oEPA
United States
'inmentm Protection
Agency
Office of PestK
and Toxic Subiijnces
5ton, DC
EPA-560/TIPS-81-001
July 1981
Tox.c Substances
State Integrated
Toxics Management:
Fact and Challe: 3
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560/TIPS-8I-001
National Governors' Association
Center for Policy Research/Office of State Services
400 North Capitol Street
Washington, D.C. 20001
STATE INTEGRATED TOXICS MANAGEMENT:
FACT & CHALLENGE
Hilary Whittaker
Project Director
Office of State Services
Helen Ketcham
Project Officer
Office of Toxics Integration
Jaynelle M. Ketchum
Research Associate
Cheryl Thomas
Research Assistant
Ann Johnson
Administrative Secretary
Financial support for this study was provided under grant
R807966-01-0 with the Environmental Protection Agency,
Office of Toxics Integration.
March, 1981
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TABLE OF CONTENTS
Page
I. EXECUTIVE SUMMARY & RECOKMENDATIONS 1
The Components of Integrated Toxics Management 1
General Findings 3
Specific Findings & Recommendations 4
Concepts & Terms 4
State Organizational Needs 5
Need for State Management Tools 10
Authorities , , 13
Role of the Governor 14
Public Information & Partcipation 15
Health Effects Monitoring & Studies 17
Scientific & Technical Support 17
Federal Management Assistance 18
Summary 19
II. INTRODUCTION 21
Chemical Proliferation. 21
Growth of Fragmented Legislation 21
Growing Health Concerns 22
Information Gaps 22
Lack of National Management Policy 23
Management Implications for States 23
TSCA: Prospect for Progress 25
Elements & Benefits of Integrated, Toxics Management 27
Purpose of this Study 29
Methodology , 30
Report Content & Uses 33
III. THE CHALLENGE OF INTEGRATED TOXICS MANAGEMENT 35
Fragmentation in Toxics Management 35
Terms & Definitions: Order vs. Confusion 36
State Environmental Authorities 41
Governors & Executive Office Involvement 44
General State Problems 45
Federal-State Relations & Problems 51
State Priorities & Needs 58
Integrated Toxics Management 62
IV. STATE GROUPINGS 67
Analytical Descriptors 67
Group X States 69
Group Y States 113
Group Z States 126
Intergroup Contrasts , 134
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Page
V. SUMMARY OF STATE DANGEROUS CHEMICALS MANAGEMENT PRACTICES 147
State Toxics Integration Management Strategies 149
Arkansas 149
California , 155
Illinois 158
Maryland. 165
Michigan 171
New Jersey , 175
New York 182
North Carolina 186
Oklahoma. 191
Puerto Rico 197
Virginia 200
Wisconsin 203
State Umbrella Legislation & Noteworthy Statutes 208
Connecticut 208
Illinois 212
Oklahoma 215
Virginia 218
Innovative Programs, Projects & Studies 223
Emergency Response , 223
Icrua
Kentucky
Tennessee
Enforcement 232
Neu Jersey
Massashusetts
Health Effects Studies ~ 237
Illinois
Montana
Neu Jersey
New York
Vermont
Wisconsin
Information Gathering 246
Iowa
tftchtgan
Mississippi
Virginia
Integrated Environmental Planning & Review 253
Icua
Kansas
Utah
Management Inventories 256
North Carolina
Virginia
Networking 261
Wisconsin
Occupational Health A Safety Planning Association
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Page
Standards Development 267
Kentucky
Vermont
Testing Procedures 269
Nea Jersey
Training 271
Colorado
Working with Industry 275
Montana
Working with Local Governments 277
Massachusetts
New lork
Washington
VI. STATE & TERRITORIAL TOXICS MANAGEMENT CONTACTS 287
(Alphabetical by State and Territory)
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I. EXECUTIVE SUMMARY & RECOMMENDATIONS
The broad and complex range of problems associated with, dangerous sub-
stances has created one of the most serious public management problems in
the United States today. For example, the generation of toxic substances is
growing apace; however, knowledge of their hazard Implications and management
strategies are lagging. There is no clear nation-wide strategy to balance ec-
onomic development with the protection of human health and the environment.
Knowledge of long-term health hazard implications is imprecise. Manage-
ment programs at every level of the public and private sectors are generally
uncoordinated and toxic chemical incidents of potentially crisis proportions
have generated tremendous public fears.
States, which must safeguard public health and safety but also assure
economic growth, are responsible for viable toxics management programs. Many
are unsure; however, of just what is involved and would welcome guidance about
how to proceed.
The Components of Integrated Toxics Management
State dangerous chemicals management programs risk piecemeal, fragmented
development in reaction to varied federal authorities and concepts unless
they encompass and address all of the following concerns:
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media: air-, land, water, workplace;
operations: production, processing, use and reuse,
handling, transportation, distribution and sale,
storage, disposal;
products; raw chemicals, combined chemicals, by-
products, waste;
impacts: on human health and the environment - em-
issions (air), discharges (water), leaching (land),
exposures (human body);
hazards; tozicity (oral, dermal, inhalation), ig-
nitability, corrosivity, reactivity, radioactivity,
explosivity, irritability;
management functions; of government and the private
sector; writing and passing laws and regulations,
monitoring, inspection, testing, sampling, investi-
gation, enforcement, registration, licensing, per-
mit issuance, certifying, funding, coordination,
training, planning, information dissemination, emer-
gency response, evaluation.
It should be emphasized that no one state program can or should encom-
pass all these concerns; rather, they must be identified and/or established
and effectively coordinated.
The concept of toxics integration Incorporates four basic elements: 1)
comprehensive management of all environmental concerns, 2) the use of toxics
as a point of commonality among all media, operations, products, impacts,
and w^^igpfflgTit1 functions, 3) a preventative, mitigative philosophy with
primary emphasis on human health, and 4) balancing economic and social costs
with benefits of environmental control.
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The benefits associated with toxics integration encompass: 1) cost sav-
ings through efficient coordination, 2) prevention of future harm, 3) promo-
tion of coordination and cooperation within state government and among federal,
state and local governments, and 4) eliminating present and future health ef-
fects information deficiencies.
General Findings
The Office of State Services of the National Governors' Association Center
for Policy Research gathered information about the current ststus of state and
territorial toxics management programs, to the extent they exist, as well as states'
needs and problems, convened several meetings of governors' aides and toxics manage-
ment personnel, and discussed toxics management with officials from most states and
territories (excepting Northern Mariana Islands, North and South Dakota and Oregon).
It was found that twelve states have developed or are planning intra-
state toxics integration programs and they have done so essentially on a trial
and error basis. A mechanism is needed to share lessons learned among them
and with states that are just beginning.
Other general findings of the NGA review were that:
States appear to be concentrating their efforts on hazardous
waste management more than on other types of hazardous sub-
stances management;
TSCA legislation provides for no explicit substantive role
for states, and most states do not see therein an implicit
role that Is not advocated by other federal environmental
laws (e.g., CAA, FWPCA, RCRA, FIFRA);
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» Many states believe they should have comprehensive, in-
tegrated hazardous substances management programs, as
well as a stronger focus on toxics, but many don't
know just where to start;
States would welcome policy and management guidance
briefings, organizational materials and more informa-
tion on available support and, importantly, a single
source to obtain valuable peer advice based on state
level experience;
The more experienced states would welcome a mechanism
by which they may keep abreast of policies, legisla-
tion and management innovations of other states; and
Due to individual state exigencies, state programs
cannot and will not be uniform; however, all desire
practical information and experienced-based advice
as they organize their programs.
Specific Findings and Recommendations
The NGA review also produced a series of specific findings which suggest
several ways in which orderly coordination may be approached.
Concepts and Terms; State government division heads working with various
types of toxic substances know and interpret terms in various ways, often be-
cause federal programs do so. In order to coordinate effectively, managers
and coordinators of overall toxic strategies must understand how relevant terms
interrelate. EPA managers also need to understand this in dealing with various
state offices. Commonly used concepts and terms demand mutually understood
definitions because effective intergovernmental coordination depends on communi-
cation.
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A taxonomy charting definitions, usages and linkages would be a useful
cool for both federal and state toxics integration coordinators and managers.
State Organizational Needs; The NGA review team examined the general
organization of states and territories as they deal with toxics in the air,
land, water and workplace in terms of interoffice cooperation, health effects
studies and monitoring; information gathering and communication, data retrie-
val and sharing and innovative programs.
It was found that states, generally, fall into three broad categories of
organization and sophistication in toxics management, although each state is
unique and some could fit two or three in terms of some of their activities.
The states will be categorized in this report as "Group X," "Group 7" and
"Group Z." The following general characteris tics describe the three cate-
gories:
Group X States
strong support for toxics integration from the governor;
an integration strategy either functioning or under development;
focus on toxics, pulling together interdepartmental programs, media
operations, products, impacts, hazards and management functions,
and integration of toxics concern throughout most environmental
management activities;
high priority on health effects studies, environmental epidemiology
and toxicology, and continuous monitoring;
emphasis on information gathering and sharing, inventorying
critical materials for prioritizing and targeting investigative
efforts, and comparatively high level of data computerization;
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relatively formal and organized communication and cooperation be-
tween various state agencies;
creative management efforts based on strong individual programs and
a long-term hazard prevention philosophy; and
these states include: Arkansas, California, Illinois, Maryland,
Michigan, New Jersey, New York, North Carolina, Oklahoma, Puerto
Rico, Virginia and Wisconsin.
Group Y States
mechanisms exist enabling future cross-agency, cross-media, cross-
program integration for toxics;
formal interagency cooperation for strong individual programs
(usually in emergency response, transportation and/or hazardous
waste), and ad hoc, informal cooperation on others;
collection of industrial production information generally limited
to hazardous waste generation and pesticide use data;
formal or organized information sharing for strong individual pro-
grams and ad hoc on others; some computerization of data;
interest in health effects studies and monitoring, recognition of
the need for environmental epidemiology, although no real emphasis,
some states have done isolated studies and preliminary research;
federal enforcement responsibility for most environmental programs
has been assumed, but more work needed to ensure they are firmly
in place;
some toxics control activities, but ad hoc attention in
varied programs (for the most part, water-related programs exhibit
stronger toxics concern); and
states in this category include Arizona, Colorado, Connecticut,
Delaware, Iowa, Kansas, Kentucky, Louisiana, Massachusetts, Minne-
sota, Montana, New Hampshire, Pennsylvania, Rhode Island, South
Carolina, Texas, Utah, Vermont, Washington and Wyoming.
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Group Z States
generally fragmented management, although some states have strong
hazardous materials emergency and/or hazardous waste programs;
ad hoc cooperation and coordination for most environmental concerns
ad hoc information sharing, with miscellaneous task forces organized
for interagency work on narrowly defined issues (e.g. hazardous
waste, siting);
little information gathering on chemical production and use or
little data computerization;
many of the individual environmental programs are in formative
stages except, generally, in pesticides and solid waste areas;
little toxics focus in individual programs, although concern exists;
these states and territories include: Alabama, Alaska, American
Samoa, District of Columbia, Florida, Georgia, Guam, Hawaii, Idaho,
Indiana, Maine, Mississippi, Missouri, Nebraska, Nevada, New Mexico,
Ohio, Tennessee, West Virginia and the Virgin Islands.
It should be emphasized that the above categories are descriptive of cur-
rent organizational state of the art in states, not prescriptive categories. It
is also necessary to underscore that the categorical placements were made based on
an initial summary review.
Depending on to whom the NGA review team talked in states, some respondents
believe they are well coordinated, and others in the same state believe otherwise.
All have varied conceptions about what toxics integration means, or should mean. It
is therefore difficult to categorize them into X, Y, or 2 groups. This was done,
simply, to provide a broad focus from which management needs and strategies might
be developed. It is also probable that in the short three month review period,
some state strategies were missed. Looking at states' toxics programs in broad
groups revealed that:
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X states appear to have developed toxic program thrusts in
reaction to (1) severe toxic crises, (2) health research
revealing high disease incidence or vulnerabilities rooted
in environmental contamination, and (3) alarming environ-
mental quality data generated by relatively sophisticated
monitoring;
In all three groups, environmental legislation has evolved
or been spurred by (1) environmental crises or incidents and
(2) federal legislative or regulatory requirements, although
many states have had some level of environmental protection
laws prior to the passage of federal legislation.
An in-depth analysis of these groupings, which appears in Section IV, ill-
ustrates interlinkages as well as contrasts between the three groups.
Y and Z States may wish to consider the extent to« which they may want to
emulate X States; however, they should not feel it necessary to do so. Many
states cannot, and should not, establish programs found in X States, because
they don't produce or handle large quantities of dangerous chemicals. The
Important thing is that all states consider the elements and potential bene-
fits of toxics integration and develop appropriate mechanisms to establish
integrated coordination, communication and cooperation to the extent needed.
Group X, T and Z States have different needs because they are at differ-
ent stages of development and have different priorities and problems. Group
X States need review materials and tools to evaluate the effectiveness of
their toxics strategies, as well as mechanisms by which they can share in-
formation with other states and gain added know-how for their own programs.
They have a great deal of expertise to be shared with Y and Z States and are
very willing to do so if a mechanism q*m be developed.
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Group Y States represent a potentially fruitful target group as they
eem to be ready to make productive use of toxics integration concepts, de-
ending on their individually perceived needs. These states could benefit
rom technical assistance from the federal level and Group X States.
Group Z States need consciousness raising about their potential vulner-
ibilities and mechanisms to deal with them. To the extent that the federal
government sees critical basic programs in which Z states should be involved,
these states should be so advised.
All states would welcome succinct, well packaged materials on informa-
tion sources as well as clearinghouse services; but materials and information
must not be in such detail or perplexing amounts that states cannot use it.
Also, states want materials geared to their individual needs and stage of
development.
Interrelating mechanisms with appropriate tools and materials should be
developed for each of the three groups. This can be done through federal-
state cooperation in the following areas:
continuous data gathering on state toxics management programs
and integration;
establishment of clearinghouse services for states, with
lessons learned by states as its cornerstone;
development of materials at different levels of expertise and
complexity for state use, and their active dissemination;
provision of management and advisory services between states
and between federal and state governments;
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the provision of EPA Chemical Substances Information Network
(CSIN) data to states in the aiost efficient, cost-effective
manner possible geared to encourage states' widespread use
and application of CSIN data; and
the development and implementation, of an annual national-
regional-state toxics management conference to facilitate
face-to-face information exchange and federal-state manage-
ment improvements.
