
sewer applications
use in three years.
High production
volume chemical
with large environ-
mental releases as
reported to the
Toxics Release
Inventory (TRI)

To investigate
pollution prevention

Cancer concerns for
workers exposed to
acrylamide and NMA
during grouting

Acrylonitrile is
classified by EPA as
a B1 "probable
human" carcinogen

Some chemicals
found in aerosol
spray paint are
r*r\nr*arn frtr

Benzidine has been
classified by EPA as
a group A "known
human" carcinogen.
Benzidine congeners
have not yet been
classified by EPA;
however, due to
animal data and
similarities to known
human carcinogens,
they fit the definition
for group B2
"probable human"
consumers and
workers who use

aerosol spray paints
in indoor air
Cancer concerns for
workers exposed to
these chemicals

Stage in
responses to
comments on
proposed rule and
preparing final rule

No further OPPT
action is warranted
at this time, although
EPA will provide
technical support to
other EPA offices
evaluating the risks
posed by acrylonitrile

Assess risk for
solvents, heavy
pigments and their
substitutes, identify
containing methyl-
ene chlorid@

Negotiations with
industry, labor
unions, and

Next Steps
Issue final rule

OPPT has sent
letters to acryloni-
trile manufacturers
encouraging them to
continue their
pollution prevention
efforts — Industry
appears to have
taken OPPT
concerns seriously
Dialogues in Spring
and Summer 1994

Complete rule
requiring notifica-
tion of EPA before
dyes may be
produced, imported
or used, and reach a
Memorandum of
(MOD) in principle
for non-metalized
dyes in mid 1994

Anticipate issuing a
final rule in mid

Project was closed
in FalM 993

Complete RM2 by
Fall 1994

Three stage phase-
out of benzidine-
congener dyes that
present significant


Existing Chemicals

Chemical Name
Paraffins (CPs)


Consumer and
Small Shop Paint
Stripping Use

Cultural Uses of


Formaldehyde - New
Homes Testing

is it in RM?
Designated for
testing by the
Interagency Testing
Committee for both
human health and
High production
volume chemical
with significant
releases to air and
water as reported to
the Toxics Release
Inventory (TRI)

CPSC raised
questions regarding
the safety of
substitutes for
methylene chloride
in consumer paint

Referral from State
of California that
certain ethnic
groups were using
mercury in some of
their religious
High volume feed-
stock chemical that
is classified as an
EPA B2 "Probable
human" carcinogen
TSCA Section 4(f)
for cancer concerns

Short-chain CPs and
alpha olefins used in
metal-working fluids
are hazardous to
aquatic life - All CP
chain lengths are of con-
cern to human health
Chloroethane is
classified by EPA
as a group B2
"probable human"
carcinogen, based
on a 1989 National
Toxicology Program

reproductive and
effects, central
nervous system
effects and flamma-
biiity- Consumers
and small shops are
not subject to OSHA

Neurotoxicity to
particularly infants
and small children,
who are exposed to
mercury in these
Cancer risk to
individuals living
near 4 specific

Formaldehyde emis-
sions from pressed
wood building
materials can pose
risks of some acute
irritation, and a low
ricl/ Af ranror
Stage in
Project closed. CP/
Os were proposed
for listing on the
Toxics Release
Inventory (TRI)

OPPT negotiated a
labeling program
with Chloroethane
manufacturers to
warn workers who
install chloroethane-
containing foam
boards of the haz-
ards and to provide
suggestions on how
to reduce exposure
Project scoping to
identify specific
chemicals to be
Work with industry
on product
stewardship and

Developing outreach
and education
campaign targeting
affected communities

Project Closed. EPA
Regions follow-up,
as needed with

voluntary testing
program with

Next Steps


Preparing assess-
ment document on
chemicals currently,
or potentially,
appearing in
consumer oriented
paint strippers
Voluntary industry
action on glove
permeability testing
and outreach
Develop radio
program on risks,
and distribute
outreach materials
to states


Negotiate final
agreement with
industry on funding
and conduct of tests,
develop quality
assurance plan

Project completed,
with limited follow-
up,. in September

Project completed

RM2 draft assess-
ment to be released
Fall 1994
OPPT decision on
further action, either
regulatory or
through voluntary
means, expected in
late Fall 1994

completion of
project by May 1994

Project closed in Fall
1993, with enforce-
ment activity in
Region 5

Expecting final
agreement with
industry in April
1994, final quality
assurance plan in
May 1994

VOL. 15/NO. 1 SPRING 1994

Existing Chemicals
Chemical Name
Lead Paints
Land-Applied Sludge
is it in RM?
High toxicity
chemical showing
volume on the
Toxics Release
Inventory (TRI)
Referral from the
Consumer Product
Safety Commission
Classified by EPA as
a group B2 "prob-
able human" carcin-
ogen, with possible
high exposures to
Request from the
United Rubber
Workers Union to
evaluate the
potential risks posed
by these chemicals
In 1991 EPA
proposed a rule to
govern the land
application of pulp
and paper mill
sludge contaminated
with dioxins and
High toxicity,
Classified by EPA as
a B2 "probable
human" carcinogen
toxicity to workers
and to users of
consumer "do-it-
yourself" paint
stripping products
Cancer and liver
toxicity concerns for
Cancer concerns for
workers in the
rubber manufacture
and leather tanning
Concerns for
exposures and
general population
Dioxins and furans
are very toxic to
humans and wildlife
Stage in
Project completed
Glove testing
agreements have
been reached
Informal referral to
the Occupational
Safety and Health
Administration has
occurred. 2-NP may
be added to OPPT's
Master Testing List
dialogue held in July
Currently incorpo-
rating new informa-
tion into review
Project Closed
Final negotiations
have been completed
for a voluntary
agreement with the
pulp and paper
industry, which will
set up guidelines for
land application,
dioxin/furan stand-
ards, and manage-
ment practices, and
provide data to
improve our under-
standing of the
ecological risks of
sludge land application
Next Steps
Pass information to
OSHA, send letter to
industry regarding
voluntary testing and
product stewardship,
send letter to EPA's
Office of Water about
permitting issues
None as a single
chemical. All further
work will be done
under the paint
strippers cluster
Further review, and
discussion of risk
reduction methods
with stakeholders
Information on
substitutes will be
collected and
Signing of voluntary
agreement with
industry trade
organization in early
Project closed in
December 1993
Work on this project
will be incorporated
into OPPT's activities
on a consumer/small
shop paint stripping
use cluster analysis
Project was closed
in September 1993
RM2 Dossier
expected in mid
Project closed, with
limited follow-up, in
February 1994
Signing of voluntary
agreement with
individual pulp and
paper mills in
Spring 1994

     New Chemicals
OPPT Establishes New Chemicals
Pollution Prevention Recognition  Project
On January 26, 1994, OPPT
Deputy Director Joseph Carra
signed a memo to OPPT Division
Directors establishing a "New
Chemicals Pollution Prevention
Recognition Project" to encourage
pollution prevention via the
Premanufacture Notice (PMN)
review program under section 5 of
TSCA. The project will result in
letters from OPPT Director Mark
Greenwood recognizing selected
PMNs submitted for new chemical
substances that may constitute
safer substitutes or be developed
via pollution prevention processes.

During the course of PMN review,
EPA/OPPT technical reviewers
will identify PMN cases that match
a flexible list of criteria. Not all
criteria must be present in order
for a PMN to receive a recognition
letter, and other criteria not listed
may also be appropriate. Carra's
memo identified the following
• Test data on the PMN sub-
  stance itself (toxicity and fate),
• No reports of adverse effects
  (e.g., section 8(e)).
• Safer substitute (i.e., the new
  chemical appears to be less
  toxic or more efficacious than
  existing chemicals performing
  the same functions).
• Less toxic or fewer toxic associ-
  ated chemicals (e.g., feed-
  stocks, by-products, impurities).

• Safer pollution prevention,
  source reduction, or recycling
  processes that reduce expo-
• Successful implementation of a
  recommendation resulting from
  either of EPA's "Alternate
  Synthetic Pathway" or TSCA
  section 5(e) "Pollution Preven-
  tion Plan" projects.

• The use of the chemical sub-
  stance should be environmen-
  tally beneficial (e.g., waste
  cleanup or renewable energy)
  rather than harmful (e.g., single-
  use disposable packaging).
• Conservation  of energy and
  water during manufacturing,
  processing or use.

• No TSCA enforcement actions
  filed against the PMN submitter
  within the past year.

Selection of PMNs to receive a
recognition letter will be made at
meetings of the  OPPT Division
Directors for presentation to the
Office Director for signature.