Need for State Management Tools; Managers must have mechanisms to be con-
tinuously informed about: risk implications; whether risks manifest themselves in
the short or long-term; whether risks pose acute or chronic health problems of po-
tentially crisis proportions, and at what point in time the crisis threshold will
he reached. Managers must know what levels of government are involved or should
be involved, and what management functions and tools are needed in order to manage
the risks effectively. Information collection, organization of data, and analysis
are the first steps in beginning to answer the unknown.
Tools should be developed to help state environmental managers better
understand how their expertise, knowledge and activities interrelate. They must
be designed in such a way as to illustrate the inter-relationships among terms,
and activities of environmental, particularly toxics programs. They should be
designed from a state perspective and reflect state needs.
Several states have developed interesting management tools (charts, manage-
ment inventories for pinpointing gaps, overlaps and inconsistencies in activities,
laws and practices, and other potential reference tools). These should be carefully
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reviewed and adapted to the extent possible for use by all states. Management tools
developed from state materials with appropriate suggestions for usages would be
welcomed by states. For example, the programs summarized in Section V of this re-
port provide a great deal of raw material from which useful management tools could
be developed and disseminated among states.
Existing federally-developed tools should also be reviewed, adapted, pack-
aged, introduced and distributed to target states. For example, the EPA publi-
cation entitled Federal Activities in Toxic Substances provides a good reference
tool for helping states understand what federal authorities exist for the regula-
tion of toxics and in what ways those regulations are being implemented at the
federal level. The publication, however, does not readily provide a clear picture
of the links among the toxic control aspects of the various laws and programs.
In addition, only the drinking water chapter lists which states have primacy for
enforcement of federal requirements. It would be helpful for interstate refer-
ence to include in all program chapters a listing of states which have assumed
primacy inenforcement of various federal authorities.
The EPA/state agreement process provides another tool for capturing under
one cover the toxic aspects of state environmental programs. These agreements,
however, describe only some of the environmental programs of a state, those for
which the state is assuming federal responsibility. Actual linkages and specific
activities or tasks that implement integration and toxics control techniquest on
the operational level are usually glossed over, if mentioned at all. Information
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of this nature should be added in new agreements, or another procedure such as
an information center established to capture, analyze, synthesize and share
useful know-how.
In addition, the federal government has various lists of contaminants
that are regulated such as a list of hazardous wastes, federally regulated sur-
face and drinking water contaminants and so forth; however, the interrelationships
of listed substances are not clear. A chart, or series of charts, would be use-
ful so that state managers could see at a glance what substances are regulated
per given medium or operation* Such a chart could prove useful in determining
the pervasiveness of a particular chemical pollutant. A substance appearing on
^
all regulatory lists, for example, would be an indication that it poses a danger
at many points along the chemical life cycle requiring strict control action and
an integrated regulatory approach. Such a chart could be used in conjunction
with state chemical inventories for helping state environmental coordinators set
broad goals and parameters for prioritizing substances for possible regulatory
action beyond that currently required. Actual criteria standards would, of
course, depend upon more specific technical reviews of volumes, concentrations
and other factors.
Mechanisms or tasks for implementing integrated environmental manage-
ment functions should be documented in an easy to read form so that states can
choose from among a variety of methods for integrating program elements and
instituting toxic control activities. States can learn from each other. In
report, we document some tools and mechanisms already in use. Development
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of a set of guidelines, perhaps a governor's guide on toxics integration, from
materials already developed by states would be a useful tool, further research
on the effectiveness of current state strategies would provide "lessons learned"
materials for interstate information exchanges.
States may not readily see the need or benefit of implementing a toxics
integration management strategy. Case studies documenting advantages of having
such a strategy would be useful illustrations for states that have not yet con-
sidered such an approach. Networking through continuous information exchanges
by telephone and in writing between states and at the federal and state levels
could foster the favorable climate needed for initiating integrated strategies
and state-federal cooperation.
Work on toxics integration activities at the federal level must be en-
couraged every step of the way. The more integration at the federal level, the
easier and more compelling it will be for the states to implement integration
strategies.
Authorities; Both federal and state level environmental legislation and
regulations appear to be fragmented, as most authorities were enacted in response
to piecemeal, albeit critical needs. Such legislation is often patterned after
federal authorities with special "cuts" according to states' needs. Federal
funding and organizational requirements are often burdensome to states.
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Only a few states want additional authority to control toxics; rather,
they are searching for best ways to document and implement authorities. If any
gaps exist, our review suggests they may be in information gathering authority
needed to obtain data on chemical production and use, worker exposure and pub-
lic health.
It would be useful to compile and analyze existing and pending state
legislation on toxics management, and share findings among states. To the
extent feasible, existing state "umbrella" legislation should be compared to
"fragmented" authorities to determine and recommend improved options.
Role of the Governor; Most often, the governor becomes involved in toxics
management when a crisis occurs or is looming. Governors are often caught be-
tween their responsibility to promote economic growth while protecting public
health and the environment. This is often compounded by public outcry based on
incomplete and often inflammatory information, making rational management diffi-
cult. Lacking long-term implications information, governors cannot plan respon-
sible growth programs*
Governors need to (1) require continuous assessment of vulnerabilities,
(2) institute continuous evaluation programs (3) coordinate and enhance economic
development while protecting life and property, (4) establish policy and perfor-
mance standards, and (5) require the implementation of systems using all avail-
able resources through comprehensive, affordable programs.
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In order to do this, governors need organized tools and mechanisms to
(1) know the management functions involved, (.2) develop and integrate policy,
(3) coordinate, monitor and evaluate functions continuously, and (4) update and
change policy and programs according to needs and objective cost rationales.
A broad range of information and management initiatives is available and
growing. When organized and maintained, it can provide a valuable resource to
help states -develop comprehensive toxics integration and management programs
encompassing media, operations, products, impacts, hazards and management func-
tions in other words, effective management frameworks within which individual
categorical programs such as epidemiology, waste siting, emergency response,
storage, transport regulations, pesticides and many others can function in a
more coordinated comprehensive environment.
A martial overviewing toxics management elements and benefits, current
practices and organization and, importantly, suggesting management standards
governors should require,questions to ask and methods to evaluate the state
state of the art, would be useful.
Public Information and Participation; One of the major problems cited
by states in controlling toxics is local political controversy over siting
hazardous waste disposal facilities. Reports of chemically induced human
health effects in a particular locality often lead to overreaction to stories
about abandoned hazardous waste sites in other areas, and widespread public
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objection to plans for siting waste facilities in new areas. These fears also
generate public concern over expansion of industrial chemical production com-
plexes. The same is true for such crises as PCS contamination of livestock and
pesticides ingestion Ce.g., 2,4,-D, causing miscarriages).
This suggests a need for increased health effects monitoring and analysis
by state and federal officials in order to assure the public that the most
thorough, objective data have been utilized in the environmental decision-
making process. In addition, more active programs, specifically designed to
incorporate the public into the siting process, should reduce the amount of
management problems associated with facility siting.
As most public information problems tend to occur after chemical accidents
when public fear is raised about possible health effects, existing state pub-
lic participation efforts tend to be reactive. More proactive programs invol-
ving the public and private sectors in addressing their perceived needs early
on, should be instituted at the state and local levels, with industry and
federal cooperation.
Broad, objective public information and participation programs are needed
to establish a climate in which managers can act responsibly with informed pub-
lic input and support. An integrated package of public information tools devel-
oped by government, industry and public organizations would be useful for public
service broadcasting and use by chief executives. They can also provide useful
background or source materials for the media, and encourage balanced news analysis
and reporting.
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Health Effects Monitoring & Studies; Activity here is primarily limited
to Group X States. Environmental program managers and health authorities of
Groups Y and Z States rarely communicate except in emergencies. Environmental
disease and health effects data are imprecise, insufficient or non-existent;
thus it is difficult to establish management criteria and regulations. State
governments are usually reluctant to legislate or impose sanctions when unsure
of their data on health consequences.
Many states would welcome assistance in environmental epidemiology and
the development of systems to collect and share health data. EPA, in coopera-
tion with the Center for Disease Control, state epidemiologists or health au-
thorities, should coordinate the exploration of:
packaging and dissemination of currently available environ-
mental disease data on a state-by-state basis;
developing environmental epidemiological techniques as sophis-
ticated as those we now have for communicable disease in-
vestigations; and
instituting environmental epidemiological training at medical
institutions and other facilities.
The Center for Disease Control and its national network of epidemiologists should
be more broadly incorporated into all aspects of toxics integration management.
Scientific & Techncial Support; Most Y and Z States urgently need sci-
entific and technical expertise and equipment for testing and sampling, es-
pecially for "exotics." They lack adequate funds for both salaries and equip-
ment at the sophisticated level needed.
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This problem might be remedied through multi-agency federal funding;
cost-sharing between EPA and states; "circuit riding" consultants; regional
lab enhancement and/or additional use and support of university facilities;
and development of a constantly updated catalogue of federal and private funding
sources which may be creatively used to meet these needs. Certainly, where ex-
pertise and equipment exist, it should be identified and shared to the extent
possible.
Federal Management Assistance: In addition-to the state and state-federal
V
toxics management needs summarized above, specific program related services
might well be considered by EPA's various program branches. These include:
national and regional support for health effects studies and dissem-
ination of objective health effects data;
provision and placement for best use of chemical detection, testing
and monitoring equipment j also trained, adequately compensated
technicians;
federal-industry funding of cleanup and mitigation programs;
training programs for state technical and management personnel,
based on state experience and inputs;
technical assistance to states to catch up on laboratory backlogs
through the provision of "circuit rider" technicians and experts;
faster setting of standards for contamination levels of chemicals
having widespread dangerous implications;
national packaging and labelling procedures with minimal and
flexible administrative requirements;
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encouragement of interstate and regional agreements on waste siting
and disposal;
continued national data bank development, integration and sharing
of lessons learned among states, especially CSIN completion and
on-line implementation;
federal-state personnel exchange programs to facilitate increased
understanding of points of view and expertise exchange;
active federal-state efforts to simplify and make federal regulations
as flexible as possible and reduce and integrate environmental reporting
requirements;
establishment of national precedents through litigation and subsequent
court decisions that states may use to justify the need for state tox-
ics controls. This can reduce multi-state depletions of technical,
financial and time resources and costly duplication of work, and
recognition of federal toxics management roles as seated in research,
policy, standards setting, technical assistance, funding and support
to states for national priorities; and of state roles in operations
and procedural implementation of national policies and standards, as
well as for area-specific chemicals concerns.
The need for integrated toxics management is upon us. As public concern
over health effects of dangerous chemicals mounts and public funding diminishes,
integrated management of available resources minimizing costly program gaps, in-
consistencies and overlaps, becomes paramount.
States can develop responsible toxics management programs given responsible
federal encouragement and support through research, information sharing and co-
ordination, technical assistance geared to gain widest possible ripple effect,
and flexible regulation and m-tnimai procedural requirements.
This study has shown that a great deal of interest and activity exists in
states to manage their own environmental affairs. Given appropriate coordinative
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support, resreach and information sharing under TSCA, they can do much to manage
their own environmental destinies. Restrictive federal requirements for state
assumption of federal programs are not needed and the drafters of the Toxic
Substances Control Act are to be commended for their circumspect approach.
Perhaps the most useful contribution the EPA Office of Toxics Integration
could make would be to intensify work with the Administration, industry and
states to develop a productive national toxics policy. This should incorporate
the hazard implications of all potentially dangerous chemicals in all media,
operations and products, and define the relationships between all chemical manage-
ment programs for all levels of government and the private sector.
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Other Publications in the Toxics Integration Policy Series:
3;aza Administrative Models for Toxic Substances Management (July 1930)
SPA-560/13-80-018
Czr.ar Publications- ir. the Toxics Integration Informatics Series:
EPA Chemical Activities Status Report - 1st Edition (June 1979)
EPA-560/13-79-003
Directory of Federal Coordinating Groups for Toxic Substaaces-Ist
Edition (June 1979), 2nd Edition (March 1980)
EPA-560/13-80-008
Perspectives on the Top 50 Production Volume Chemicals (July 1980)
EPA-560/13-80-027
Federal Activities in Toxic Substances (May 1980)
EPA-560/13-80-015
TSCA Status Report for Existing Chemicals Volume 1, Issue 2 (July 1980)
EPA-560-13-80-033
Perspectives on State-E?A Grant Activities (September 1980)
EPA-560/12-80-037
Chemical Selection Methods: An Annotated Bibliography (November 1980)
EPA-560/TIIS-80-001
EPA Chemical Activities Status Report - 2nd Edition (December 1980)
EPA-560/13-80-040 (a)
Chemical Information Resources Handbook (January 1981)
EPA-560/TIIS-81-001
TSCA Status Report for Existing Chemicals Volume 2, Issue 1 (January 1931)
EPA-56Q/TIIS-81-002
Toxic Substances Control Act Grants to States (July 1981)
EPA-560/TIIS-81-003
TSCA Status Report for Existing Chemicals Volume 2, Issue 2 (July 1981)
EPA-56Q/TIIS-81-004
TSCA Chemicals in Commerce: Regional and State Perspectives
(July 1981) EPA-5601 TIIS-81-005
For further information, or to order copies contact:
Industry Assistance Office (TS-799)
U.S. Environmental Protection Agency
401 H Street, SW
Washington, D.C. 20460
Ton-free Telephone: 800-424-9065
In Washington, D.C.: 554-1404
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Foreword
We consider intergovernmental relationships a critical
factor in our efforts to develop better alternatives for
improved integration of EPA chemical regulatory programs.
It was with that perspective that we initiated a project
with the National Governor's Association to identify the
States' perspectives on integrated toxic chemicals management
their capabilities, needs, and constraints to effective
management. This final report paints a picture of toxic
chemical management issues as States see them, a picture
that EPA is analyzing carefully as we seek to chart new
roles in integrated toxics management. For States, this
report should be a valuable reference on what other States
are doing, as well as a tool for evaluating both
independently and collectively their weaknesses and
strengths. For all of us, the information becomes the
blueprint for an even more cooperative, and responsive
partnership.
Walter W. Kovalick, Jr.
Director
Integration Staff
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II. INTRODUCTION
Cheaical Proliferation
In the past decade, the nation's attempt to manage dangerous chemicals
has presented problems of increasing proportion. During most of the post
World War II era, the generation of toxic chemicals in this country has
been rapid and virtually uncontrolled. Between 1940 and 1970, an-
nual production of synthetic and organic chemicals increased by 340 billion
pounds. 1 Now, in 1980 it is estimated that over 55,000 chemicals are in
daily use in this country, with hundreds of new chemicals produced and placed
on the market each year.2
Growth of Fragmented Legislation
In the 1970s the federal government attempted to remedy damage and en-
sure protection of the environment through broad-based legislation such as
the Clean Air Act, Resource Conservation and Recovery Act, Federal Insecti-
cide, Fungicide, and Rodenticide Act, and over fifteen other federal laws,
each regulating a particular environmental medium, hazardous matierials op-
eration, hazardous substances product, or combination thereof. Such legis-
lation clearly paved the way for enhanced government protection of the en-
vironment and the quality of life. The piecemeal passage of these laws,
however, spurred the proliferation of overlapping jurisdictions and ad hoc
programs at the federal level. This contributed to a fragmented ap-
proach to managing dangerous chemicals at all levels of government.
1. Cancer and Industrial Production, Science Magazine 206, December 1979,
p. 1356.
2. Toxic Substances! A Brief Overview of the Issues Involved, EPA (Washington
U.S. Government Printing Office, 1980), p. 3.
3. EPA Region V Integrated Toxics Strategy Where All The Pieces Fit, EPA
Region V Analytic Center, 1980, p.4.
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Private citizens, concerned over the impact of chemicals in daily life,
face a jumble of federal, state, and local agencies, each responsible for
different aspects of chemicals management. The private chemical industry
which has been virtually unregulated, must now find the means of complying
with over twenty federal laws, as well as state and local laws, regulating
the manufacture, use, transport, sale, and/or disposal of dangerous chemicals.
Growing Health Concerns
To date, most federal environmental legislation calls for protection of
the environment, the implication being that a safe environment protects human
health. It can be argued that this approach has overshadowed direct efforts
to protect human health.
In the long term, the most elusive health hazard is the threat of slow,
often invisible poisoning of the environment through chemical contamination.
Active concern for such long term chemical hazards is now beginning to affect
environmental protection laws, regulations, programs and activities. The pass-
age of the Toxic Substances Control Act of 1976 indicated a heightened aware-
ness at the federal level of the need to control toxic substances explicitly
to protect human health. Implementation of this Act, unfortunately, has been
hampered by numerous scientific and political obstacles.
Information Gaps
Lack of sufficient information about the amounts and properties of chemicals
produced, used in industrial processes, distributed in commerce, transported,
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and ultimately disposed of as waste, makes it difficult to determine and im-
plement the most effective measures to control chemical misuse. Knowledge
of the short and long-term health effects of chemical exposure remains impre-
cise, insufficient, or even non-existant. In contrast, the economic benefits
of che chemical market are well known. Strong action to control chemical
substances is often deterred by two factors: their properties being so
complex that their potential for damage is unknown, non-quantifiable and/
or may not be manifest until long into the future; and profitability of
chemical production and use that supercedes social costs.
Lack of National Management Policy
A national dangerous chemicals management policy that links the hazard
implications of all potentially dangerous chemicals in all media, operations,
and products, and considers the administrative relationship between all
chemical management programs does not exist. The development of such
policy has been hampered by the lack of nationwide awareness of long-term
human health hazards, the slow accumulation of adequate environmental health
knowledge, and inability to efficiently manage health crises.
Management Implications for States
The rapid and virtually uncontrolled growth of chemical production, the
passage of piecemeal federal and state legislation, the subsequent prolifera-
tion of uncoordinated environmental control programs, the need for greater
awareness and knowledge of the health hazard implications of toxic chemicals,
the lack of adequate scientific and technical information, and the lack of a
national management policy pose problems for environmental managers.
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It is at the state level, however, that the lack of coordinated aanage-
ment presents the most severe problems. States, obligated to balance the
protection of public health and safety with the protection of the state's
economic base have created programs addressing toxics-related issues
that are not covered by federal programs. In addition, many federal
environmental lavs require states to assume substantial program responsibility.
For example, the Clean Air Act mandates that states develop State Implemen-
tation Plans (SIPs) for controlling primary and secondary hazardous air pol-
lutants,* the Clean Water Act delegates primary responsibility for controlling
nonpoint source pollution to the states,^ and the Resource Conservation and
Recovery Act requires every state and territory to develop an EPA-approved
state plan for implementing, monitoring, and enforcing the federal regula-
tions. States, responding to both national mandates and local needs, tend
to focus on the development of particular media, operation, or product-specific
programs rather than overall integrated management strategies.
At a time when many federal and state agencies face substantial budget
cuts, clear policy with administrative flexibility is needed to reduce gaps,
overlaps and inconsistencies in authorities and management practices that
squander scarce funds and resources. Continued inefficient management re-
inforces the popular view of government as excessive, wasteful, and ineffec-
tive, failing to protect human health and the environment and stifling the
4. Tools and Rules ... Federal Environmental Protection Programs. EPA, 1978,
p. 27.
5. Tools and Rules, p. 2.
6. Tools and Rules, p. 41.
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growth of industry and jobs. The financial constraints facing the federal
gcvemnent apply doubly to the states because federal budget cuts ultimately
iapact on federally-funded state programs, and a shortage of state monies
further restricts state efforts to control dangerous chemicals. The existence
of any local programs.depends, in turn, on the viability of the corresponding
state programs.
TSCA: Prospect for Progress
Among the over twenty pieces of federal legislation regulating some as-
pect of dangerous chemicals, one act - the Toxic Substances Control Act (TSCA)
- attempts to regulate toxic substances comprehensively, and "...for the first
time the entire chemical industry serving the U.S. is subject to broad-based
federal regulation."7 "TSCA gives EPA a broad mandate to protect public
health and the environment from unreasonable chemical risks - gather informa-
tion on chemicals to identify harmful substances and to control those sub-
stances whose risks outweigh their benefits to society and the economy."8
TSCA provides the EPA the authority to assess the hazardous nature of a
chemical prior to its introduction into the marketplace. EPA conducts a com-
prehensive inventory of existing chemicals and a prior notification procedure
for manufacturing new chemicals or existing chemicals for new uses, at which
time the agency may prohibit or regulate the manufacture, processing, distri-
bution, or use of a chemical.9
7. The Toxic Substances Control Act; An Overview of its Authorities and Major
Activities. EPA, 1979, p. 2.
8. The Toxic Substances Control Act; An Overview of its Authorities and Major
Activities. EPA, 1979, p. 2.
9. The Toxic Substances Control Act; An Overview of its Authorities and Major
Activities, EPA, 1979, p. 4.
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The authority to enforce TSCA requirements is primarily carried out by
EPA Headquarters with some activity at the regional level. Funding of TSCA
activities does not extend to the state and local level, except for a small
number of state projects financed under Section 28. Congress authorized
$4.5 million for three years for grants to states to assist them in designing
and implementing projects for the prevention or elimination of risks assoc-
iated with toxic substances for which EPA is unlikely to take action.
TSCA is one of the first federal laws to address the prevention of ser-
ious health and environmental problems associated with toxic chemicals in
our society. Other federal laws primarily enable the government to take ac-
tion only after widespread exposure and possibly serious harm have occurred.
TSCA provides for greater federal authority to control all aspects of toxic
substances and addresses gaps in control that previously existed.
Section 9 of the Act mandates that EPA coordinate the management of dan-
gerous chemicals across all federal authorities and programs. Serious ef-
forts to implement this mandate have focussed on interagency, international,
and inter-program cooperation. Coordination with, and among the states,
has nntil now been overlooked.
EPA is currently developing a comprehensive toxics integration manage-
ment strategy. Its aim is to "coordinate the toxic-related planning, re-
search, information collection, regulatory, and enforcement efforts at all
EPA's program and staff offices to ensure that resources are used most
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effectively."-^ The strategy is based on the following assumptions: ex-
isting aedia programs (air, water, resource conservation, etc.) need coor-
dination; the existing scheme of chemical regulatory programs needs a crit-
ical assessment; and physical, environmental and fiscal damages continue to
run a high risk of occurring in the absence of a more coordinated, compre-
hensive management strategy.^ Intergovernmental coordination will be a
new and important component of the strategy.
Elements and Benefits of Integrated Toxics Management
Development of a toxics integration strategy may not be the only frame-
work for achieving comprehensive management of dangerous chemicals. It does,
however, incorporate and balance key elements of a comprehensive environmental
management approach. Such a strategy requires:
the interlinking of environmental problems and program
activities as they relate to all media, all operations,
all products, all hazards and impacts thereof, all
levels of government and all relevant government agen-
cies and their functional areas of responsibility;
the infusion of more focused attention and activity in
the area of toxic substances control;
the fostering of a philosophy of long-term mitigation
and activities in support thereof, with regard to pro-
tecting human health; and
the balancing of the economic and health costs and bene-
fits of environmental control.
10. EPA Region V Integrated Toxics Strategy ... Where All The Pieces Fit.
p. 1.
11. EPA Region V Integrated Toxics Strategy ... Where All The Pieces Fit.
p. 2-3.
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A toxics focus in hazardous substances management accomplishes three
objectives:
it provides a common focal point around which all danger-
ous chemicals management activities can organize, and
provides a point of departure for enhanced interagency
coordination and cooperation;
it heightens awareness and activity in an area of danger-
ous chemicals management where little is known, yet sign-
ificant and perhaps irreversible damage to human health
and the environment is suspected; and
it provides for primary emphasis to be placed on the human
health effects of environmental contamination.
The potential benefits associated with adoption of such a strategy en-
compass the following:
cost savings through efficient coordination;
prevention of future harm to health and the environ-
ment;
promotion of coordination and cooperation within state
government and among federal, state and local govern-
ments; and
elimination of health effects information deficiencies.
The federal toxics integration strategy is in the early stages of devel-
opment. Twelve states are developing similar state-designed integration
strategies, with some receiving federal grant support under Section 28 of
TSCA to implement specific elements of their policy. Much remains to be done,
however, to mesh state and federal strategies into a nationwide comprehensive,
coordinated system.
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Purpose of This Study
This study and report were completed to assist state and EPA efforts to
develop coordinated toxics integration strategies. The EPA Office of Toxics
Integration (EPA/OTI) is interested in substantially strengthening federal-
state cooperative mechanisms for the control and management .of toxic sub-
stances. Designing a framework for federal-state cooperation and coordina-
tion depends heavily upon states' perspectives on their needs and potential
roles. In cooperation with EPA/OTI, the National Governors' Association's
Center for Policy Research undertook a three month review of state perspectives
on overall hazardous materials management, focusing on toxic substances to
support the development of this federal-state cooperative strategy.
At a .time when most of the states and territories are only in the ini-
tial policy development or planning stages of dangerous chemicals management,
this document is organized as a useful information tool for initiating manage-
ment information exchanges between states and between states and the federal
government. It also provides information for use by the EPA Office of Toxics
Integration in its effort to establish viable federal-state cooperative mech-
anisms to achieve coordinated toxics integration management.
/
The study focuses on managerial rather than technical or scientific
aspects of dangerous chemicals control. In broad terms, management consists
of:
the gathering of sufficient and accurate information and
its organization to enable problem and/or goal definition;
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the identification of all applicable resources;
the development of administrative structures capable
of using information and resources effectively;
the preparation and analysis of options for problem
resolution;
the choice of most productive options and the coor-
dination of organizational systems that implement
pieces of the ensuing effort;
the evaluation of their success and incorporation
of lessons learned into the management process.
Methodology
Initial exploration of state environmental management indicated that the
state of the art varies tremendously. Informed recommendations to OTI on how
to work more closely with states could only be developed after careful re-
search on each state's and territory's toxic chemicals control activities in the
context of its general approach to environmental management. State officials
were contacted when in D.C. and by phone, state-prepared written materials
were solicited, and recently published research studies on state activities
in environmental management were examined for general insight. Efforts were
made to probe each state extensively and develop descriptions and files on
each; however, time constraints precluded detailed inquiry in all states.
Because of the diversity of state management activities and to avoid inordin-
ate length of this report, we have summarized and compared state management
activities and highlighted unusual examples and innovations, rather
than describe 3^1 states and territories. A great deal more detail is on
file and available for review at the N6A Center for Policy Research. It
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should also be noted that our reconmendations are based on our findings and
expanded by our understanding of states' and territories' general needs de-
veloped from our continuous work with states in various arenas.
Through the process of gathering information from all states and terri-
tories, answers were sought to the following general lines of inquiry:
what environmental management strategies, orientations,
philosophies, or comprehensive policies prevail among
states?
in what ways are states organized to manage dangerous
chemicals as they affect human health and the envi-
ronment?
what management functions and activities are implemented
through the media, operation and product-specific en-
vironmental control programs, especially those related
to toxics control?
how do states achieve cooperation and coordination in
environmental management?
what prompts changes or modifications in environmental
management strategies, organizational structures,
management functions, and activities?
what are the states' perceptions of their problems,
needs, and priorities?
to what extent is toxics control integrated into the
state environmental management scheme, and how?
Initially, we reviewed relevant federal and state legislation and writ-
ten materials, extracting information on state management activities, com-
prehensive strategies, control mechanisms, tools, and organizational struc-
tures in overall environmental protection. We conducted intensive telephone
and in-person discussions with officials working on dangerous chemicals
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management in every state and territory. The governor's assistant respond-
sible for environmental issues was identified and contacted, as well as
officials of state environmental agencies and specific program offices. It
was not possible to administer a standard survey or set of questions to states,
because they are at different stages of development, have fragmented toxics
activities, and interpret terms variously. In order to obtain an overall,
accurate picture of each state and territory, it was necessary to talk with
3 to 9 officials in each and to examine a wide variety of documents (e.g.,
state/EPA agreements for 1980, state laws and regulations, state policy and
strategy papers, organizational tables, state environmental newsletters,
TSCA grant proposals, and executive orders). Preliminary written descrip-
tions of each state's and territory's dangerous chemicals management programs
were developed by NGA and then reviewed by a state official, usually the
governor's assistant for environmental matters.
An advisory committee, comprised of ten state officials especially in-
volved or interested in toxic substances control, was established and con-
vened twice to discuss project planning, preliminary findings and the scope
of specific concerns to be addressed.
In this study, the following specific areas of inquiry were excluded:
consumer products (other than pesticides) dealt with under the federal stat-
utes CSPA, FFDCA, FFA, and FXFRA, and radioactive materials. To the extent
possible, all other aspects of dangerous chemicals management were researched.
Technical and scientific aspects were explored only to the extent that they
affect management concerns.
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Report Content and Uses
This report consists of six main sections. An executive summary and
this introduction form the first two sections.