  For further information on this
project, contact Roy Seidenstein at
(202) 260-2252.
TRI  Chemical


On January 6, 1994, EPA
Administrator Carol Browner
held a press conference to
announce that she had signed
a rule proposing to add 313
chemicals to TRI. The pro-
posed list consists of chemicals
regulated under various envi-
ronmental statutes such as the
Clean Air Act. Over half of the
chemicals (170) are pesticides.
The addition  of chemicals is
one phase of the expansion of
the Toxics Release Inventory.
EPA also intends to expand the
types of industries covered by
the TRI. Currently only facili-
ties in the manufacturing sector
are required to submit reports.
The proposed rule was
published in the Federal
Register on January 12, 1994.
There was a  public meeting
on this proposal on March 2,
1994.  The public comment
period on the proposed rule
closed  on April  12,  1994.
Anyone who would like a
copy of the proposed rule or
a copy of the list of 313
chemicals should call the
EPCRA Hotline at 1-800-535-
0202. Additional information
can be obtained from Maria
Doa at 202-260-5992.
                                      VOL. 15/NO. 1 SPRING 1994

      Design for the Environment
Green  Chemistry:   Benign By Design
by Joe Breen

EPA's Green Chemistry Benign
By Design approach offers a new
intellectual challenge to organic
chemists. The challenge to the
synthetic chemist is to create new
products in an economically cost
effective and environmentally
friendly manner. The moment a
chemist puts pencil to paper to
design a synthetic sequence for a
product, he or she also is making
decisions about the use or gen-
eration of hazardous substances
that require treatment, recycling,
transportation, or disposal. The
goal of green chemistry and
technologies is to reduce or
eliminate the toxic substances
used or generated in the process,
as well as their associated costs.

Traditionally,  organic chemists
have been trained to identify
reaction pathways that maximize
yield as the fundamental evalua-
tion criteria for a reaction
scheme. This  evaluation scheme
tends to discount the potential
problems associated with hazard-
ous feedstocks, solvents, cata-
lysts, by-products, and impurities.
Given the rising costs of waste
treatment, waste disposal, com-
pliance with regulations, and
liability insurance, chemists and
chemical engineers increasingly
need to consider the environ-
mental impacts of a given syn-
thetic method on the overall
economic equation.
 EPA and the National Science
 Foundation (NSF) have joined
 forces to promote and foster
 green chemistry through the NSF
 university grants program. Some
 $2 million in chemical engineer-
 ing and a  comparable amount in
 chemistry will be awarded
 annually over the next several
 years. Research advances are
 needed in aqueous-based solvent
 systems, ambient-temperature
 reactions,  just-in-time in-situ
 generation of toxic intermediates,
 chiral catalysts, artificial enzymes,
 built-in  recyclability, and molecu-
 lar manufacturing.
 Advances  in environmentally
 benign chemistry will, in time,
 become an integral part of the
 education and training of future
 chemists, as they formulate the
 new synthetic methods of the
 21st century.
 In the second of three planned
 American Chemical Society (ACS)
 National Meeting Symposia on
 Pollution Prevention and Design
for the Environment, OPPT
 showcased progress made to-
 wards environmentally benign
 chemical synthesis and processing
 at the ACS meeting in Chicago in
 August 1993. The Chicago sympo-
 sium, Alternative Synthetic Design
for Pollution Prevention, high-
 lighted the primary role the
 synthetic chemist plays in design-
 ing environmentally benign
    The challenge to the
    synthetic chemist is
    to create new products
    in an economically
    cost effective and
    friendly manner.
chemical processes. The Chicago
symposium featured the accom-
plishments of researchers from
OPPT's highly successful Chemi-
cal Grants Program to university
chemists, as well as reports from
their industrial colleagues on
recent ventures in this new area.

OPPT's first ACS National Sympo-
sium in this series was published
as Pollution Prevention in Indus-
trial Processes: The Role of Pro-
cess Analytical Chemistry, ACS
Symposium Series No. 508,
October 1992. It focused on the
contributions of analytical chem-
ists as they adapt and adopt
microsensors, electrochemistry,
spectroscopy and chemometrics
to industrial process streams to
optimize productivity and mini-
mize or prevent pollution.
       Green Chemistry continued on page 21

      Design for the Environment
Green  Chemistry: Benign by Design
Reports from Research Labs
Biocatalysis and
benzene substitutes
Chemistry professor John W.
Frost, Purdue University, applies a
biotechnology approach in his
search for a new route to indus-
trial chemicals. Frost uses mi-
crobes to convert D-glucose into
industrially important compounds,
with the goal of replacing ben-
zene as a starting material.
Benzene, used in the manufacture
of a variety of chemicals, is a
carcinogen and must be derived
from nonrenewable fossil fuels.
Frost points out that about 12
billion pounds of benzene are
produced in  the U.S. each year.
He further notes  some 98% of all
organic chemicals are currently
manufactured from petroleum
feedstocks, which puts the U.S.
chemical industry at a competitive
D-glucose is  abundant and inex-
pensive in the U.S. because it can
be derived from numerous agri-
cultural products as well as waste
streams from processing food
products. Frost says using geneti-
cally engineered  microbes and D-
glucose as starting materials
provides not only a more benign
synthesis route but may also
improve the  long-term, global
competitiveness of U.S. industry.
Frost has developed technology
employing genetically engineered
microbes to catalyze the synthesis
of hydroquinone, benzoquinone,
catechol, and, most recently,
adipic acid that is used in the
production of nylon. About 1.75
billion pounds of adipic acid are
produced annually in the U.S.
In addition to requiring benzene
as a starting material, manufac-
ture of adipic acid also generates
nitrous oxide gas that contributes
to global warming and ozone

Genes essential to the conversion
of D-glucose into hydroquinone,
benzoquinone, catechol, and
adipic acid were isolated from
microbes and then expressed in
Escherichia coli that were geneti-
cally engineered to overexpress
certain enzymes. The strategy is
to make the organism direct the
largest possible percentage of
consumed D-glucose into the
common pathway of aromatic
amino acid biosynthesis, and then
siphon the flow of carbon away
from aromatic amino acids and
into the  synthesis of the desired
industrial chemicals.

Another alternative to the use of
benzene as a starting material was
described by Orville L. Chapman,
professor in the Department of
Chemistry and Biochemistry at the
University of California, Los
Angeles. He outlined research
opportunities relating to the UCLA
styrene process, which converts
equilibrium mixed xylenes to
styrenes in a single step. Existing
styrene processes use benzene
and ethylene as raw materials and
involve catalytic alkylation and
subsequent dehydrogenation,
Chapman says. The UCLA styrene
process could eliminate 13 billion
pounds per year of benzene from
the global economy, and xylenes
have a clear edge as a raw mate-
rial for styrene manufacture.

jn-situ generation of toxic
An industrial perspective on
efforts to eliminate by-products
and process waste was provided
by Leo E. Manzer, associate
director in DuPont's central
science and engineering labora-
tory in Wilmington, DE. He points
out that hazardous and toxic
materials such as HCN, HF, HCl,
C12, acrylonitrile,  formaldehyde,
ethylene oxide, sulfuric acid,  and
phosgene are essential building
blocks in the chemical industry
since they often contain function-
ality or reactivity required for
further chemical reactions. Future
business practices must avoid or
minimize the inventory and
transportation of these materials.

For example, methylisocyanate,
familiar as a result of the tragic
accident involving its release  at
Bhopal, India in 1984,  was pro-
duced by the phosgenation of

       Research Labs continued on next page
     VOL. 15/NO. 1  SPRING 1994

     Design for the Environment
Research Labs

from previous page
methylamine. Out of concern over
the use and storage of the toxic
material, DuPont developed a
proprietary catalytic oxidative
dehydrogenation reaction process
that makes methylisocyanate and
converts it in situ to an agro-
chemical product. In that way,  the
potential for exposure is greatly
reduced.  The trend toward in-situ
manufacture and derivatization is
clearly the way of the future for
hazardous chemicals.

Toxic solvent replacement
Another group reported on its
efforts to look for ways to replace
hazardous solvents in chemical
reactions with environmentally
friendly ones. James M. Tanko
and Joseph F. Blackert, Depart-
ment of Chemistry, Virginia
Polytechnic Institute & State
University, Blacksburg, are ex-
ploring supercritical fluids as a
medium in which to carry out
free-radical reactions, replacing
toxic solvents such as benzene
and environmentally damaging

Supercritical  fluids offer unique
opportunities as a medium for
probing solvent effects. Relatively
minor changes in temperature
and/or pressure can be used to
'dial up' solvent properties such
as viscosity and Hildebrand
solvent parameter without
changing the molecular
functionality of the solvent. Such
flexibility is not possible with
conventional liquid solvents.
The researchers report free-radical
brominations can be conducted in
high yield in supercritical carbon
dioxide solvent. Reaction of
toluene with bromine in super-
critical carbon dioxide yields
benzyl bromide as the major
reaction product.