The third section describes current state environmental program frag-
mentation, authorities, executive office involvement, general state problems,
federal-state relations and problems, and state priorities. It concludes
with a description of key elements for a state integrated toxics management
strategy.
The fourth section is an analysis of states grouped according to their
stage of development with respect to five descriptors. These are: interagency
management practices, health effects monitoring and studies, information
gathering, computerization of data, and individual environmental or toxics
programs. Three groupings emerged and intergroup comparisons are made.
Section V describes illustrative state toxics integration management
strategies, noteworthy state legislation, and innovative or interesting
state chemical-related management programs. Descriptions of individual
state strategies, legislation, and programs are provided, together with
information on whom to contact for further details.
The sixth and final section provides contact information for key
environmental officials in states and territories.
We have not attempted to include all states' strategies or program
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innovations. Only chose that are relevant to the concept of toxics inte-
gration, or useful practices that have implications for enhancing cooperation
or coordination in the management of dangerous chemicals, are incorporated.
Throughout the project, governors' aides, state officials, and program
managers have expressed strong interest in the experiences of other states in
attempting to control chemical misuse. It is only through achieving the
greatest amount of communication among state and federal agencies that use-
ful know-how may be shared, that unnecessary, duplicative work can be avoided,
and greater coordination among all chemical management programs be obtained.
This report is descriptive,, rather than conclusive. It would have taken
far more time than that available to have made it so. Rather, it provides
initial background information, identifies and defines problematic areas,
outlines mechanisms for improved dangerous chemicals management at the state
level, and establishes the backdrop from which appropriate intergovernmental
can be designed for enhanced toxics management.
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III. THE CHALLENGE OF INTEGRATED STATE TOXICS MANAGEMENT
This section of the report describes current state perspectives on dangerous
chemicals management, and toxics control in particular. Findings are extrapolated
from comments and materials provided by states.
It should be noted that states often express general management frustrations
such as "we need more federal dollars," and "one of our major problems involves
coping with inflexible federal requirements." Such state perspectives should not
be taken lightly, as they are perceived as real constraints, the implications of
which must be creatively accommodated by any federal-state cooperative action plan.
Fragmentation in Toxics Management
The need to talk to several state officials and read a variety of state pre-
pared materials in order to obtain an accurate picture of state hazardous materials
and toxic substances management reflects the fragmented nature of current toxics
control strategies. In most states, no one respondent could provide a detailed
overview of the state's perspective and relevant hazardous materials management ac-
tivities. The governor's assistant in charge of environmental matters was usually
able to provide general information on whether or not the state has a comprehensive
strategy, statewide priorities, problems or concerns, some insight into the politics
of environmental control in the state, and names of additional state officials to be
contacted for more specific information. Individual program managers (e.g., air,
water, hazardous waste), then provided very detailed information, but only about
the media, operation or product specific program which he or she implements.
Fragmentation is also exemplified by the fact that states are generally reactive
when enacting environmental legislation or developing toxics programs. For example,
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in most states, extensive environmental legislation and programs have evolved pri-
marily as a result of two factors: environmental crises or incidents which have
generated the enactment of some level of environmental protection laws, and re-
action to federal mandates.
Reacting to crises, federal mandates, or alarming data does not always re-
sult in fragmentation. Our review, however, indicates that often it does lead to
ad hoc activities and short-term solutions.
In addition, toxics control activities undertaken by states to date appear to
have been prompted by at least one of three elements: severe toxics crisis situa-
tions; preliminary health-related research indicating higher than national average
incidence trends in diseases suspected of having causes rooted in environmental
contamination; and relatively sophisticated environmental monitoring producing
some alarming data on the extent of toxic pollution.
Terms and Definitions - Order vs. Confusion
State program managers have slightly different orientations toward defini-
tions and elements of environmental management. Water people talk in terms of
effluent discharges, priority pollutants, criteria standards and NPDES permits;
hazardous waste people discuss generation, disposal and manifest system require-
ments; air people use the terms effluent emissions, federally-designated air
contaminants, national ambient air quality standards, national emission standards
for hazardous air pollutants, and so forth. The new toxics manager is confronted
by a plethora of terms and concepts from which he or she must create order.
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INFORMATION PROCESSING SYSTEMS^
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A multitude of elements, terms, concepts and meanings used in different
environmental contexts makes it difficult to communicate with and oetween var-
ious state agencies. Most states conform their laws and programs to follow
definitions, concepts, and terms found in counterpart federal laws, regula-
tions and programs. Few states have attempted to cross reference or create
all encompassing definitions of hazardous materials or embrace "umbrella"
statutes outlining general pollution control elements of statewide environ-
mental management.
Most state environmental managers operate programs tailored to specific
media, operations or products, and hence may only need to master one or two
definitions, acts, regulations, and lists of regulated substances and the
relevant terminology. Few express concern over communication problems between
programs. We question, however, whether integrated environmental strategies
and comprehensive policies can be structured to cut across state agency pro-
grams without a greater degree of integrated terminology and cross-referencing
that could provide for enhanced inter-program communication.
State dangerous chemicals coordinators need to analyze how various state
program managers interpret laws, functions and terms differently, and then
must interrelate them in order to coordinate effectively. Management tools
that chart various definitions and commonly used terms and their interrelation-
ships would be useful for both federal and state toxics integration managers.
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Although an indepth examination of all the terns, concepts and elements
involved and their interrelationships exceeds the scope of this study, the
outlining of general components provides insight into comprehensive toxics
management .
Public administrators can take a very broad or very narrow approach to
what is involved in the management of hazardous substances, hazardous materials,
dangerous chemicals, or toxic chemicals. Dictionary definitions imply a very
broad approach toward dangerous chemicals management. For example:
hazardous substance: a physical material from which some-
thing is made or which has discrete existence (or matter
of particular or definite chemical composition) involving
or exposing one to risk (as of loss or harm) .
hazardous material; the element, constitutent, or substance
of which something is composed or can be made (or matter
that has qualities which give it individuality and by
which it may be categorized) involving or exposing one to
risk (as of loss or harm) .
dangerous chemical: a substance (as element or chemical
compound) obtained by a chemical process or used for pro-
ducing a chemical effect involving or exposing one to
risk (as of loss or harm) .
toxic chemical: a substance (as element or chemical com-
pound) obtained by a chemical process or used for pro-
ducing a chemical effect that is poisonous, i.e., that
through its chemical action usually kills, injures, or
an organism.
Note that dangerous is considered a synonym for hazardous and that the word
material is used in defining substance and vice versa.
It appears that dangerous or toxic chemical refers to a slightly more
specific type of harmful substance or material. Recall, however, that chemicals
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are siaply the 92 natural elements and the 12 man-made elements that form the
essence of life, and that anything can, in its broadest sense, be poisonous
depending upon the circumstances.
The most Important subtlety among the four terms lies in the hazard im-
pact on the health of living organisms. Hazards vary according to their tox-
icity (mutagenicity, teratogenicity, carcinogenic!ty), flammability, corrosivity,
reactivity, radioactivity, explosivity, and irritability. Each dangerous chem-
ical may be capable of causing any or all of these hazards at any time, depend-
ing upon the circumstances. The concept of toxicity implies hazardous effects
causing direct harm to living organisms through poisoning. This underscores
the importance of the goal of environmental protection, i.e., the explicit pro-
tection of living things from harmful exposures.
While flammable, corrosive, or explosive hazardous substances, materials,
or dangerous chemicals can kill, injure, or impair living organisms, their haz-
ardous effects are more external in comparison to the poisonous effects of toxic
substances that harm living organisms through oral, dermal or inhalation means.
A substance that ignites or explodes poses more of a short-term, immediate haz-
ard to living organisms, while a poisonous substance generally poses a more
long-term, elusive threat to living organisms .
For the purpose of this study we use hazardous substance, hazardous ma-
terial and dangerous chemical interchangeably within their broadest context.
The terms toxic chemical^ toxic substance, or toxic material refer to a subset
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having the distinguishing quality of posing the primary hazardous effect of
toxicity or "poisonousness" to living things.
Although all dangerous substances could be considered poisonous under
certain circumstances, primary hazard implications vary, i.e., the
primary hazard implication of substance X is toxicity whereas for substance
7 it is flammability. To the extent that adequate information exists for
various dangerous substances, a chart indicating primary and secondary haz-
ardous effaces would be useful as a first step in delineating environmental
management responsibilities. The U.S. Geological Survey's environmental im-
pact matrix is a good example of such a "decision-making" chart.
State Environmental Authorities
For the most part, all the states have authorities to carry out major
environmental control programs. State laws are mostly patterned after their
federal counterparts, with few exceptions. Where such exceptions were noted,
they are documented in the state groupings section and Section V. These ex-
ceptions represent aspects of state laws that vary somewhat from their federal
counterparts. Variations are for the most part relatively minor and usually
involve slight differences in definitions of hazardous waste, pesticide reg-
istration or use requirements, hazardous waste volume exemptions, and in the
setting of standards for air or water pollutants not federally-regulated.
Additional exceptions might be uncovered through a more detailed state legis-
lative analysis than time permitted. What appears to be a lack of creativity
in legislation may be attributable to two factors in particular; the tendency
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of states to react to federal mandates as opposed to being proactive often due
to a lack of time and resources; and the restrictiveness of federal mandates
that allows little room for creativity within the guidelines constituting "sub-
stantially equivalent authority."
Some states have "umbrella statutes" that outline general state authority
in several of the seven environmental control areas. Two examples in Oklahoma
and Illinois are described in Section V of this report. These are interesting
from the standpoint that they represent "integrative" tools in and of themselves.
They pull together various definitions and general requirements governing air,
water, hazardous waste management, among others, and cross-reference other
state laws providing authority for more specific environmental practices.
While umbrella statutes are not necessarily the only way to integrate
state toxics management, they can provide a "one-stop" reference to many state
environmental authorities for use by environmental coordinators who must often
keep abreast of several areas of concern. They can also eliminate the need
for individual laws for air, water and hazardous waste for example, allowing
for state regulations to delineate the specifics rather than having an air law
and a set of air regulations, a water law and a set of water regulations and
a hazardous waste law and a set of hazardous waste regulations. Perhaps legis-
lative reviews for overlaps, gaps and inconsistences would be better facili-
tated if umbrella statutes were used. In addition, functional integration ef-
forts such as one-stop permitting could be mandated in an umbrella act, as
opposed to using a separate law or executive order to support its use. A
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completely integrated strategy at the policy and operational levels, does not,
however, depend on umbrella legislation, although it nay be enhanced by such
means.
Several states have interesting laws which do not really parallel fed-
eral laws. Most of these laws are evidenced by Group X states and concern
information-gathering authorities. Examples include:
Maryland has a cancer reporting law whereby public or pri-
vate hospitals or institutional labs must report to the
Department of Health and Mental Hygiene every positive
tissue-based diagnosis of human cancer (note, law may be
amended to require reports be made primarily from the
hospital based tumor registries, excluding lab reporting
requirements);
Maryland also has a physician reporting requirement law
whereby clinics and hospitals are required to report
on poisonings or adverse reactions from drugs or toxic
agents;
California has a workplace carcinogen reporting act re-
quiring users to report worker exposure and use infor-
mation;
Virginia's TSIA and Connecticut's carcinogen statutes
are documented in Section V of this report.
Nearly all states considered their authorities to be comprehensive and
complete or will be so as soon as appropriate regulations are finalized to sup-
port the laws already passed. This is primarily true among states where federal
enforcement authorities have been assumed.
Only a few states felt the need to enact additional authority in order to
control toxics, i.e., authority other than that currently being sought or
-43-
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implemented by the states to enable assumption of environmental program enforce-
ment from the federal government. In several instances, states have passed
legislation imposing the legal notion of strict liability on hazardous waste
generators and disposers in order to shift the burden of proving negligence
in handling toxics from the individual/plaintiff to the industry/defendant.
With such legally imposed strict liability, the burden falls on industry to re-
fute the individual's claim that, if not for the industry's actions, the plain-
tiff would not have suffered damages (personal or property).
If any gaps exist in state laws, our review suggests that it is in the in-
formation gathering areas of chemical production and use, worker exposure, and
«
public health data such as cancer incidence or physician reporting requirements.
Other fhq" emergency health powers, most states do not have authorities to sys-
tematically gather health-related data such as cancer incidence, worker exposure
data, or physician reports of toxic exposure incidents. Other than hazardous
waste generation inventories and pesticide production/use information, most
states do not have explicit authority to systematically collect chemical pro-
duction/use data.
Governors and Executive Office Involvement
Most states reported that the governor is directly involved in hazardous
waste issues which, of course, have generated a great deal of public attention.
Less need has been seen, to date, for executive office involvement in overall
toxics management. A major exception, however, appears in five states which
report strong, direct governor's involvement in strategy development for inte-
grated toxics management. There is no doubt that the governor's involvement
has contributed to these states' progressive development in toxics integration.
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General State Problems
State environmental and toxics management are beset by a plethora of
technical, financial, organizational, political, and informational problems.
The compilation of comments received from officials in the 52 states and
territories is expressed in percentages. They are based on the number of
states out of all states that had at least one official report a particular
problem, rather than on the total number of officials responding. Not all
officials responded to the general question posed, "what are your state's
problems in environmental management and toxics control activities," and
specific problems were not referenced in questions posed to those queried.
Low percentages should not therefore be interpreted as an indication of the
lack of pervasiveness of a particular problem. Many officials pinpointed
only one or two pressing problems indicating that with more time and fore-
thought a detailed description of state problems could be made. Although
the method of obtaining a general picture of state management difficulties
and of quantifying specific problems mentioned for general comparison pur-
poses tends to deflate actual percentages, these percentages can provide
insight into areas to be explored in establishing federal-state cooperation
in toxics integration activities.
Technical Problems; The look of adequate technology and scientific
procedures to track sources of toxics contamination and to establish de-
grees of risk to humans and the environment is indicated as a problem by
twelve percent (12Z) of the states and territories, specifically in
regard to testing for surface, drinking and ground water contamination,
-45-
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exotics and instances of long-tern degradation as opposed to chemical spills.
The states view this as necessary to mitigate future occurrences of toxics
contamination, and generally reflects a need for better information on the
level of toxicity of chemicals entering state waters.
In addition, ten percent (10%) specify the task of special equipment
designed specifically to assess water quality and determine levels of con-
tamination as a difficulty. The expense of existing chemical detection equip-
ment and, in some cases, its non-existence are sited as prohibitive factors
for the states. Included under this category is the expense and lack of moni-
toring equipment, a resulting inability to do extensive chemical analysis, to
afford repairs and recalibrations for existing equipment.
Financial Problems; The lack of money to support administrative costs
is cited by thirty-eight percent (38Z) of the sample states. These adminis-
trative costs primarily include support of necessary personnel and equip-
ment to implement federal and state authorized chemical-related programs
(clean up of large chemical spills, inactive hazardous waste sites, and cases
of pesticide misuse).
The lack of a highly paid, specialized technical staff (epidemiologists,
industrial hygienists, laboratory analysts) is seen as a problem for fifteen
percent (152). In many cases, state salary restrictions under civil service
codes are the prohibiting factor in hiring and maintaining such highly special-
ized personnel.
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Approximately six percent (62) of the sample point to the look of funds
to support research, development and application of technical solutions needed
to help industry and local governments comply with environmental pollution
control requirements. Adequate funding for these needs is usually not pro-
vided to the state from state or federal appropriations. Available federal
funding is often plagued by the lengthy time period in receiving federal
dollars further hampering the state's ability to satisfy these technical
needs.
Procedural Problems; Laboratory backlogs (overloads) are indicated as
a problem by approximately six percent (6%) of the sample. The lack of time,
money and staffing to carry out the necessary amount of environmental sampling
and.monitoring is seen as hampering a timely, thorough analysis of possible
toxics contaminated samples.
Eight percent (82) also perceive the time and financial constraints in-
volved in training state epidemiologists in environmental health procedures
and problems as particularly difficult. Several states point specifically to
the lack of epidemiologists trained to assess and respond to the environmental
health impacts associated with chemical-related emergencies.
Regulatory Problems; The look of standards- for chemical contamination
is viewed as problematic for eight percent (82) of the states and territories.
The need for research and development activities especially to meet unique
state needs, and the data and time required to adequately develop these stan-
dards are indicated as integral components of this problem.
-47-
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Political Problems; Twenty-seven percent (27%) of the sample point out
the existence of 'Iccal political 'Hazardous i&zste problems in their states.
The lack of public awareness and environmental education programs are seen as
contributing factors leading to public opposition to siting of hazardous waste
disposal facilities and clean up activities. Additionally, several states
point to increased media publicity over toxics /hazardous waste incidents as
contributing to public outcries which make "rational" local government decisions
in the area more difficult.
Conflicts between states' need to protect the public and industry 's need
to develop resources, complicated by depleting resources present problems
for eipht percent (8Z) of the states and territories. States point to the diffi-
culty in accommodating constant pressure for economic and technical growth with
a depleting finite resource base, in addition to industry unwillingness to sup-
port pollution control programs (especially when industry is a controlling force
in the state legislature). One state in particular cited the problem of respon-
ding to a rapid increase in state resource development which negatively affects
the quality of the environment and requires a sharp increase in the state's
administration of environmental regulations.
Information Problems; The lack of access to and existence of medical
records necessary to monitor the human health effects of chemical exposures
within the state population is specified by fifteen percent (15 Z) of the
sample. This deficiency exists not only in the lack of collection of chemi-
cal exposure data by physicians and coroners filing medical and death reports,
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but relates also to the lack of systematic collection procedures for such
data. Several states indicate that the lack of awareness on the part of phy-
sicians and other medical professionals for the need to consistently record
and report the type of chemical exposure and illness-related information nec-
essary to do epidemiological research is a problem. Additionally, the lack
of access to industry worker medical records (often necessitating states going
to court to obtain such information in order to protect worker health and safety)
is seen as a problem for several states.
Eight percent (8%) of the sample feel that an inadequate labelling of
industrial chemicals poses problems in establishing safe use methods. Some
states point specifically to the packaging of chemicals and the labelling of
chemical waste containers, while others suggest that the general lack of ade-
quate packaging and labelling requirements leads directly to increased pro-
gram constraints by requiring more state testing and monitoring procedures.
Twenty-two percent (22%) feel that the look of Truman health effects data
presents severe problems in sufficiently controlling chemical exposures within
their states. Several states indicate that the non-existence of much needed
control data for specific segments of the population (children, pregnant wo-
men, regional inhabitants) results in program constraints such as the need for
additional time, money and specialized staff to gather and analyze this data.
Program-Specific Problems; Technical difficulties associated with the
disposal of hazardous waste are documented by forty-five percent (452) of the
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STATES' MAJOR PROBLEMS IN ENVIRONMENTAL MANAGEMENT *
Difficulties with hazardous waste disposal
Lack of money for administrative costs
Local political problems in hazardous waste siting
Lack of human health effects data
Lack of highly paid, specialized technical staff
Lack of existence of and access to medical records
Lack of adequate technology and scientific procedures
Lack of special equipment
Training state epidemiologists in environmental health
procedures and problems
Lack of standards for chemical contamination
Conflicts between states' need to protect public, and
industry's need to develop resources
Inadequate labelling of industrial chemicals
Lack of funds to support research and development and
application of technical solutions
Laboratory backlogs
23 states
20 states
13 states
11 states
8 stdtea
8 states
6 states
5 states
4 states
4 states I
4 states I
4 states
J
3 st.
3 at.
* summary of state/territory responses to question: "What are your state's problems in environmental mul toxics
-------
sample. These difficulties range from the general issues of lack of sites,
plans, clean up capabilities and alternatives for hazardous waste
disposal, to more unique state needs such as a high water table, insufficient
volume of waste to sustain a site, and the need for inventories and evaluations
of disposal needs.
Federal-State Relations and Problems
State toxics management cannot be examined without an analysis of state-
federal management relations. States were thus queried and a number of con-
siderations and problems identified.
The two major federal agencies working with states in toxics control
activities are EPA and DOT. Virtually all state agency environmental offi-
cials work in some respect with EPA (either out of Headquarters or the re-
gional office), although most direct state-EPA activity is carried out through
EPA regional offices. State-DOT relations are centered primarily around the
transportation of toxic substances, whether it be the Implementation of chem-
ical labelling and packaging requirements for interstate transport, setting up
enforcement systems, or responding to transportation-related chemical incidents.
Not all states or state officials indicated that a specific relationship,
positive or negative, exists between the federal agencies discussed below. An
attempt has been made, however, to document the general orientation toward re-
lationships that exist between the states and these federal agencies, and to
provide the primary factors states attribute to the nature of such relation-
ships. Percentages were again calculated and the caveats presented earlier
prevail herein as well.
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EPA-Stace Relations: Seventy-seven percent (77%) of the fifty-two
states and territories in the sample report good or satisfactory relations
overall with their respective EPA Regional Office. They attribute this pri-
marily to:
1) long-term working relationships developed betveen state
and regional office staff;
2) regional office responsiveness to requests for informa-
tion and assistance from states;
3) regional office understanding of unique state needs; and
4) frequent meetings or other forms of direct contact
between the states and regional offices.
Thirty-one percent (31%) report an unsatisfactory relationship with EPA
Headquarters. States attribute their disenchantment with Headquarters to a
feeling that federal staff do not know the state personnel responsible for im-
plementing state and federal programs* primarily due to the constant changeover
in personnel at Headquarters. The lack of direct federal contact with states
and the lack of federal responsiveness to state requests and unique needs are
perceived as contributing factors. Numerous states point to a need for more
practitioners (specifically enforcement and techncial personnel) as opposed
to lawyers at EPA Headquarters. And finally, states feel particularly con-
strained in carrying out pollution control programs as a result of conflicting
reports emanating from Headquarters and the regional offices, with the states
often unable to determine which are official policy statements.
DOT-State Relations; Overall good working relations with regional DOT
offices are reported by seventeen percent (172) of the sample, primarily
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attributed to the same factors responsible for the positive relations between
states and EPA Regional Offices - long-time working relationships, understand-
ing of unique state problems and needs, regional office responsiveness to state
requests and frequent meetings.
States discussing their relations with DOT indicated infrequent, although
generally satisfactory relations with DOT Headquarters. Apparently there is
not a great need to work directly with headquarters staff implying that DOT
Regional Offices are able to meet states' needs appropriately.
Additional Federal-State Relations: States indicating a specific working
relationship with the federal Occuaptional Health and Safety Administration
(OSHA) are primarily either very positive about OSHA's responsiveness to
state problems and needs, or very negative. Those states indicating posi-
tive relations point to OSEA technical staff as extremely responsive to state
requests for information on standards and testing procedures. Those states
reporting negative relations are generally disenchanted with the extent of
OSHA activity in the state that is duplicative of existing state program
activities and critical of OSHA's orientation toward protecting worker health.
In their view, OSHA seems overly attentive to citing industry violations and
not attentive enough to collecting worker exposure data or providing technical
assistance for correcting cited violations.
In addition, several states report good relations with other federal
agencies such as FEMA (on emergency matters), OSDA (pesticides), and EHS (FDA).
These agencies, however, are seen as operating within the states basically in
response to specific problems, often emergency-related.
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Attitude Problems: Look of federal consideration for unique state needs
c&d p?cbl&xs is cited by seventy-seven percent (772) of the states and terri-
tories. Specifically, the perception that federal legislation, regulation,
and prescribed implementation procedures do not allow for enough flexibility
from state to state is cited by fifty-two percent (522) of the states. In
particular, they referred to the narrow orientation of national legislation,
detail, of procedural requirements, lack of local orientation, centralization
of power in EPA Headquarters, resulting discouragement of state innovations,
and lack of time and funding to assure proper interpretation and administration
of regulations. Ten percent (102) of the fifty-two states and territories see
a lack of consideration on EPA's part over the practical implications of im-
plementing a regulation in a particular state or territory as a major concern.
Forty percent (40Z) view EPA as .maintaining a blanket expectation that states
will Implement rules and regulations developed by EPA exactly as told, regard-
less of the states' lack of staff and funding. Eleven percent (112) of the
total sample view EPA as too strict in its oversight of procedural guidelines
for state implementation of federal mandates, rather than focussing its con-
cern on achieving the final results of human health and environmental protec-
tion. In addition, federal overregulation of activities leaving little room
for state creativity is Indicated as another aspect of inflexibility.
Coordination Problems: The overlapping, fragmentation^ and vagueness
of interpretation of federal authorities is Indicated as a problem for twenty-
nine percent (292) of the states and territories. The inconsistencies, com-
plexities, and confusion in federal toxic control authorities is viewed as
presenting difficulties in the private sector as well as state and local
-54-
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government, and is seen as fostering and reinforcing state fragmentation re-
quiring additional staff and money to keep up with these complexities. Speci-
fic examples cited by states include: EPA's indefinite interpretation of re-
gulations making state implementation difficult; varied and confused EPA dir-
ectives; overlapping transportation-related responsibilities between EPA and
DOT; and a hazardous waste definition that does not include hospital, labora-
tory, and mining wastes.
Fifteen percent (15%) view the federal authority to control toxics as
adequate, but field implementation is not. This is seen primarily as a result
of a lack of coordination between EPA Headquarters and its regional offices.
Fifteen percent (15%) also see a coordination problem in the excessive
amount of federal paperwork, where program planning and reporting requirements
are often duplicated. The paperwork involved with federal-state grants is
cited specifically by several states in this group.
Proeedurual Problems; Twenty-five percent (25%) of the states and terri-
tories see no true partnership existing between themselves and EPA. A lack of
EPA consultation with states prior to proposing and finalizing regulations is
disconcerting to states. Often, EPA comes out with regulations after states
have submitted program plans in response to prior rules necessitating exten-
sive state revisions that cost the state in time, money and other resources.
In addition, several states indicate specific problems such as the lack of
federal responsiveness to states attempts to participate in rule development,
a lack of federal trust of states' abilities, and a feeling of token delegation
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MAJOR STATE-FEDERAL PROBLEMS IN ENVIRONMENTAL MANAGEMENT *
Ul
T
Lack of federal consideration for unique state
needs and problems
Not enough flexibility for state Implementation
of federal legislation and regulations
EPA's blanket expectation that state implemen-
tation will mirror federal rules, even though
states lack staff and funds to do so
Overlapping, fragmentation and vagueness of in-
terpretation of federal authorities
No true federal-state partnership
Federal rulemaklng slow, restrictive, arbitrary
Adequate federal toxics authority, but Inade-
quate field Implementation
Excessive amount of federal paperwork
Overstrict EPA oversight on procedures vs result
of human health and environmental protection
Lack of appreciation of practical Implications of
state Implementation of EPA environmental regulations
federal duplication of state activities
Unfavorable federal funding time schedule
EPA headquarters enforcement of notices and memos as
If they were regulations (sporadic)
40 states
27 states
21 states
IS states
13 states
9 states
8 states
8 states
6 states
5 states!
3 at
3 st
-------
of authority to states from EPA.
Seventeen percent (17%) view the federal rule-making process as too slow,
restrictive and arbitrary. States find difficulty in having to wait to develop
their rules, regulations and plans, thereby allowing industry to wait to cor-
rect acknowledged problems.
Federal duplication of state activities is viewed as a problem by six
percent (6%) of the sample states and territories. Especially noted in this
context is the duplication of field investigations by the federal government
resulting in industry annoyance, which is in turn conveyed to state and local
government officials.
Six percent (6%) also see the federal funding schedule as not favorable
for the states. The states indicate that by not receiving federal program
funding at the start of the fiscal year, due often to OMB and Congressional
delays, the states are left with the responsibility of administering programs
without federal monies during the time lag. This often requires states to '
borrow money to compensate during this period, and ultimately results in in-
creased program costs.
Six percent (6%) cite EPA Headquarter's enforcement of notices and memo-
randa as if they were regulations as restrictive. Additionally, this is done
with no set pattern resulting in confusion for the states.
Another six percent (6%) see the federally imposed timetable for
-57-
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cxinc rrocrCT sontrol as too quick, not allowing for consideration of individ-
ual state problems and needs. Such timetables rarely, for example, take into
account the fact that in some states the legislature (which must approve state
programs) meets only once every two years.
State Priorities and Needs
At the present time, many states indicate they need assistance targeted
for certain environmental programs to attain levels of competency they con-
sider adequate to address respective priorities. Nationwide, they cite the
following major program areas as in need of prioritized assistance: hazardous
waste management (63Z), emergency preparedness (27%), clean water (172)-, en-
vironmental epidemiology and toxicology (17%), technical training (13Z), and
pesticides (10Z). More specific state needs for improving these priority'
program areas are discussed below. In addition, states have informational,
technical, financial, legislative, and procedural priorities and needs that
relate to many program areas. Percentages were again calculated and caveats
discussed earlier prevail herein as well.