Benign by design
synthesis software
In an effort to help chemists
identity theoretical reaction
pathways that are environmentally
safer, J. Dirk Nies, Chemical
Information Services, Rockville,
MD, with Paul Anastas and
Stephen C. DeVito, OPPT's Eco-
nomics, Exposure and Technol-
ogy Division, are evaluating
computer-based software tools for
synthesis design. Such computer
software has been under develop-
ment for the past 25 years. Its
purpose is to help chemists
identify new syntheses for target
molecules from the myriad poten-
tial routes and to suggest novel
chemical reactions that might be

Most  of these software tools are
retrosynthetic — that is, they
generate syntheses for target
molecules by working backwards
from  the target to candidate
starting materials. Other programs
are synthetic — they identify side
reactions,  by-products, and the
effects of varying conditions on
reaction outcomes. However,
none of them was built with the
explicit objective of identifying
environmentally benign chemical
synthesis routes.

Out of some 20 software pack-
ages examined, three programs
appear to have the greatest
potential to provide theoretical
alternative synthesis pathways in
support of EPA's pollution preven-
tion initiatives: CAMEO, which
operates synthetically, and Syngen
and LHASA, which both operate
retrosynthetically. The three
computer programs appear useful
for providing theoretical alterna-
tive synthetic pathways to target
molecules. The user, however,
will have to decide, from  consid-
erations of the health and envi-
ronmental hazards of the  starting
reagents, which pathways are
environmentally safer.

Applying retrosynthetic and
synthetic programs in sequence
permits optimal routes to be
identified, and their associated
condition, by-products, estimated
costs, and potential hazards to be
compared.  Future developments
in computer-assisted synthesis
design tools will include features
to make them function as true
expert systems in support of
pollution prevention and  benign
by design goals.

For a fuller version of these reports
or for further information  on
Green Chemistry,  call Dr. Joseph
Breen at the U.S. Environmental
Protection Agency, 202-260-1573,
or Dr. Paul Anastas, 202-260-2257.
                                       CHEMICALS IN PROGRESS

      Design for the Environment
Green Chemistry from page 18

OPPT's third ACS National Meet-
ing on pollution  prevention will
be held in Washington, DC,
August 21-25, 1994. The program,
DfE: The Environmental Para-
digm for the Twenty-first Century,
will afford an opportunity for
analytical and synthetic chemists,
chemical engineers, economists,
industrial and environmental
scientists, management, and
policy makers to report progress
and exchange ideas on imple-
mentation of pollution prevention
as an integral part of our national
environmental and economic

A sample of research lab activities
is presented on pages  19 and 20.
For a fuller version of the reports
from the research laboratories or
an agenda for the 3rd ACS Na-
tional Meeting, call the TSCA
Assistance Information Service at
For more information on Green
Chemistry, call Joe Breen at 202-
DfE  Printing Project Enters
Product Demonstration Phase
The Design for the Environment
(DfE) Printing Project has started
the product demonstration phase
for the lithography and screen
printing sectors of the industry.
In this phase, products used for
blanket washing and screen
reclamation, two processes
used in lithography and screen
printing, respectively, will be
demonstrated to assess their
These product demonstrations
will be conducted first at trade
association laboratories in order
to make certain that the products
meet basic performance stan-
dards. For lithographic blanket
washes, the laboratory testing
will be done at the Graphic Arts
Technical Foundation (GATF);
and for screen printing reclama-
tion chemicals and equipment,
the laboratory testing will be
conducted at the Screen Printing
Technical Foundation (SPTF).

Once the products have been pre-
tested at the laboratories, the
identities of the products that have
been shown to effectively clean
blankets and reclaim screens will
be concealed. The products will
then be sent to volunteer printers'
facilities throughout the United
States to begin the performance
demonstration. The volunteer
printers will use the products and
report how they function and how
well they were satisfied with the
products. This product demonstra-
tion format is the result of numer-
ous meetings between the printing
industry, trade associations, and
EPA to develop a demonstration
program that will provide standard-
ized performance information.

The results of the demonstrations
will be incorporated into the
Cleaner Technology Substitute
Assessments (CTSAs) that EPA is
preparing in cooperation with both
the lithographic and screen print-
ing industries. The CTSA will be a
tool for printers to use in evaluat-
ing possible alternative products
and processes in the areas of
blanket washing and screen
reclamation. The document will
incorporate the information from
the performance demonstration
with health and environmental risk
and cost information on each of
the alternatives.

It is intended that printers will use
the information in the CTSA as
the first step in evaluating alterna-
tives. Printers will be able to  see
the risk, cost, and performance
tradeoffs between the products
under consideration. For more
information, please contact
Stephanie Bergman, DfE Printing
Project leader, at (202) 260-1821.
     VOL. 15 / NO. 1  SPRING 1994

     Design for the Environment
EPA Technology Innovation
Strategy Emphasizes Partnerships
In January, EPA released for public
comment its draft Technology
Innovation Strategy. The Strategy
discusses the critical roles the
Agency must play to trigger
the steady stream of technological
innovation needed to achieve
our national environmental goals.
The public comment period
closed on April 15.
New and innovative technologies
offer the promise that the demand
for continuing economic growth
can be reconciled with the im-
perative of strong environmental
protection, This same concept is
central to EPA's Design for the
Environment (DfE) Program,
which will be an important
element of the Agency's technol-
ogy innovation program under
the Strategy.
The DfE Program in EPA's Office
of Pollution Prevention and
Toxics harnesses EPA's expertise
and leadership to catalyze infor-
mation exchange and research on
pollution prevention efforts. DfE
convenes broad-based industry-
government partnerships on a
voluntary basis that: (1) evaluate
the risks, performance, and costs
of alternative technologies, pro-
cesses, and chemicals, (2) change
business practices to prevent
pollution and improve productiv-
ity, and (3) help industries and
individual businesses undertake
environmental design efforts
through the application of specific
tools and methods.

EPA's Technology Innovation
Strategy establishes a blueprint for
the Agency's  efforts to stimulate
the development and widescale
use of innovative technology
solutions for  environmental
problems. EPA will emphasize
four  innovation enhancing roles:
(1) fostering environmental
technology through the frame-
work of environmental policies
and programs, (2) catalyzing the
environmental technology efforts
of others throughout the U.S.
economy, (3) providing funding
for the development and commer-
cialization  of some key technolo-
gies,  and (4)  accelerating diffusion
of innovative technologies at
home and  abroad.

The principle of partnering
underlying the Agency's Strategy
converges with the DfE concept.
A partnership approach is seen by
both as the key to success. Part-
nerships will build collaboration
across government agencies and
with the developers and users of
technologies in the private sector.

The Design for the Environment
Program is a centerpiece of
EPA's plans to implement the
Strategy and the President's
Environmental Technology
Initiative, an EPA-led federal
program that provides seed
money for partnerships in
innovation. EPA will support
several industry-specific DfE
projects in the first year,  includ-
ing dry cleaning, printing, metal
plating and coating, metal
degreasing, and printed circuit

For more information about the
Design for the Environment
Program, call Libby  Parker at 202-
260-1678. For more  information
about the EPA Technology Inno-
vation Strategy, call  David Berg at
                                     CHEMICALS IN PROGRESS

      Pollution Prevention Activities
 Proposed  Pulp and  Paper Rule Integrates
 Multi-Media, Source Reduction Measures
In November 1993, EPA pro-
posed the first rule under its
Source Reduction Review Project
(SRRP) which will dramatically
reduce and prevent water and air
discharges of dioxin and other
toxic pollutants by  U.S. pulp and
paper mills.

The proposed regulation repre-
sents an innovative, multi-media
initiative to improve public
health and the environment by
integrating regulations under the
Clean Water Act (CWA) and the
Clean Air Act (CAA), specifically
the effluent guideline and
Maximum Achievable Control
Technology (MACT) standard,
respectively. The rule is based
on installing state-of-the-art
pollution prevention technology
to further reduce risks.
The SRRP is determining how
source reduction techniques can
be integrated into regulatory
procedures for 24 proposed rules
set by the CAA, the CWA and the
Resource Conservation and
Recovery Act (RCRA).
Under the water standards, almost
all dioxin discharges to rivers and
other surface waters would be
eliminated,  and discharges of
other toxic pollutants would be
reduced significantly. In addition,
dioxin levels in sludge may be
reduced, which may enable
industry to avoid high compliance
costs by eliminating the need for
EPA to list the sludges as hazard-
ous material under RCRA. The air
standards would cut toxic emis-
sions by about 70 percent from
current levels. For example,
emissions of chloroform, a prob-
able human carcinogen, and
volatile organic compounds, the
main component in ground-level
ozone, or smog, could be reduced

For information on the proposed
water standard, contact  Debra
Nicoll at 202-260-5386. For infor-
mation on the air standard,  contact
Penny Lassiter at 919-541-5396.
33/50  Program Achieves '92 Reduction Goal One Year Early
Releases and transfers of 33/50
Program chemicals declined by
34% between 1988 and 1991,
surpassing the Program's 1992
interim 33% national reduction
goal a full year ahead of schedule,
according to 1991 TRI reporting
data (see figure on next page).