Program-Specific Priorities and Needs; Twenty-seven percent C27Z) of
the states and territories in the sample specified as a priority the develop-
ment and implementation of chemical-related emergency mitigation and response
plans and training programs for local government and on-scene officials. Sev-
eral states specifically indicated the need for county level emergency response
-58-
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plans, a. stacs-federal inceragency energetic}* response team, as veil as equip-
ment and chemical handling training programs.
Seventeen percent (17%) of the sample place priority status on increas-
ing emphasis on toxics contamination of state waters through increased assess-
ment, monitoring and control activities. Ground, surface and drinking water
supplies are included in this broad category, with states indicating the need
to develop control plans and state regulatory authority, and to improve co-
ordination of programs for preventing and responding to chemical spills into
state waters.
Another seventeen percent Q.7%) see a distinct need to increase capa-
bility and activity in the epidemiology and toxicology fields. States see
this occurring through the development of testing procedures to determine
human health effects of chemicals, the correlation of cancer incidence data
with state chemical production data, the increase in integrated toxics strat-
egy funding, and the expansion of the state industrial hygiene staff.
The need to increase hazardous waste management activities is singled
out by sixty-three percent (63%) of the sample. These activities include:
siting PCS disposal facilities, determining the effects of toxic wastes, cleaning
up abandoned sites, inspecting existing sites for compliance, setting up a na-
tional manifest system to track hazardous waste disposal, and developing, im-
plementing, and upgrading the state programs to comply with the Resource Con-
servation and Recovery Act (RCRA) .
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The ccr.-tixusd rxmitaring and sduczticnzl sxstesis or. prepay pes~ioid£3
use to minimize environmental and human health risks is seen as a priority for
ten percent (10S) of the states. Several indicated the particular need for
increased chemical testing of pesticides and the maintenance of existing
pesticides programs.
Information Priorities and Needs; Six percent (6%) of the states and
territories in the sample indicated as a priority encouraging counties and in-
dustries to prepare chemical inventories of local manufacturers, users, trans-
porters and storers of chemicals/hazardous materials. Included in this pri-
ority is the encouragement of county level procedures for identifying sources
and testing techniques for chemical exposure.
The integration of scientific, technical, economic and social informa-
tion in the planning anrf development of regulations, and the development of
a nation-wide chemical information sharing system are designated priorities
of eight percent (8Z) of the states. The priority for integration includes
timlti-disc^.pl'tTifffy anj multi-agency coordination and the development of re->
source sensitive environmental control strategies.
Technical Priorities and Needs; Twelve percent (.122) of the sample
specified the need to develop waste reduction alternatives such as recycling,
detoxification and resource recovery as important. These states are looking
to develop methods of handling hazardous vaste through other than traditional
land disposal siting mechanisms.
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STATE PRIORITIES AND NEEDS FOR ICNV IKONKliNTAh MANACEMKWT
Increase hazardous waste management activities
Development and implementation of chemical-related
emergency plans and training programs for local officials
Increase emphasis on toxics contamination of state waters
Increase capability and activity in epidemiology and
toxicology
Increase present amount and extent of training for
chemical control officials
Develop waste reduction alternatives
Continued monitoring and education emphasis on proper use
of pesticides
Integration of scientific, technical, economic and social
data and development of nationwide chemical information
sharing system
Encourage counties and Industry to prepare inventories
Increase funding or realign priorities to satisfy need for
more epldemiological studies
33 states
13 states
9 states
9 states
7 states
6 states
5 states
4 st.
3 st
3 st
* Summary of state/territory responses to question: "What are your state's priorities and needs for EnvJronmental
and toxics management?"
-------
Financial Priorities and Needs: Of the fifty-two states and territories
in che sample, six percent (6%) indicate the need to increase flooding c? re-
align priorities to satisfy the need for more epidemiological studies. In-
cluded in this priority is a specific attempt to increase the industrial hy-
giene staff to monitor and test for chemical exposures in the workplace.
Legislative/Regulatory Priorities and Needs; Among the diverse legis-
lative and regulatory priorities being addressed by the states and territories,
the attempt to increase the punative impact of fines for hazardous vaste vio-
lations through increasing fines or criminalizing disposal violations is specif-
ically cited by several states.
Procedural Priorities and Needs; Thirteen percent (132) of the sample
stated a need to increase the present extent and amount of training for chem-
ical control officials in their states and territories. Training in this
category Includes such areas as transportation enforcement, pesticide control,
and general technical training for chemical monitoring, investigation and ana-
lysis .
Integrated Toxics Management
Managers of integrated toxics control programs must ensure that funda-
mental components exist and are effectively coordinated. These include: media,
operations, products, impacts, hazards, and management functions.
Hazardous substances threaten the environment and living organisms
through four media air, land, water, and workplace. Although workplace is
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r.ct usually referred co as a medium, and actually encompasses the other three
r.edia, we label it as a separate medium because of its importance as a closed
environnent in which people are likely to have closer, more prolonged exposure
to potentially dangerous chemicals.
Qperaticps refer to the extraction, generation or production, processing,
use or reuse, handling, labelling, transport, sale, import or export, storage,
and disposal of hazardous substances.
Products refer to raw materials, intermediate products, catalysts, final
goods, by-products, and waste of which hazardous substances may form part or
the whole.
The impacts of dangerous chemicals include emissions (air) , discharges
(water) , leaching (land) , and exposures (humans and animals) .
It is through the impacts on living organisms and the environment that
hazards are created, i.e., toxicity (oral, dermal, inhalation), flammability,
corrosivity, reactivity, radioactivity, explosivity, or irritability.
The key Tnanagtypient components of dangerous chemicals control include :
management strategies; general policy, orientation or
philosophy underlying all environmental control pro-
grams and activities, providing a point of departure
for coordination and cooperation among state agencies
and between state and federal agencies;
organizational structures: frameworks within which the
strategies operate;
-63-
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management functions: activities that design, imple-
ment and evaluate the strategies within the organiza-
tional structure. These encompass coordination,
planning, passing laws and regulations, funding, reg-
istering, licensing, permitting, certifying, training,
educating, responding to emergencies, sampling, citing
violations, prosecuting violators, research and de-
velopment;
management tools; resources such as meetings, HPA/state
agreements, interstate and local mutual aid agreements,
memoranda of understanding, laws and regulations, policy
papers, executive orders, official planning or strategy
documents, technical reports and experts, funding mech-
anisms, managers, personnel (private and government),
and materiel.
The concept of disaster or emergency within environmental management is
vitally important. The processes involved in the prevention or reduction of
(known as mitigation), preparedness for, response to, and recovery from all
types of disasters represent the essence of all government schemes to protect
life and-property. Dangerous chemicals emergencies and disasters involve pro-
tecting the environment either from high impact emissions or from general,
long-term degradation as a result of long-standing, pervasive pollution.
Environmental disease, unlike communicable disease, has its roots in man-
made occurrences. Like all other types of man-made and natural disasters, envir-
onmental disease possesses short and long-term implications which must be miti-
gated, prepared for, responded to, and recovered from. The understanding that
environmental disease possesses short and long-term emergency implications
remains primitive, largely due to the lack of advanced scientific and
medical knowledge of the linkages between environmental contamination and the
health of living organisms.
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N'oc only must managers conceptualize and act on short-term environmental
emergencies such as spills and accidents, but they must also conceptualize and
act on long-tern environmental disease and contamination problems as if they
were potential emergencies. The cancer "epidemic" caused by chemical contam-
inant X twenty years from now may. not seem like an emergency or crisis situation
now; however, if not considered today, potentially irreversible damage may occur
for which no late emergency response plan can provide relief. Long-term health
implications as well as short-term accident suppression are both vital aspects
of environmental emergency management.
Integrated management of hazardous substances therefore, involves the ele-
ments of media, operations, products, hazards and impacts thereof, for which
management strategies, organizational structures, functions and tools are de-
vised so that government can mitigate, prepare for, respond to, and recover
from human health and environmental degradation in the short and long-tans. A
"comprehensive" toxics strategy implies the integration of the above and the
encouragement of management practices that focus attention and action on toxic
substances with explicit implications for the ultimate protection of the health
and well being of living organisms.
The following chart may be useful to environmental managers to identify
and locate some of the most pertinent dangerous chemicals management functions
throughout the state and evaluate the extent to which they are, or should be
integrated throughout each of the four environmental media.
-65-
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IV. STATE GROUPINGS
Analytical Descriptors
In order to determine approaches involved in building a toxics integra-
tion strategy, which states are progressing toward that end and their relative
progress, the implied needs of states in. managing toxics, and in order to sug-
gest state and federal activities for enhanced toxics integration, five de-
scriptors, or management factors were identified and each state was thereby
examined. This enabled the grouping of states into three broad management
categories, as well as intergroup contrasts and intragroup comparisons.
' The five factors are: interagency management mechanisms; health effects
monitoring and studies; information gathering, computerization of data, and
individual environmental or toxics programs. These consist of:
Interagency Management Mechanisms; activities designed
to foster coordination, cooperation and communication
among all relevant environmental agencies, and the in-
tegration of like programs and activities among them.
Three basic mechanisms emerged: formal, permanent
cormitteeSj commissions or processes; ad hoc tempor-
ary task forces; and functional integration.
Health Effects Monitoring and Studies; necessary for
the identification and targeting of toxics control
needs. We looked at whether states engage in epi-
demiological studies, toxicological investigations
or other health effects research. In addition, we
examined whether states are systematically collect-
ing occupational or public health data that could be
used to monitor disease and illness trends possibly
rooted in environmental pollution (e.g., cancer or
birth defects monitoring) and other data useful for
epideniological research.
Information Gathering; concerning dangerous chemi-
cals production and/or use (e.g., hazardous waste
generation inventories, pesticide use information,
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chemical manufacturing and use inventories). This
type of information gathering is differentiated from
environmental monitoring as all states collect air
and water quality data, and health effects data re-
viewed as part of factor #2.
Computerization of Data; involves the extent to which
states computerize or are planning to computerize any
dangerous chemicals related data (e.g., chemical pro-
duction/use data, hazardous waste reporting require-
ments data, environmental health data, and monitoring
data). We also examined whether states are using
federal or private computerized data bases or are
planning to do so.
Individual Evnironmental or Toxics Programs: this
factor concerns the examination of state activities
in implementing seven major environmental control
programs clean air, clean water, safe drinking
water, hazardous waste, pesticides, transport, and
occupational health and safety. We assessed where
each state stands in relationship to others, and in
relationship to achieving federally delegated au-
thorities, i.e., assumption of basic enforcement re-
sponsibility. Although, the federal government is
adding more requirements for which the states are
being asked to assume enforcement responsibility,
we limited the examination to relative state progress
in assuming basic responsibilities and not the addi-
tional delegations. For example, highly developed
states with regard to RCSA would be those that have
reached the stage of applying for interim authori-
zation from EPA; for the clean air program, highly
developed states are considered those that have
assumed enforcement responsibility for the federally
designated air contaminants but not necessarily the
PSD or auto emissions components. The level and ex-
tent of concern manifested by specific activities
for eontrolling toxics programs is also a major con-
sideration in analysis of this factor.
The analysis of state practices according to these five factors yielded
the Impression that states fall within three basic categories we designate as
"Group X, Y and Z States." Although there are overlapping areas where a state
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slight easily be placed in one group or the other, and ic should be remembered
that each state is unique, their broad grouping facilitates analysis of their
needs and subsequent design of viable federal-state action plans for integrated
toxics management.
Group X States
This section examines Group X states according to the five factors de-
lineated above. States that can be characterized by the following description
include Arkansas, California, Illinois, Maryland, Michigan, New Jersey, New
York, North Carolina, Oklahoma, Puerto Rico, Virginia and Wisconsin.
1. Interagency Management Mechanisms: Toxics integration strategies
and use of a permanent committee^ acrmission oz> prcasss to implement the
strategies characterizes the twelve Group X States. The strategy and the
structure ensure that:
environmental problems and activities are integrated
among programs, agencies, and governments;
attention is focused in the area of toxic substances
control, and systematically incorporated into over-
all environmental management;
a long-term, mitigative philosophy is fostered with
emphasis placed on protection of human health;
the costs and benefits of controlling the manufact-
ure, use, transport, and disposal of toxic sub-
stances are actively considered.
Details of each strategy are documented by state in Section IV. A brief
comparison of the strategies, however, is useful here in order to understand
how they are implemented at the state level and what aspects are important with
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regard co development of a toxics strategy. Although strategy approaches vary
among the states, we can compare their status of development, degree of official
support, coordinating mechanisms used, and the cornerstones of each strategy.
Status of Development: Arkansas, California, North Carolina, Oklahoma,
and Puerto Rico are in the initial planning and/or early stages of development,
having been involved in toxics integration work for approximately one to two
years. Illinois, Maryland, Michigan, New Jersey, New York, Virginia, and Wis-
consin have more firmly institutionalized the strategy within state government
operations, having been involved in toxics integration work for two to three
years. This latter group of states recognizes, however, that further develop-
mental work is necessary in order to elaborate already existing features and
expand strategy activities to include more sophisticated elements.
Degree of Official Support: Arkansas, California, Maryland, Michigan,
New Jersey, North Carolina, Puerto Rico and Virginia receive strong and direct
support from the Governor. In most cases, it was through the Governor's exec-
utive order or directive that the strategy took form. The other state strate-
gies receive indirect support from the Governor's office, i.e., through is-
suance of executive orders in support of certain strategy elements, signing
off on budget amounts or pushing for specific pieces of legislation in support
/
of strategy elements. In addition, New Jersey and Maryland reported strong
support for their strategies on the part of the state legislature.
Coordinating.Mechanism; Three types of coordinating mechanisms emerged
from the comparison Type I; Interagency Committee or Council;-Type II: Line
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Agency or Program; and Type III: Combination of Interagency Conmitree and
Line Agency/Program.
States using Type I mechanisms include: Arkansas (.Toxic Substances and
Hazardous Materials Policy Committee), California (Toxic Substances Coordina-
ting Council), Maryland (Council on Toxic Substances), North Carolina (Incer-
agency Coordinating Committee), and Virginia (Toxic Substances Advisory Coun-
cil).
These interagency committees or councils consist of state agency repre-
sentatives covering the environmental areas of air quality, surface and drink-
ing water quality, hazardous waste, pesticides, transport, public and occupa-
tional health (medical and environmental health orientation), economic or in-
dustrial development, emergency services, natural resource development, and
laboratory services. Some noteworthy variations to these include: Maryland's
Council includes representatives from the state planning agency and state
legislature, labor, business, academia, and medical professions; North Caro-
lina's Committee includes representation from the state planning agency and
state justice department; Virginia's Council includes five governor-appointed
citizens from the fields of agriculture, medicine, labor, industry, and local
government.
The principal role of these committees or councils involves providing
overall coordination and clearinghouse services for those agencies and their
programs implementing integral parts of the strategy. Duties usually include
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all or a. combination of the following: devising tools for enhancing integra-
tion and unification of environmental management functions where appropriate;
providing a forum for increasing communication and information sharing on a
regular basis; advising the Governor and state legislature on toxic control
problems and making recommendations for changes; promoting long range planning
initiatives; providing guidance to specific toxics related programs; networking
with all relevant state government units, local government, federal agencies,
private industry, public interest groups, and the general public; ensuring
that economic impacts of actions are considered; planning, designing, and en-
suring Implementation of policies, procedures and organizational arrangements
appropriate for the strategy and reviewing them as needed. For specific toxics
issues, committees or councils usually create subcommittees out of their mem-
bership or by drawing from other state agency personnel as appropriate. Line
agencies and operational units carry out the strategy activities on a day to
day basis and feed back problems and concerns to the council or committee.
States using Type II mechanisms include: Illinois (Environmental Tox-
icology Program), New Jersey (Program on Environmental Cancer and Toxic Sub-
stances and the Office of Hazardous Substances Control), New York (Office of
Toxic Substances), and Wisconsin (Environmental Epidemiology Section).
These line agencies and programs are charged with providing overall co-
ordination and leadership for the development and implementation of the strat-
egy and maintenance of ongoing flow of communcations with other operating units
involved in carrying out the strategy activities. They operate as a focal point
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within the scats bureaucracy for interaction with federal agencies, industry,
citizens, and the research and medical community involved in toxics. These
agencies and programs have day to day operational responsibilities in toxics
control as well.
Type III seehanisms are used by Michigan (Toxic Substances Control
Commission consisting of non-state personnel appointed by the governor and
the Office of Toxic Materials Control); Oklahoma (Pollution Control Coor-
dinating Board made up of state representatives covering a wide range of en-
vironmental areas of concern and the Environmental Epidemiology Service); and
Puerto Rico (Interagency Hazardous Waste Task Force consisting of state repre-
sentatives from various environmental program offices and the Solid and Haz-
ardous Waste Office).
These states use a combination of Type I and Type II mechanisms. The
policy commission/board/task force makes recommendations to the governor and
state legislature on problems and organizational or legislative changes needed.
The line agency/program, however, provides a central point of contact for day
to day activity implementation ensuring that there is an inter-disciplinary,
multi-media, and multi-agency approach among operating units involved in the
environmental and health aspects of the toxics strategy.
Strategy Cornerstone; Cornerstones are the key elements or activities
upon which the strategy focuses at the present time. Although in general all
Group X states engage in all the listed cornerstone activities, among many
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others each state appears to place greater emphasis on one or two elements
in particular. The cornerstones provide us with an image of each state
strategy by which we can pinpoint those developing expertise in one area or
another.
Arkansas emphasizes the establishment of a framework for decision making,
i
prevention and control upon which deverse activities of participating agencies
can be coordinated and focused consistent with existing expertise, resources,
and statutory authorities. Fostering inter governing" tal coordination and co-
operation, establishment of information management systems, monitoring and
assessment of environmental and public health trends, designing prevention
and control programs, and improving crisis response capabilities are key areas
of involvement within the framework;
California's cornerstone is two fold: reducing the overall use of toxics
and waste generated from toxic materials and enhancing state clean up capa-
bilities to minimize health and environmental risk of accident. The state
stresses Information exchanges, use of penalities for violations and provid-
ing incentives to industry for gaining compliance in the overall effort to
control toxics;- .
The development of two-way communications networking among state and
federal environmental and health agencies, the research and academic com-
munity, physicians, hospital administrators, and other health professionals
constitutes the backbone of the Illinois strategy. The goal is to enhance
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coordination and increase the probability of early warnings of inninent en-
vironmental health problems based upon a comprehensive program of environ-
mental health and epidemiology;
Maryland's strategy cornerstone involves a preventative disease control
program for minimizing occupational or community exposures to industrial re-
lated hazards based on the expertise of an investigative unit and consul-
tation service utilizing teams of medical, nursing, industrial hygiene, and
epidemiological personnel. Core activities include field diagnosis of health
hazards posed by emergency incident exposures, high risk population epidem-
iological studies and the monitoring of illness and disease trends (e.g., can-
cer registries and other reporting tools);
Maintenance and updating of the Critical Materials Register and the de-
velopment of an Air Priority Chemical Register characterizes the strategy
cornerstone of Michigan. The gathering and analysis of chemical production/
use, discharge/emissions and health hazard data provides the springboard for
state agency work in controlling dangerous chemicals.
The cornerstone of New Jersey's strategy is two-fold: information ga-
thering and analysis based on extensive monitoring of toxics in the various
media and chemical inventory materials; and the development and improvement
of testing, sampling and chgnrical screening protocols.
North Carolina's cornerstone involves the development of an interactive
computerized management information system integrating diverse types of
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information including chemical production/use, environmental quality, aoni-
coring, and population/demographic data, and the incorporation of federal
and private computerized data bases.
New York emphasizes the development of technical procedures (e.g., test-
ing, sampling and screening protocols) that will enhance its environmental
aonitoring program and which will have state-wide applications for locating
past and present sources of toxic substances contamination, assessing their
impacts and developing management techniques for their control. Development
of techniques especially suitable for local government application is of
particular importance;*.
\
Oklahoma's cornerstone centers around the environmental epidemiology
program and its two basic component activities: assisting persons accidently
contaminated by toxics in the home or workplace, especially for major emer-
\
gency/accident situations warranting advice on potential human health haz-
ards; and analyzing environmental health data through epidemiological tech-
niques; ,
Puerto Rico emphasizes the designing of its strategy to support the
prevention of the occurrence of major pollution problems, the mitigation of
future crises that may result from environmental trends in environmentally-
related diseases and the institution of management mechanisms for the ex-
peditious hand n rig of health and environmental emergencies when they cannot
be prevented; %
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Virginia's strategy cornerstone involves the collection of chemical
production/use information, its evaluation in relationship to health hazards
and its dissemination to industry and the general public;
Health effects surveillance and environmental epidemiology constitute
the key components of Wisconsin's strategy. The state's indepth case study
of formaldehyde vapor problems through use of epidemiological techniques may
provide protocols for other similar investigations.
The five states whose strategies are in the early developmental stages
and the seven states that have stronger strategies in existence vary in their
,'
needs. The former could use concrete suggestions as to how to operational-
ize strategy elements already designed and how to design those only planned.
The latter group have gained insight from more practical experience. Their
lessons learned could help the former states in their plans. The latter
states could benefit from tools to evaluate the effectiveness of what has
been done so far.
Official support for the strategy seems to be an important element es-
pecially with regard to the governor's office. Building a strategy and ad-
ministrative structure to carry it out is a management-oriented activity as
opposed to line item programs and activities for which support is usually
present in the legislative branch. How the strategy is funded was not a
direct area of inquiry. It appears, however, that financial support is pri-
marily for actual projects or program activities as opposed to the strategy
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itself or the coordinating mechanisms which are more often supported through
staff tine devoted by agency personnel having other day to day environmental
responsibilities. This may be an advantage as the line agency/program element
probably receives a line item appropriation from the budget. Only two states
reported direct support for the strategy from the legislature. In addition,
only one state has state legislators as members of the coordinating committee.
This may be an area for exploration on the part of the other X states.
The various coordinating mechanisms apparently have wide representation
from a variety of state agencies concerned with toxics control. As toxics
problems touch so many agency activities with many of them not even realizing
it, it is of great importance that broad representation exist so that all
angles of toxics control can be explored in an organized, regular fashion.
Importantly, these strategy states clearly recognize the need to integrate
environmental and health concerns. Their coordinating mechanisms and various
toxics activities are evidence of this.
In addition, these strategy states Include representation from indus-
trial and economic development and natural resource development state agen-
cies. Toxics control activities are often at odds with the promotion of
economic and industrial growth. Input from the agencies concerned with these
elements is vitally important for cohesive policy development and implemen-
tation. Balancing of economic development and environmental protection needs
can potentially be better addressed when the responsible agencies are regu-
larly brought together to learn and understand their various perspectives.
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Inclusion of the emergency services personnel is important as they need
to be aware of the long-term hazard implications of toxics contamination and
emergency health concerns of hazardous materials incidents that go beyond the
scope of emergency medical services.
Representation from state planning agencies is conspicuously missing in
all but two states.- Given the fact that long-range planning is an element of
toxics strategy, the planning personnel could provide valuable input.
Intergovernmental coordination between state and local levels needs to
be fostered in an integrated strategy. Few of the coordinating mechanisms
evidence local government representation, although they usually function as
a focal point for interacting with local government agencies. How this is
actually accomplished on an operational level remains to be determined. The
same is true for integrating activities with the federal government. Al-
though X states are working toward these ends, information flows among state-
local and state-federal counterparts do not seem clearly defined. Group X
.States, however, have instituted within their organizational structures a
formal, centralized entity through which toxics information can flow between
and among the three governmental levels - local, state and federal.
With regard to ad InoQ, temporary task forces> many of the Group X States,
especially Type I states, use subcommittees formed from membership of the co-
ordinating mechanism, rather than miscellaneous task forces for studying specific
issues such as economic impact, health effects and toxic waste. As such, their
formation can occur in an orderly structured manner.
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Although in general, these states are not characterized by a prolifera-
tion of ad hoc task forces, some do exist. They tend to focus on very specific
component parts of toxics control, and while not falling under the direct
auspices of the coordinating mechanism as subcommittees do, they are geared
toward coordinating with the overall toxics committee or council. Some are
organized through the governor's office (mostly those concerned with hazard-
ous waste issues), while others are organized for intra-departmental concerns.
Some are only made up of a small number of state officials, while others are
solely made up of citizens from the private sector - industry, business, pub-
lic interest groups, the general public. Several interesting ones follow:
Maryland's Hazardous Substances Advisory Council is composed of repre-
sentatives from the Department of Agriculture, University of Maryland, De-
partment of Licensing and Regulation, Department of Health and Mental Hygiene,
as well as representatives from the hazardous waste industry and two public
citizens. This Council makes recommendations as to what substances should be
designated as hazardous and listed for the purpose of hazardous waste and
transport regulatory action pursuant to the state Dangerous Substances Act
of 1976;
Arkansas's Technical Advisory Committee on Hazardous Waste Management is
independent of the Governor's office and state bureaucracy and is composed of
industry representatives, university officials,.a mayor, and an attorney. The
Committee examines state functions in hazardous waste management, delineating
them and recommending ways to enhance their coordination as well as making
recommendations on laws and regulations for hazardous waste management;
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Michigan's Grouudwater Enforcement Task Force is an inter-agency group
formed to enforce the state's policy on priority problem sites, identify re-
sponsible parties to clean up contamination, require nydrclogical studies
be done where appropriate, halt and/or require reduction in contamination
where sources can be identified, and investigate and initiate remedial action.
Maryland's task force provides for interagency involvement in designa-
ting what substances are hazardous. Importantly it allows for discussion of
"hazardousness" of various substances from different perspectives - agricul-
ture, medicine, public and occupational health, and environmental quality so
that the varying costs and benefits or regulating and hazards of not regula-
ting a particular substance can be weighed.
Task forces (e.g. Arkansas) that review state government functions and
practices in a specific environmental area (e.g., hazardous waste) can help
to identify and delineate appropriate agency roles, discover gaps and over-
laps and develop mechanisms to address them, and recognize areas where inte-
grative activities could be instituted.
An interagency enforcement task force can foster an integrative approach
at the operational level and enhance identification of repeated violators of
laws that are handled by separate agencies. This is especially true of areas
like groundwater whereby polluters may be regulated by surface, drinking water
and/or hazardous waste programs.
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Many Group X States engage in interesting functional Lntegrat'ion efforts
chat constitute part of their respective strategies. For example:
Wisconsin's Bureau of Water Quality and the Hazardous Waste Management
Bureau are developing a joint approval process for pretreatment of chemical
discharges based on examination of effluents and NPDES permits;
NPDES permits in Michigan are systematically reviewed by the Office of
Toxic Materials Control in order to be sure that toxics information collected
through the Critical Materials Register is considered when issuing permits;
Arkansas conducted an extensive state agency functional review, examining
laws, resources and expertise in the state for environmental management and
toxics control. The review resulted in a report to the Governor on the need
for a toxics integration strategy and recommendations on how it should be es-
tablished;
Oklahoma's Pollution Control Coordinating Board is charged by law with
the function of examining the state of environmental management and making
recommendations on existing overlaps, gaps and inconsistencies with regard
to authorities, activities, organizational structure, and resource use. An-
nual reports documenting their findings are submitted to the state legisla-
ture; -
's Toxic Subs.tances Advisory Council prepares an annual report
for the Governor on the status of toxics control in the state. It includes
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an appendix on toxics-related agency and program activities, serving as an
annual "inventory" of state toxics management.
Permanent or planned information-sharing mechanisms are also character-
istic of Group X States. Information clearinghouses, educational projects,
newsletters, hazard alerts, memoranda of understanding, and communications
networks are used to facilitate state agency exchanges of information and
dissemination of knowledge to the public provide useful tools. For example:
California's Environmental Data Center acts as a clearinghouse of "infor-
mation on information," i.e., staff provide reference and referral services co
the general public and state agency personnel to assist in their locating the
most appropriate source of information to answer their questions. The Center
maintains a hard copy and on-line catalogue of information sources in anno-
tated bibliographic and geographic formats. In addition, it handles central
distribution of some state documents for which the state has no other es-
tablished distribution system. On occasion the Center performs some short-
term research to answer an inquiry if there exists no readily-available source
of information;
New Jersey's Toxic Substances Resource Center was created as a central re-
pository for various kinds of toxics information including conventional li-
brary materials, in-state and out of state developed materials such as re-
search documents, hazard maps, chemical inventory data, monitoring and en-
vironmental quality of data. The state plans to computerize data and
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provide on-line information search and retrieval methods, and an on-line
catalogue referencing the resources of the Center. The UPGRADE data base
is a core component;
Oklahoma maintains a central repository of state-generated environmental
documents at the educational Center for Ecology Information, East Central
State College for use by the public. The state's Environmental Epideniology
Service is also building and maintaining a toxics reference library including
an extensive contact persona list of federal and state experts in environ-
mental and health related problems.