The figures  indicate that releases
and transfers of 33/50 Program
chemicals declined from 1.474
billion pounds in the Program's
1988 baseline year to 973  million
pounds in 1991, excluding catego-
ries of reporting in 1991 that were
not required for reporting in 1988.
The 501 million pound reduction
in reported emissions through
1991 exceeds by nearly 15 million
pounds the amount required to
achieve the Program's interim
reduction goal. The early achieve-
ment of the goal, together with an
analysis of facilities' projected on-
site releases and off-site transfers
to treatment and disposal of the
17 target chemicals through  1993
(reported for the first time in
1991), offers strong encourage-
ment that the 33/50 Program's
ultimate goal of a 50% reduction
by 1995 will be achieved.
Many companies and individual
TRI facilities have already
achieved some or all of their own
reduction targets. Through the
1991 TRI reporting cycle, more
than 200 companies that are
participating in the 33/50 Program
have reported reductions in their
emissions of the Program's 17
target chemicals equal to or
exceeding the targets provided to
EPA in their commitment letters.
Many states, a number of industry
associations, and numerous
individual companies include 33/
             33/50 continued on next page
                                     VOL 15 / NO. 1  SPRING 1994

                                       Pollution Prevention Activities
  TRI Releases and Transfers of
  33/50 Program Chemicals, 1988-1992
  NOTE: The amounts for recycling and energy recovery reported
  for 1991 and 1992 have not been included in these totals.
33/50 from previous page
SO Program chemicals within the
scope of their own reduction
programs. Twenty-six states had
established toxics use reduction
and pollution prevention pro-
grams prior to establishment of
the 33<'SO Program, contributing
to its design.  Others  have used
the 33;SO Program as a model.
EPA views the 33 SO Program  as
an umbrella under which the
federal government,  states, indus-
try, and communities work in
partnership to achieve common
goals. Any progress in reducing
emissions ot  33/SO Program
chemicals reflects the efforts ot all
these partners.
Anyone interested in obtaining
copies of the newly released
document. State Directory: .->.•>  5(7 <:-
 \'oluntan' Pollution Prevention
 Programs, /99.x or the Fourth
              Progress Report,
              should direct their
              calls to the 33SO
              Program Office at
              (202) 260-WOT.
              Letters should be
              directed  to:  Mail
              Code ""408,  Office
              of Pollution
              Prevention and
              Toxics, I'.S. EPA.
              401 M Street SW,
              Washington, DC
              20460. Written
              from companies
              are maintained in a
              publicly  available
              33 SO Program
              Record.  Copies of
company communications and
computer generated lists of  partici-
pating companies are available
upon request. Information about
the 33 SO Program can also  be
obtained from 33'SO Program
Coordinators in HPA's ten Regional
Fifty-Two Pollution
Prevention Grants

The Pollution Prevention Division.
in conjunction with the ten EPA
Regional Offices, has awarded $4.S
million to S2 state and tribal organ i-
xations under HPA's Pollution
Prevention  Incentives for States
(PPIS) grant program. The  1993
grants and cooperative agreements
support state  and tribal programs
that address the reduction or
elimination of pollution across all
media: air, land, and water. Since
1989, over S2S million  has been
awarded to support state and tribal
pollution prevention efforts. This
was the first year in which awards
were made directly through the
HPA Regional  programs.

Hach Region received  S-n(),()00 to
allocate as it deemed appropriate.
Various methods and formulas
were used. A number of Regions
held competitions among the
states and tribes, convening review
panels and awarding grants to the
highest ranked projects. Other
Regions divided the funds evenly
to each of their states.
The funded programs ranged
from projects lasting one year to
those which covered the maxi-
mum 3-year period. The highest
awards were given to the Ne-
braska Department of Environ-
mental Quality ($300,000) and the
New York Department of Environ-
mental Quality ($222,2%). Tribal
programs in  Regions  1, 4, 6, and
 10 were  awarded grants ranging
from  $13,000 to $182,000.
Grant recipients must match a
minimum ol SO percent of the
federal funds, as required by the
Pollution Prevention Act. State and
tribal contributions may come from
dollars, in-kind goods and services,
or third party contributions.
 For a summary of projects funded
 in 1993,  or for more information
on the PPIS grant  program,
 contact Lena Ilann, Pollution
 Prevention Division, at 260-223"7-

     Pollution Prevention Activities
Pollution  Prevention  Clearinghouse
Receives  High  Marks for  Information Services
Customers of EPA's Pollution
Prevention Information Clearing-
house (PPIC) appear to be a
very satisfied group. Of 272
respondents to an ongoing
customer survey on the reference
and referral line, 96 percent rated
the service as good (52 percent)
or excellent (44 percent). Over
three fourths said the informa-
tion they received was very
relevant to their purposes.

This encouraging feedback may
reflect in part the expanded role
given to PPIC over the past year
and its growing collection of
pollution prevention resources.
Both within EPA and among the
public, PPIC is charged with the
responsibility of educating
people on pollution prevention
and coordinating the transfer of
key technologies to appropriate
industry and governmental users.
PPIC was created following the
passage  of the Pollution Preven-
tion Act  of 1990. A joint project
of OPPT and ORD's Office of
Environmental Engineering and
Technology Demonstration, the
Clearinghouse provides informa-
tion to the public and industry to
promote the conservation of
natural resources and reduce or
eliminate pollutants in the work-
place and our communities.

OPPT operates two of the three
major services offered by PPIC:
the Reference and Referral Line,
and the Online Library System.
ORD operates the Pollution
Prevention Information Ex-
change System (PIES).

Primarily designed as a general
information resource, the Refer-
ence and Referral Line (202-260-
1023) provides basic information
on pollution prevention and
refers callers to appropriate
sources of information in a
network of national, regional,
and state organizations.

The Online Library System
represents an impressive range of
materials on pollution prevention
for a variety of users. EPA and
State publications, conference
minutes, industry case studies,
and journal articles on pollution
prevention and developing
technologies are included in this
storehouse of materials. The
collection will very shortly be
available for interlibrary loan by
dialing (919) 549-0720
(databits=7, parity=none, stop
bit=l, duplex=halO.
PIES is a  24-hour database
featuring literature search func-
tions, a national calendar of
conferences, case studies on
pollution prevention, a bulletin
board, and a variety  of informa-
tion exchanges for pollution
prevention issues. You can
access the PIES database by
    percent rated
    the service as
    good or excellent.
dialing (703) 506-1025
(databits=8, parity=none, stop

One of PPIC's goals is to dramati-
cally improve information sharing
among the many institutions and
organizations now involved in
pollution prevention. OPPT has
funded a cooperative agreement
with the National Roundtable of
State Pollution Prevention Pro-
grams to conduct the necessary
research for establishing a na-
tional network of pollution
prevention information centers.
More information on this exciting
project will be available in the
near future.
For more information on PIES,
contact Myles Morse at 202-260-
3161. For information on other
services offered by PPIC, contact
Beth Anderson at 202-260-2602.
                                     VOL. 15/NO. 1  SPRING 1994

     Pollution Prevention Activities
National  Roundtable of State Pollution
Prevention Programs:  1994 Spring  Conference
A watershed meeting of the
National Roundtable of State
Pollution Prevention Programs
was held in Seattle on April 3-6,
attended by over 300 representa-
tives of state and local govern-
ments, federal agencies,
industry, and private  nonprofits.
A key focus of the meeting was
redefining the Roundtable's
mission at a time when pollution
prevention is becoming a
"mainstream" concern of core
state environmental programs.

Other topics discussed at the
meeting include state involvement
in "preventive regulation," coordi-
nation of EPA's voluntary pro-
grams and their connection with
compliance activities, small
business assistance programs
under the Clean Air Act, and state
involvement with the technical
assistance programs of the Manu-
facturing Technology Centers run
by the National Institute for
Standards and Technology.
The new Executive Director of the
Roundtable is Natalie Roy, taking
over from Jim Lounsbury who is
returning to EPA after a year's
detail. The Next Roundtable
meeting will be held in Minne-
apolis, November 2-4, 1994.
  Conference To Promote Voluntary Initiatives

  In partnership with EPA, the Hampshire Research Institute is sponsoring a conference on "Promoting
  Pollution Prevention by Voluntary Initiatives." The conference, featuring EPA Administrator Carol Browner
  as the keynote speaker, will be held June 1-3, 1994, in Colonial Williamsburg, Virginia.
  Broad in scope, the conference will address case studies, future voluntary approaches, full cost account-
  ing, obstacles and opportunities in voluntary initiatives, and legislative, regulatory and international
  perspectives. There will be ample opportunities for interaction among attendees; there also will be an
  information exchange where participants can have questions answered on a broad range of topics, from
  technical to regulatory to financial.
  The conference will feature stimulating and provocative plenary, luncheon and dinner speakers. It will
  be of interest to companies both large and small across a spectrum of industries, as well as to govern-
  ment officials and public interest organizations.
  For more information on registration, to request time to make a presentation, to inquire about participa-
  tion in the information exchange, or to provide recommendations on speakers or topics, contact:
                            R. Cynthia Pruett, Conference Coordinator
                            Hampshire Research Institute
                            1600 Cameron Street, Suite 100
                            Alexandria,  VA 22314
                            Phone: 703-683-6695;  Fax: 703-684-7704
                                      CHEMICALS IN PROGRESS

     Pollution Prevention Activities
Environmental  Management
Standards:  Is EPA ISO-lated?
by Mary McKiel

In January 1991, the International
Standards Organization (ISO)
began development of interna-
tional Environmental Management
Standards. This article takes a
look at ISO, the ISO documents
for quality and for environment,
and how EPA is playing a role in
the development of voluntary
environmental standards.

What is  ISO?
The International Standards Orga-
nization along with its companion
organization, the International
Electrotechnical Commission, is
the world's leading private sector
developer of voluntary standards.
ISO develops and publishes 85%
of the international standards
available.  The main work of ISO
includes the harmonization of
national standards and certification
systems across international
borders. More than 120 countries
belong to ISO as full voting
members, while several other
countries  are observer members.
The United States is a voting
member and is officially repre-
sented in  ISO by the American
National Standards Institute (ANSI)
located in New York.
Most of ISO's 7,000-plus standards
deal with products, product
testing  and certification testing.
Under the ANSI umbrella, U.S.
industry, trade associations,
consumers and government
agencies participate on ISO
committees to develop standards
on everything from soup to
satellites. Technical experts
usually populate the ISO commit-
tees, of which there are over
200 main committees  and  many
more subcommittees and work-
ing groups.
ISO's Technical Committee  207,
known as TC-207, is responsible
for the Environmental Manage-
ment Systems Standards. Unlike
product or testing standards whose
users are generally in the technical
community, documents developed
in the  TC-207 are intended  to be
management tools, i.e., they are
used by management to establish
and measure goals — in this case,
environmental goals. Professional,
managers and environmental
groups as well as technical  experts
are needed as active participants
on the committee.

This is the second time in ISO's
history that member countries
have tackled management stan-
dards. The now famous ISO-9000
series  of documents on quality
management were first published
less than a decade ago. Since then,
U.S. industries, like many around
the globe, have spent considerable
              ISO continued on next page
When ISO documents
are referenced in bilateral
agreements or trade
agreements, they
become de facto
regulatory elements of
trade. They are powerful
tools of commerce.
                                    VOL. 15/NO. 1 SPRING 1994

     Pollution Prevention Activities
ISO from previous page
time and money in bringing
manufacturing and quality systems
into conformance with the ISO
documents. When an industry
adopts an international product
standard, the industry may have to
adjust, for example, a segment of
its manufacturing process. For
many U.S. companies — even
large,  multi-national corporations
— adapting to ISO-9000 has meant
readjusting their whole way of
doing business.
What  is the interest in ISO all
about? In its simplest form, the
answer is; easier access to com-
petitive trade. The ISO documents
harmonize standards between
trading partners. An analogy from
grade-school algebra would be: If
A=C and B=C, then A=B. In other
words, ISO acts as a "recognition
factor" so that an industry from
one country can trade on an even
basis within another country.
When ISO documents are refer-
enced in bilateral agreements or
trade  agreements, they become
de facto regulatory elements
of trade. They are powerful tools
of commerce.

Environmental Management
Joe Cascio, an IBM executive and
chairman of the U.S. Technical
Advisory Group (TAG) to the ISO-
TC -207, has said: "Environmental
standardization will be the
equivalent to ISO 9000. I predict
that four years from now, Ameri-
can plants will have to be certi-
fied to environmental standards in
order to sell their products in
Europe." Let's take a look at the
environmental standards that are
beginning to take shape in the
ISO 207 process.
The ISO Technical Committee 207
on Environmental Management
Systems is currently divided into
five subcommittees in the follow-
ing areas: Environmental Manage-
ment Systems, Environmental
Auditing, Ecolabeling, Environ-
mental Life Cycle Analysis and
Environmental Performance
Evaluation. In  addition, a Working
Group on Environmental Aspects
of Product Standards  reports
directly to the  full committee.

The scope of work for the TC-207
expressly prohibits addressing any
regulatory issues. Environmental
Management Systems as conceived
by the ISO process are principles
and guidelines that a company or
industry would adopt to help it
identify environmental goals
beyond regulatory conformance,
and provide an implementation
plan for reaching the  goals. Audit-
ing standards would be used to
determine if the system has the
necessary check  points. Environ-
mental Performance Evaluation
Standards will be the  measurement
tools to see if the environmental
indicators are accurate and to see
if environmental goals are reached.
The subcommittee on Life Cycle
Assessment (LCA) is further
subdivided into working groups
on aspects of life cycle such as
inventory analysis. LCA outputs
will help inform the Eco-labeling
subcommittee and working
groups which are putting
frameworks on  international
practitioner programs as well as
report-card-type labeling programs
and codes of good practice.

The main TC-207 Committee has
also established an advisory
committee to work with the ISO
TC-176, the Technical Committee
responsible for the ISO-9000
documents. If Mr. Cascio is
correct, it will be critical for the
two committees to integrate their
standards so that certification
requirements for quality and for
environmental management do
not act as barriers to one another
and that joint certification costs
are not prohibitively high.

The ISO Environmental
Standards and EPA
ANSI has delegated its authority
for coordinating the U.S. partici-
pation in the  TC-207 to the ASTM
(formerly, the American Society
for Testing Materials). ASTM and
the members of the U.S. TAG are
trying to encourage a broader
range of participation. EPA re-
cently brought good news on that
subject to the TAG.

OPPT and the Office of Wastewater
Enforcement and Compliance
jointly brought the ISO activity to
               ISO continued on next page
                                       CHEMICALS IN PROGRESS

      Lead, Asbestos, PCBs
ISO from previous page
the attention of the Administrator
and other EPA Offices. With a
mandate from EPA Administrator
Carol Browner, the Agency estab-
lished a new Standards Network in
order to track and participate in the
work of the TC-207. At the January
meeting of the U.S. TAG, EPA
announced its intention to partici-
pate in the development of the
environmental management stan-
dards and designated representa-
tives to the main Committee and to
each of the five subcommittees.

The fit is a natural one for the
Agency. Labeling and  life cycle
analysis are two of EPA's existing
projects which provide valuable
input to the U.S. TAG. Under its
central ethic of pollution preven-
tion, the Agency encourages
public and private sector alike to
seek ways of achieving industrial
and economic ends through non-
polluting mechanisms. The
Environmental Management
Systems Standards under develop-
ment in the ISO process give
promise of promoting pollution
prevention concepts on a national
and international level.

For Information
For more information  about the
ISO TC-207, contact Rose
Tomasello at ASTM, 1916 Race
Street, Philadelphia, PA. 19103.
For information about the EPA
Standards Network, contact Mary
McKiel at (202) 260-3584.
PCB Petition Denied

EPA has denied a citizens' petition
filed under Section 21 of the
TSCA. The petition sought to
amend the definition of incinera-
tor found at 40 CFR 761.3 of
TSCA. 40 CFR Part 761 regulates
the manufacture, processing,
distribution in commerce, use,
and disposal of Polychlorinated
Biphenyls (PCBs).
The petition was submitted  on
July 14, 1993 by the Hazardous
Waste Treatment Council, the
Sierra Club, and the Izaak Walton
League of America. The petition-
ers sought to have EPA initiate
action to amend the definition  of
incinerator at 40 CFR 761.3  to
include any device "that heats
waste in an oxidative environ-
ment." (This would encompass
any exposure  to air or flame
while heating.) The petitioners
maintained that certain technolo-
gies are allowed to treat PCB
wastes without meeting the same
standards required of incinerators,
thereby posing a risk to health
and the environment.
Under Section 21  of TSCA, the
EPA has 90 days either to grant a
petition and initiate appropriate
action, or to deny the petition and
publish a notice in the Federal
Register, giving the reasons  for the
denial, EPA denied the petition
because the amendment re-
quested by the petitioners is not
necessary, in EPA's judgment, to
protect against unreasonable risk
to health or the environment. The
current TSCA PCB regulations
require all disposal devices to
meet equivalent standards,
whether they are permitted as
incinerators under 40 CFR 761.70
or as alternative methods under
§76l.60(e).  Therefore, amending
the definition of incinerator to
include certain alternative tech-
nologies would not subject those
technologies to more stringent
standards than they already are
required to meet. In addition, the
changes proposed by the petition-
ers would be difficult to imple-
ment, due to  the ambiguous
nature of the  proposed definition.

The petitioners also petitioned  the
Agency under RCRA Section
7004(a) to amend the definition of
incinerator  found at 40 CFR
260.10. EPA will address that
petition separately. (Unlike TSCA
Section 21, RCRA Section 7004
imposes no deadline for EPA's
response.)  TSCA Section 21 does
not authorize a person or organi-
zation to petition EPA to take
action under  other statutes.

For additional information, see
the October 5, 1993 Federal
.Register Notice (58 FR 51816)
which explains the Agency's
reasons for denial. A copy of the
petition and related documents
are available  for inspection at the
TSCA public docket (file no.
OPPTS 211034).
                                       VOL. 15 / NO. 1 SPRING 1994

International Community Steps Up Focus on Toxics Inventories
At an unusual meeting held in
Brussels on January 24-26,  1994,
more than 80 people from around
the world gathered to discuss TRI-
type inventories for collecting and
disseminating information on
industrial releases of toxic chemi-
cals. The meeting was widely
represented by international
organizations: it was convened by
OECD, hosted by the EC, and co-
sponsored by IPCS and UNITAR,1
among others. The focus of the
meeting was on pollutant release
and transfer registers, an interna-
tional term for emissions invento-
ries much like TRI in the U.S.

The impetus for the meeting was
the recognition at the Earth
Summit in Rio de Janeiro in 1992
of the value of chemical release
inventories. Agenda 21, the Earth
Summit's master blueprint for
sustainable development, recog-
nizes the fundamental right of
citizens to learn about toxic
chemical emissions in their
communities, and the value of
emissions inventories as a plan-
ning and information dissemina-
tion tool for governments,
businesses and the public at large.

OECD  is creating a Guidance to
Governments document to detail
1 The Organization for Economic
  Cooperation and Development, the
  European Commission, the Interna-
  tional Program for Chemical Safety,
  and the United Nations Institute for
  Training and Research.
the advantages of inventories as
well as the mechanics of putting
one in place. The purpose of the
Brussels meeting was to reach
agreement on the content of the
first overview chapter for this
document. The meeting was
attended by  government repre-
sentatives  from more than 15
countries.  In a highly unusual
step, and in  deference to the spirit
of public involvement and right-
to-know, the meeting was open
to a broad spectrum of  interested
parties. In addition to EC and
OECD member countries, non-
member countries such  as Mexico
and Hungary were at the meeting.
Dozens of industry groups and
public interest organizations such
as Friends of the Earth and the
World Wildlife Fund attended the
meeting as full participants.

Three inventory models
described at the meeting
Three active models of chemical
release inventories were de-
scribed at  the meeting. The most
familiar is  the TRI-type inventory
developed in the U.S., and cur-
rently being  implemented in
Canada; this type involves manda-
tory reporting requirements to a
centralized data system, and tends
to focus on releases from the
industrial sector. Australia and the
EC are considering TRI-type
inventories as well.

The Dutch inventory system is
actually a  collection of different
inventories and estimation
schemes to develop air and water
release scenarios from all sectors
— industry, agriculture, transpor-
tation, etc. The Dutch system had
not been mandatory in the past,
and only aggregated information
was made publicly available.
However, due  to the international
momentum regarding right-to-
know, the Dutch are now making
site-specific data available,  and
are considering legislation to
require reporting.

In the U.K. a data system is being
developed in concert with their
program of integrated pollution
control. Unlike the TRI and Dutch
systems, IPC collects data re-
quired under permits, and con-
solidates it in a centralized data
system. All  three inventory mod-
els have the capacity to collect
chemical-specific information.
Only TRI is truly multi-media, in
that it collects data on  releases to
air, water and land as well as
transfers, but the Dutch and UK
systems are contemplating expan-
sion in this direction,
Anyone interested in further
information on these efforts, or
on future meetings (the next is
scheduled for Ottawa in June)
should contact David Sarokin at
                                      CHEMICALS IN PROGRESS

OECD  Member Countries Consider
Limiting Lead  in  Consumer Products
On November 18-19, 1993, OECD
held a work group meeting in
Paris, France, to discuss whether
and how a Council Act on lead
reduction should be drafted. The
U.S. delegation included OPPT
Deputy Director Joe Carra (who
led the delegation) and Doreen
Cantor, Chief the OPPT's Program
Development Branch. Other
federal delegates included repre-
sentatives from the Food and
Drug Administration and the
Department of Commerce. In
addition to the government
representatives, the U.S. has a
practice  of inviting observers to
these international meetings.
Accompanying the U.S. delegation
on this trip were Dr. Ellen
Silbergeld of the Environmental
Defense Fund, and Bob Muth of
the Lead Industries Association.

OECD began work in 1990 on
international risk reduction of
lead with the development of a
Council  Act on existing chemicals.
This Council Act enhanced and
coordinated information gathering
and encouraged concerted risk
reduction activities for high-
volume  chemicals. As a result of
this Council Act, OECD produced
a risk reduction monograph for
lead which spelled out what
individual countries were doing to
limit the risk of lead exposures.
As a result of discussion among
OECD countries, there was
interest in exploring whether the
OECD could formulate a Council
Act to reduce lead hazards —
especially those hazards that
could best be addressed by
international action.
OECD member countries include
most of the  Western European
nations, the U.S. and Canada, as
well as Japan, Australia, and New
Zealand. Mexico and China are
observer nations but have not
joined OECD. OECD Council Acts
may be in the form of a "Council
Decision" which member coun-
tries are expected to implement,
or a "Council Recommendation"
which member countries are
encouraged to implement. The
United States takes both Council
Decisions and Council Recom-
mendations seriously. To pass a
Council Act requires a consensus
among member countries. OECD
actions usually require several
years to complete.
At the November meeting, the
OECD Lead Working Group
agreed on criteria in deciding
whether a specific product or use
should be considered for interna-
tional attention. These criteria  are:
• International concerns, includ-
   ing international trade and
   transboundary pollution.

• Substantive contribution to reduc-
   ing human health exposures.
• Availability of safe and cost-
  effective substitutes or alterna-
  tive technology.
• Absence of environmentally
  sound and/or economically
  viable recycling systems.

The lead working group also
agreed upon a list of high priority
product categories for possible
future OECD action:
1. New uses of lead: new uses of
  lead would be adequately
  assessed and addressed by
  appropriate risk management

2. Recycling: encourage environ-
  mentally sound collection and
3. Point source controls: consider
  limiting the use of lead from
  major point sources (not-
4. Abatement programs: encour-
  age national  programs to  clean
  up existing facilities.
5. Assessment programs: encour-
  age instituting national pro-
  grams to measure the
  effectiveness of lead hazard
  reduction programs, including
  blood lead screening programs.
6. Technology transfer programs:
  consider providing assistance to
  non-member countries, includ-
      Lead Reduction continued on next page
                                     VOL. 15 / NO. 1 SPRING 1994

OECD Considers
Lead Limits
Lead Reduction from previous page
  ing information transfer and/or
  transfer of technology.
The Lead Working Group agreed
to meet in Canada in September
1994 to determine what control
measures might be feasible and
how best to achieve risk reduc-
tion of the identified products
and uses.
Each member country comes to
these meetings with its own
position and readiness to pro-
ceed. Several European delega-
tions were eager to begin drafting
a Council Act as soon as possible.
Other countries were hesitant to
move quickly. The United States
has already taken or is now
taking aggressive actions to
dramatically reduce human and
environmental lead exposures.

While it is too early to tell if the
OECD will be successful in
passing effective  resolutions,  there
appears to be significant promise
of achieving meaningful OECD
action. Such action could require
harmonized restrictions of prod-
ucts in international trade (e.g.,
ceramic ware), better control  of
transboundary pollution (e.g.,
smelting, recycling), and control
over the worst offenses of lead in
domestic consumer products  (e.g,,
paint and gasoline).
Report of the 3rd SIDS Review  Meeting
The 3rd SIDS Review meeting
was held at the Organization for
Economic Cooperation and
Development (OECD) in Paris
on September 20-23, 1993,
attended by participants from 16
member countries, the Business
and Industry Advisory Commit-
tee (BIAC), and international

The participants reviewed
updated assessments for a
number of SIDS chemicals:

• Phase 1:  Reviewed 10 remain-
  ing chemicals for final dispo-
  sition or  deferral pending
  other information.

• Phase 2:  Approved the SIDS
  testing plans for 12 previ-
  ously uncompleted cases and
  authorized preparation of
  Initial Assessment Report for
  six others.

• Phase 3:  Review of 63 cases
  resulted in final approval of
  testing plans for 23 and
  approval pending revision
  for 12 others. In another 23
  cases, all SIDS endpoints
  •were judged complete; these
  are thus ready for preparation
  of Initial Assessment Reports.
  Five cases were deferred to
  Phase 4.

For Phase 2 and 3 chemicals,
exposure information will be
collected during the testing
phase,  as agreed earlier by

A list of the chemicals to be
sponsored in Phase 4 was
distributed (see box on next
page).  Data collection for Phase
4 of the SIDS program began in
October 1993.
The 2nd SIDS Initial Assessment
Meeting will be held in Europe
in June 1994 and will consider a
set of 48 chemicals from Phases
2 and 3 that have completed
SIDS data packages.
                                      CHEMICALS IN PROGRESS

Sponsorship of Chemicals for Phase 4
Number Name
67641    Acetone
71363    n-Butanol
74851    Ethylene
77736    Dicyclopentadiene
78795    Isoprene
78831    iso-Butanol
79005    Ethane, 1,1,2-trichloro-
80433    Dicumyl peroxide
87901    Trichloro-S-triazinetrione
89838    Thymol
90028    o-Hydroxybenzaldehyde
98088    Benzene, (trifluoromethyl)-
98544    p-tert-Butyl phenol
98839    Benzene, (1-methylethenyl)-
100447   Benzyl chloride
101688   4,4'-MDI
103231   Di-(2-ethylhexyl) adipate
108054   Vinyl acetate
108894   4-Picoline
108996   3-Picoline
109068   2-Picoline
110021   Thiophene
110908   Morpholine
111308   Glutaraldehyde
United Kingdom
Number Name
111820   Dodecanoic acid, methyl ester
115775   Pentaerythritol
121335   Vanillin
156627   Cyanamide, calcium salt
556672   Cyclotetrasiloxane, octamethyl
760236   1-Butene, 3,4-dichloro-
923262   2-Hydroxypropyl methacrylate
1120214  n-Undecane
1163195  Di-pentabromobenzene ether
1313991  Nickel (II) oxide
1338416  Sorbitan, mono-octadecanoate
1570645  Phenol, 4-chloro-2-methyl-
2524030  Dimethyl chlorothiophosphate
2524041  Diethyl chlorothiophosphate
2536052  2,2'-MDI
3039836  Ethenesulfonic acid,
         sodium salt
5873541  2,4'- MDI
7784181  Aluminium fluoride (A1F3)
9016879  (Polymeric) MDI
25155300 Sodium

32055144 MDI (polymer)
Benzene, 1,1'-methylenebis



                                   VOL. 15 / NO. 1 SPRING 1994

EPA and  Environment Canada Exchange  Information
In the next few months, Environ-
ment Canada expects to finalize
its regulatory process under the
authority of the Canadian Envi-
ronmental Protection Act (CEPA)
for the assessment of all new
substances prior to their commer-
cialization in Canada. With the
compilation of the Canadian
Domestic Substances List (the
Canadian equivalent of the TSCA
Inventory) now completed,
Canadian regulators  are turning
their attention to the establish-
ment of procedures for adminis-
trative processing and scientific
evaluation of the information
which will be submitted by
industry under CEPA. Throughout
this process, Environment  Canada
and Health Canada staff have
worked closely with EPA staff and
their final regulations are aligned
with EPA's TSCA regulations in
many ways.

In addition to several meetings
over the past few years with
Canadian environmental staff in
which the U.S. New  Chemicals
Review Process was  described,
the Canadians requested a two-
tiered information exchange/
training session for their staff. In
June 1993, the New  Chemicals
Program played host to three
members of Environment  Canada
and Health Canada who will be
responsible for the day-to-day
review process. With the use of
non-confidential mock cases, the
Canadians were given a walk-
through of the entire New Chemi-
cals Review Process and had the
opportunity to meet NCP staff. In
September, 1993, a U.S. contin-
gent participated in a 3-day
information exchange held in
Ottawa with 20 staff  members
from Environment Canada and
Health Canada.

The New Chemicals  Review
Program at EPA uses an inte-
grated approach that draws on
knowledge and experience
running across disciplinary and
organizational lines to identify
and evaluate concerns regarding
health and environmental effects,
exposure and release,  and eco-
nomic impacts. The  result is that
a large number of individuals,
with specific expertise and
experience in these  various
disciplines, are involved in the
new chemical review and assess-
ment process.

The  New Chemical Program that
Environment Canada is estab-
lishing will use a similar multi-
disciplinary review process,
since the regulatory require-
ments of CEPA and  TSCA are
similar.  It  is in the interest of
both countries that efforts be
made early to harmonize assess-
ment methodologies and infor-
mation  sharing procedures.
A broad group of EPA  participants
allowed Environment Canada and
Health Canada participants an in-
depth look into "new" chemicals
review program functions, from
receipt of a notice to final regula-
tion/risk management. Each step
of the review process was pre-
sented in detail. Chemistry assess-
ment, the work of the Structure
Activity Team, ecotoxicity, human
health, environmental fate and
exposure, engineering, risk
assessment, and risk manage-
ment were all discussed by EPA
specialists in these fields. Each
of these presentations also pro-
vided the Canadians an opportu-
nity to ask questions about the
day-to-day running of a chemical
review program, resources neces-
sary  to complete tasks, and the
types of cases they could expect.
Because of the similarities be-
tween EPA's new chemical regula-
tions and Canada's, the detailed
discussions of the different phases
of our review process proved
very valuable.

A roundtable discussion on how
EPA's review process has changed
over time was especially valuable
to the Canadians. Fourteen years
of experience with our New
Chemicals Program has allowed
EPA  to develop certain efficiencies
and short cuts. For the purposes
of this exchange, though, the
adoption of these efficiencies was
not necessarily encouraged in the
early stages of the development
of their review process. Instead,
EPA staff emphasized the benefit
of in-depth review as a learning
tool  and the development of a
process that fosters the accep-
tance of new ideas and change.
                                      CHEMICALS IN PROGRESS

Clinton  Administration  Proposes Reforms  in
Nation's  Pesticide and  Food Safety Laws
The Clinton administration has
proposed extensive reforms of
the nation's pesticide and food
safety laws to reduce the risks
associated with pesticides, espe-
cially for infants and children.
The proposal, presented to a
joint Senate and House commit-
tee in September, includes
changes to FFDCA and FIFRA.
The reforms, designed to reduce
pesticide use and promote
sustainable agriculture, represent
the most significant attempt in
the past twenty years to improve
and update the nation's food
safety and pesticide laws.

The proposal establishes a
health-based standard for pesti-
cide  residues in food. Since
infants and children may receive
greater exposure to pesticide
residues because they consume
more food for their size than
adults, the plan calls for EPA and
USDA to identify foods children
eat in large  quantities and to
focus on child safety when
setting tolerances for those foods.

The reforms would extend
FDA's health-based standard of a
"reasonable certainty of no
harm" to all pesticide  treated
foods, including raw fruits and
vegetables.  Potential carcinogens
could pose no more than a
"negligible risk," interpreted as a
one in one million risk of can-
cer. The current Delaney stan-
dard does not allow
carcinogenic pesticides that
concentrate in processed foods.
Under the new reforms, EPA
would identify within six months
all pesticide residue levels on
food that may exceed the safety
standard. The highest risk
pesticides will be required to
meet the safety standard within
three years and all other pesti-
cides will be required to meet
the standard within seven years.

The reforms also would elimi-
nate consideration of economic
benefits in the pesticide review
and approval process except in
exceptional cases. High-risk
pesticide use •will be reduced
through the use of integrated
pest management (IPM) tech-
niques, which combine limited
pesticide use with practices
such as crop rotation, cultiva-
tion of predator insects, and use
of biological pesticides. EPA
would have the authority to
suspend the immediate use of
dangerous pesticides without
having to undertake  a lengthy
cancellation action, and all
pesticide registrations would
"sunset" every fifteen years, to
ensure that they meet current
health standards.
    The reforms, designed
    to reduce pesticide use
    and promote
    sustainable agriculture,
    represent the most
    significant attempt in
    the past twenty years to
    improve and update the
    nation's food safety and
    pesticide laws.
Other components of the reforms
would strengthen existing en-
forcement power, protect farm
workers from hazards associated
with pesticides, and prohibit the
export of pesticides  banned or
withdrawn in the United States
because of health concerns.
                                    VOL 15/NO. 1 SPRING 1994

     Legal / Enforcement
Enforcement  Reorganization
EPA Administrator Carol Browner
has announced the consolidation
of the Agency's enforcement
function into a single unit, the
Office of Enforcement and Compli-
ance Assurance (OECA). The new
organization will  streamline  the
compliance assistance services
provided to the regulated sector
and reduce inefficiencies associ-
ated with planning and conducting
multi-media enforcement activities.

The consolidation reverses the
decentralization  begun during
the administration of Anne
Gorsuch. This effort is now being
formally reviewed and imple-
mented by the Agency. The
entire Office of Compliance
Monitoring, which is part of
OPPTS, will be folded into

The next step in the process is to
evaluate the potential  impacts the
headquarters reorganization might
have on EPA Regional Offices,
where most enforcement takes
place. The Administrator has
asked Sylvia Lowrance, Associate
Deputy Administrator for EPA, to
chair a major Agency Task Force
to examine these impacts and to
recommend options for:
• Any long-term changes, includ-
  ing organizational ones, needed
  in the regions;

• Any short-term changes in
  procedures, reporting pro-
  cesses, planning/budget
  mechanisms, or other functions
  that would be needed to
  continue a strong enforcement
  program during the transition
  to the new OECA; and

• Changes in delegations of
  authority needed to increase
  the efficiency and effectiveness
  of enforcement programs.

The Task Force provided these
recommendations/options to the
Administrator on April 20, 1994.

For more information, non-EPA
employees are  invited to contact
Lynne Ross at (202) 260-5203.
The new organization
will streamline the
compliance assistance
services provided to the
regulated sector and
reduce inefficiencies
associated with
planning and
conducting multi-media
enforcement activities.
                                     CHEMICALS IN PROGRESS

     TSCA Hotline
Question  & Answer:
Exporter Responsibilities
Q: What are exporter responsibili-
   ties under §12(b) of TSCA, and
   how are export notification
   reporting requirements chang-
   ing due to the Federal Register
  publication of July 27, 1993?

A: Section 12(b) of TSCA requires
that any person who exports or
intends to export to a foreign
country a chemical substance or
mixture for which the submission
of data is required under TSCA §4
or 5(b), an order has been issued
under §5, a rule has been proposed
or promulgated under §§5 or 6, or a
relief has been granted under §§5 or
7, to notify EPA of such exportation
or intent to export.

  EPA issued a final rule on
December 16, 1980 (45 FR 82844)
which outlined the procedures
chemical exporters must follow in
order to comply with §12(b) of
TSCA.  Under this rule exporters
are required to submit, for each
affected chemical substance or
mixture, a single notice each year
for each country to which the
chemical substance or mixture is
exported. The Agency, in turn,
will advise the government of the
importing country about the U.S.
regulatory action concerning the
substance or mixture.

  The final rule published on
July 27,  1993 (58 FR 40238)
amends the December 16, 1980
rule for  chemicals subject to test
rules under §4 of TSCA by requir-
ing exporters to submit a  one-
time notice to  EPA for export of a
§4 chemical substance or mixture
to a particular country, instead  of
annual notification.  This  rule
became effective on January 1,
1994, wherein any exporter who
submits a notice to EPA advis-
ing of an export of a §4 chemi-
cal substance  or mixture to a
particular country does not
have to repeat submission of
identical notices in the years
following 1994.
  EPA believes this amendment
will maintain, if not increase, the
degree of protection to human
health and the environment
afforded by the December 16,
1980 rule, while reducing the
burden on exporters and the
administrative burden on EPA and
foreign governments.
To further reduce
your export reporting,
did you know...
• Notification of export to any
  country's territory or posses-
  sion satisfies the reporting
  requirement for its respective
  country or any other territory
  or possession belonging to
  that country. For example, a
  notice advising of an export
  of a particular chemical
  substance or mixture to
  Bermuda, would satisfy the
  reporting requirement if the
  same substance or mixture
  were exported to England or
  any other territory or posses-
  sion of the United Kingdom.
• Separate notification of
  export to a particular
  country is  NOT required for
  different products which
  may contain the same
  chemical substance or
  mixture, unless specified in
  the respective rule. In other
  words, one notice is suffi-
  cient per chemical per
  country, regardless of the
  presence of the same
  chemical substance or
  mixture in other products.
• Notification of export is
  NOT required for territories
  or possessions of the
  United States.
For additional information,
please contact the TSCA
Assistance Information Service
Export Office at (202) 488-3821.
                                      VOL. 15/NO. 1 SPRING 1994

ECOSAR:  New Ecotoxicity Software Available
The Office of Pollution Preven-
tion and Toxics announces the
availability of ECOSAR, a soft-
ware program for estimating the
toxicity of industrial chemicals to
aquatic organisms.  Under Sec-
tion 5 of TSCA, OPPT reviews
Pre-Manufacture  Notices for new
chemicals to assess the potential
hazards and risks that these
chemicals may present to human
health and the environment.
Often, ecotoxicity data are
lacking for such  new chemicals;
this has led OPPT to  develop
and refine techniques for esti-
mating the aquatic toxicity of
chemicals based  on other prop-
erties. OPPT's new software
makes the techniques used by
OPPT more readily accessible for
use by the chemical industry to
screen chemical toxicity to
aquatic organisms.
Structure-Activity Relationships
(SARs) have been used by OPPT
since 1981 to predict  the aquatic
toxicity of new industrial chemi-
cals in the absence of test data.
SARs are based on the relation-
ship between properties of a
chemical and biological effects. A
Quantitative Structure-Activity
Relationship (QSAR) is a predic-
tive equation (model) derived
from the statistical  analysis of test
data from the testing of an
organism and a variety of chemi-
cals  with a similar  mode of
action, e.g., narcosis.
The acute toxicity of a chemical
to fish (both fresh and saltwater).
invertebrates (daphnids), and
green algae has been the focus
of the development of SARs.
Some SARs are also available for
other effects (e.g., chronic toxic-
ity and bioconcentration factor)
and organisms (e.g., earth-
worms). The most frequently
used physical/chemical  property
is the octanol/water partition
coefficient (Kow). SARs have been
developed for specific chemical
classes (e.g., phenols) based on
measured test data that  have
been submitted by industry or
developed from other sources.
Using the measured aquatic
toxicity values and estimated Kow
values, regression equations
have been developed for many
chemical classes. Toxicity values
for new chemicals can  then be
estimated by inserting the esti-
mated  Kow of a new chemical
into the regression equation
and correcting the  resultant
value for the molecular weight
of the compound.
ECOSAR is a computerized
version of the SAR methods
currently practiced by Staff
scientists in OPPT. It is  a prag-
matic approach to SAR  as op-
posed to a theoretical approach.
The  program allows access to the
SARs via user-friendly menus.
Over 100 SARs, representing 42
chemical classes, are available for
estimating the toxicity of chemi-
cals to aquatic organisms. The
appropriate SAR may be selected
from an alphabetical list of
chemical classes and subclasses,
including various permutations of
the chemical names. SARs for
predicting the toxicity of chemi-
cals to fish, daphnid, and green
algae are available for most
classes. Ecotoxicity values for
other chemicals, including some
surfactants and polymers, can be
determined using the number of
carbons in the alkyl chain or the
percent amine nitrogen instead
of the Kow. The program also
estimates the water solubility of a
chemical and compares it with
the predicted ecotoxicity values.
In addition, the ECOSAR can
provide estimates for the aquatic
toxicity of some inorganic chemi-
cals based on the Office of
Water's Water Quality Criteria for
aquatic organisms.
ECOSAR is designed for use by
scientists with knowledge of
chemistry, biology, toxicology,
and SARs. It is menu driven and
contains numerous help screens
to guide the user regarding the
requirements for inputting the
information required to estimate
the toxicity of a chemical. The
program also provides access to
a description of each SAR's
derivation, use, application, and
limitations. The print option
permits the user to generate a

            ECOSAR continued on next page
                                      CHEMICALS IN PROGRESS

New Software
ECOSAR from previous page
report on the toxicity profile for
the chemical in question.
Minimum requirements for
running the software program are
an IBM-compatible personal
computer with an 80286 proces-
sor and 640K RAM with a mini-
mum of 512K free.
"ECOSAR: Computer Program
and User's Guide for Estimating
the Ecotoxicity of Industrial
Chemicals Based on Structure
Activity Relationships" is avail-
able. Copies may be obtained
from the National Center for
Environmental Publications and
Information, (513-596-7985)
(EPA-748-R-93-002); National
Technical Information Service
(NTIS), 703-487-4650 (PB94-
104668 and PB94-500485); and
Government Printing Office, 202-
512-1530. The Program and
User's Guide may also be down-
loaded from the Government
Printing Office Bulletin Board
  New Brochures Available
  From OPPT
  Among the publications now
  available from the Office of
  Pollution Prevention and
  Toxics are:

  • Status Report on the Use of
    Environmental Labels

  • The Use of Life Cycle Assess-
    ment in Environmental
  • Evaluation of Environmen-
    tal Marketing Terms in the
    United States
  • "Green"Advertising Claims

  • Fact Sheet: Environmental
    Messages in the Marketplace
  For copies of these or any
  other OPPT publications,
  please contact PPIC at 202-
  New Publications Available from

  the TSCA Hotline: 202-554-1404

  • EPA's 33/50 Program: Fourth Progress Update

  • Broad Scan Analysis of the FY 82 National Human Adipose
    Tissue Survey Specimens
    Volume I - Executive Summary
    Volume II - Volatile Organic Compounds
    Volume III - Semi-Volatile Organic Compounds
    Volume IV - Polychlorinated Dibenzo-p-Dioxins and
              Polychlorinated Dibenzofurans
    Volume V - Trace Elements
  • Volatile Organic Compounds in Whole Blood Determination by
    Heated Dynamic Headspace Purge and Trap Isotope Dilutum -
  • Baseline Estimate and Time Trends for Beta-Benzene, Hexachlo-
    ride, Hexachlorobenzene, and PCBs in Human Adipose Tissue
  • Characterization of HRGC/MS Unidentified Peaks from the
    Analysis of Human Adipose Tissue - Volume II - Appendices

  • Chlorinated Dioxins and Furans in the General U.S. Population:
    NHATS FY 87 Results and Executive Summary

  • Indoor Air Pollutants from Household Product Sources

  • Acquisition and Chemical Analysis of Mother's Milk for Selected
    Toxic Substances
                                    VOL. 15/NO. 1 SPRING 1994