Maryland's Health Education Center is planning a health education .pro-
gram covering aspects of environmental cancer protection for occupational,
community, professional and school groups;
Oklahoma conducts state-wide workshops in poison prevention, use of pes-
ticides and other household hazardous substances;
Arkansas would like to conduct or sponsor seminars and information pro-
grams on the handling and use of toxics substances in industry, agricultural
and household settings;
Maryland issues Toxic Substances Advisories to alert industries to sub-
stances that are known or suspected carcinogens;
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Oklahoma * s Environmental Epidemiology Service disseminates fact sheets,
prepares public information materials and news media items on toxics;
Virginia issues Health Hazard Alerts to affected parties on newly re-
ported toxic effects or widespread misuse.
Michigan is using memoranda of understanding (HOC) to enhance informa-
tion sharing between state agencies at the express direction of the Governor's
office. The MOU delineates relative state agency responsibilities where over-
laps or confusion exists. It mandates that each signatory designate a focal
point for toxic substances information exchange for routine requests and no-
tification of accidents. Focal points are responsible for communications flow
and updating each other on progress achieved on a day to day basis as well as
emergency situations involving toxics. In addition, personnel designated as
the focal point are mandated to exhange toxic substances program proposals
prior to their submission to the state budget office. The signatories and
their focal points are Department of Agriculture (Office of Toxic Substances
and Emergencies), Department of Public Health (Chemicals and Health Center),
Department of Natural Resources (Office of Toxic Materials Control), and the
Toxic Substances Control Commission (administrative office).
Illinois would like to establish a systematic, organized communications
network. The goal is to develop a two way information flow between state en-
vironmental and health agencies and those in the field (e.g., doctors, veter-
inarians, hospitals, coroners, local health directors, state field investigators)
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on human and animal illness or death related to toxic exposures. Systematic
documentation of field investigation results, routine and special reports of
environmental monitoring, and results of toxic substances research and epi-
detniological studies would be required. Three tasks outline the initial scope
of the planned project: identifying all agencies, institutions, groups and
relevant contacts with whom information-sharing should take place on a regular
basis; compiling a guide of relevant programs documenting research, labora-
tory, data management and investigative capabilities of contacts listed; and
developing a workshop for participating network personnel to describe logis-
tical considerations for collecting and sharing information.
- «
Functional integration efforts such as these represent specific opera-
tional level activities that implement the integrative concepts fostered by
the coordinating mechanisms and strategies. Without such efforts, toxics
integration would remain theoretical.
Joint approval processes for pretreatment needs and systematic, formal
permit reviews especially those that include the "toxics bureau," enhance
the opportunity for a variety of agency input so that important concerns will
not be overlooked.
Environmental agency functional reviews and annual reports can delineate
and uncover gaps, overlaps and inconsistencies in-laws, programs and activities
and help to ensure that toxics control is the key thread of relevant strategy
programs. AfTntta1 reports especially <*an provide the starting point for
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evaluation of strategy effectiveness and provide an "inventory" tool for
maintaining state-wide awareness of toxic control initiatives and authorities
available for use when the need arises.
Maintaining central repositories of information or reference and referral
services constitute a basic clearinghouse function. Such information management
mechanisms can assist the state policy makers especially when there is no time
to waste in searching for information needed to make decisions efficiently, ef-
fectively and quickly.
Mechanisms for the state to consistently share information with industry
and the citizenry can enhance integration and should be designed to provide
mechanisms for feedback of information and concerns from non-state to state
agency entities.
A better informed public can help decision makers by providing a more
rational political climate in which to make decisions. Educational programs,
newsletters and hazard alerts can assist in enhancing the protection of public
health and encouraging a more cooperative spirit between industry and the
state. Often, chemical misuse is a result of the lack of knowledge on how to
safely produce, handle or use a particular product not only on the part of the
general public and household chemical products but also on the part of indus-
try, especially those using chemicals in their industrial processes for which
adequate labelling is lacking.
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Memoranda of understanding can be effective in instituting interagency ~
information sharing not only when it is of crucial importance during crisis
situations buc also on a day to day basis. Ensuring that information circu-
lates among appropriate personnel who need to know, can make use of and in
turn provide input is a very important aspect of networking.
Two-way information flow of the kind proposed by Illinois is an valuable
element for a toxics strategy. Often information flows from the state agency
to the field, and not vice versa. Systematic feedback of field information is
especially important for health and illness data gathering needs. Relying
upon people to automatically do so results in sporadic, inconsistent and often
unreliable flows. Encouraging awareness of information needs and providing for
direct and regular contact can help Improve the situation.
2. Health Effects Monitoring and Studies; All Group X States place a
high priority on monitoring health effects and on performing individual
health effects studies. Environmental epidemiology and toxicology play key
roles in their respective strategies. The following examples illustrate the
extensiveness of the work of X States as a whole in this area, while providing
a checklist of possible tasks states not heavily involved in health effects
work may want to consider performing:
Health effects monitoring is accomplished by the following type of ac-
tivities in states:
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routine biological testing of children for blood lead
levels (Maryland and Wisconsin)'
periodic review of adult blood lead reports submitted
by laboratories throughout the state, abnormal levels
are followed up by physician's obtaining additional
clinical and occupational data (Maryland);
occupational diseases are monitored through reports
submitted according to law, combined with a cross-
checking review of workmen's compensation claims
(Maryland); monitoring of worker exposure to carcin-
ogens through reporting requirements mandated by
law (California);
engagement in various activities for which medical re-
sponse units or investigative teams of physicians,
biostatisiticians, monitoring experts, epidemiologists,
Laboratory personnel, and environmental health pro-
fessionals provide field analysis and monitoring of
health effects of victims of pollution incidents and
emergency accidents (toxic spills or leaks) or those
complaining of home or work related exposures. Tasks
performed include site visits, sampling, rev.iew of
medical records, provision of toxicological and medi-
cal information to physicians treating victims ex-
posed, and provision of advice to clean up personnel
regarding health concerns (Maryland, Illinois, and
Oklahoma);
monitoring of disease incidence, mortality or morbid-
ity trends through use of currently available infor-
mation (e.g., National Cancer Institute statistics)
and state documentation; diseases observed include
cancer, birth defects, cardivascular, congenital
heart and circulatory abnormalities (Maryland, Michi-
gan, New York, New Jersey, Illinois, and Wisconsin);
evaluation of potential health hazards related to chem-
icals listed in production/use inventories and attempts
to identify sources, levels and duration of human ex-
posures of populations potentially affected; statistical
correlations observed between chemicals and illness or
disease incidence for a given geographical area (Mary-
land, Michigan, New York, New Jersey, Virginia, and
several states planning to do so);
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implementation of a systematic reporting, surveillance
and investigative system for industrially-related
diseases (Maryland and Virginia); institution of an
automatic cancer and birth defects surveillance sys-
tem (Wisconsin);
monitoring of trends in hcspitalization related to tox-
ic exposures (Wisconsin).
Health effects studies are carried out in various ways:
general studies of disease patterns among high risk
groups and their relationship to other data collected
such as ch<"H^.C9'1- inventory, environmental quality and
epidemiological study data in an attempt to document
statistical correlations and apply epidemiological
techniques (Maryland, New York, New Jersey, and Ill-
inois) ;
epidemiological study of health effects of a community
exposed to fluoride in the ambient air emitted from
an g|l"ni-trnttn smelting plant during which an attempt
was made to find correlations between health data
collected and results of air and water sampling of
the surrounding environment (Maryland);
health surveys or small scale studies of workers and
the immediate community exposed to a variety of haz-
ards potentially being caused by hazardous substances
emissions or discharges (e.g., lead exposed workers
of a solder grinding operation of an auto plant),
specially developed questionnaires were designed to
obtain detailed information on worker practice and
personal hygiene and personal health data, physical
exams were performed, blood lead samples taken and
analyzed, and plant engineering deficiencies dis-
covered (Maryland);
study of PCS levels in citizen's blood entitled "Evalu-
ations of Changes of the Level of Polychlorinated Bi-
phenyls (PCS) in Human Tissue" in which a comparison
of PCS levels in the blood of fish eaters and that of
non-fish eaters pinpointed a direct relationship be-
tween size and quantity of Great Lakes fish consumed
and PCS levels found in human blood, although no health
or medical problems could be directly attributed to
such levels (Michigan);
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study of the relationship between PBBs and human breast
ailk from researchers confirmed that almost 962 of nur-
sing mothers in the area studies had at least a trace
level of PBBs in their milk (Michigan);
epidemiological study of miscarriages and birth defects
of those living near Love Canal (New York);
statistical study attempting to find correlations be-
veen the health risks posed by chemicals and community,
occupational, social, or environmental variables CNew
Jersey);
case studies of lead contamination, toxicity in the air
resulting from a fire, explosion at a waste treatment
plant, and leukemia cluster in a school for which an epi-
demiological study was done to define casual linkage
(New Jersey);
epidemiological studies of leukemia, lymphoma and mul-
tiple meloma and a 20 year study of households adversely
affected by the chemical lindane (Illinois);
study of persons exposed to the highly toxic chemical or-
ganophosphate during a chemical fire incident (Illinois);
formaldehyde vapor study whereby dose response relation-
ships and correlations with human exposures are to be
done (Wisconsin);
study of pulmonary diseases and their relationship to
industrial areas emitting a high level of particulate
matter (Puerto Rico);
study of health risks faced by employees and the immed-
iate community as a result of exposure to birth control
pills apparently creating changes in sexual character-
istics (Puerto Rico).
Systematic collection of health effects, toxic exposure and disease in-
cidence data is vitally important for a comprehensive toxics strategy. Statis-
tical correlations between environmental quality and health data, application
of epidemiological techniques in the study of environmentally-caused diseases
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and observance of trends between illness and highly industrialized areas where
toxic exposures may be the cause are impossible tasks without appropriate
health data. Establishing baseline health data against which changes can be
measured and potential cause and effect determined is vital.
Most efforts to date, however, involve collection, compilation and ana-
lysis of cancer data. Very little data for other potentially environmentally
related illinesses/diseases are available.
Regular testing of children and adults for the presence of chemicals in
the blood and body tissues is generally lacking among all but a couple of X
States. Occupational work exposures are regularly reported to a few of the
states. Efforts in these two areas apparently need intensification.
Although in general X states are 'further along in these areas than
most states, much remains to be done. Systematic reporting mechanisms for
state and national health data appropriate for environmental health study
are needed to further progress already made by these states. Efforts by some
states in this regard must be shared with counterparts in this grouping who
are ready to utilize their experience gained to date.
Legal mandates governing physician reporting requirements, cancer and
other disease registries, and industry reporting requirements with regard to
worker exposures are tools some states are using and remain tools other states
in Group X may need to institute.
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3. Information Gathering: All Group X States collect hazardous waste
generation data and/or pesticide production/use data. In addition, these
states show extensive chemical production/use data gathering efforts under-
way or planned. For example, five states (Maryland, Michigan, New Jersey,
New York, and Virginia) document the collection of data through chemical
inventories or industrial production/use surveys. Three additional states
are planning to do so (Arkansas, North Carolina, and Puerto Rico). High-
lights of these chemical inventories follow:
Maryland's Toxic Substances Registry identifies producers, users,
handlers of 150 selected known or suspected carcinogens. Data is collected
on quantity, composition, methods or treatment or disposal of waste generated
therefrom. Information gathered is routinely used by other program areas,
e.g., in prioritizing monitoring and control efforts, health effects studies
and correlations with permit data;
Michigan's Critical Materials Register is developed through state
preparation of a list of substances for which data must be reported. Pro-
ducers and users of listed substances are required to report annually on
uses, discharges and emissions related to the listed substances. The list is
derived through literature searches and then further refined through a haz-
ard assessment process based on a priority ranking scheme;
New Jersey has conducted a state-wide survey of industrial usage of
approximately 200 selected toxics and carcinogens. Information collected
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includes daca on the aanufacture, use storage, processing, packaging and dis-
posal of waste generated by the toxic chemicals. In addition, the state is
looking toward incorporating additional data on pollution control devices and
vaste treatment/disposal practices currently used by major chemical users,
i.e., state of,:he art technology, as well as information on industrial prac-
tices related to the emissions of carcinogens and other toxics;
Sew York completed its industrial chemical production/use survey in 1978.
All chemicals are referenced by their chemical abstract registry number and
categorized by industry, by county and by watershed;
Virginia's toxic substances registry consists of geographic information
on the production and use of chemicals, i.e., raw materials, catalysts, pro-
cess solvents, and final products, including mixtures. For each chemical
the following information is reportable by law: name and location of plant,
name and estimated quantity of substance reported. A list of Class I sub-
stances is derived through a hazard assessment process and further informa-
tion must be reported on those listed including name of toxic substance,
chemical properties, means of detoxification or decontamination, how emitted,
and whether a forseeable health risk to employees is present or risk to sew-
age treatment/disposal plant operation;
Arkansas is planning to collect information on industrial and agri-
culture uses of toxics by geographic area and by frequency of use;
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North Carolina is planning to develop a profile of chemical substances
produced, used, stored and accumulated as waste in the state. Data to be
collected includes plant location, size of the plant, amount produced or used
and composition of the chemicals. 1,000 chemicals will be then selected for
preparation of detailed background summaries and each chemical will be rated
according to volume produced or used, volume produced by county and severity
of health or ecological effects;
Puerto Rico will also develop a chemical materials registry to identify
existing and potential high risk industrial processes for prioritizing envi-
ronmental control program activities;
California's collection of commerce-related data on industries using
carcinogens;
Michigan's collection of information on the distribution and use of
PCBs;
Virginia's collection of production and use data on paints and PCS con-
tent of sewage must be reported.
4. Computerization of Data: Group X States are relatively sophisticated
in data computerization. Program managers apparently make use of, or are
planning to develop for their use, appropriate computerized data bases.
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Seven states reported having operational computerized data bases for en-
vironmental nouitoring, chemical inventory, reference and referral catalogue,
manifest system, pesticide use, and/or toxicological data. The five states
compiling chemical inventory data have computerized this information as well
as health hazard assessment data.
Oklahoma is planning to computerize its waste inventory and manifest data;
Puerto Rico is planning to computerize its pesticide data; and California will
be establishing a computerized state-wide water quality information system and
a wastewater information management system.
Considerable efforts to institute comprehensive, computerized management
information systems are under way or planned in some states.
Illinois's plans for a data management and evaluation system involve
the incorporation of capabilities for the storage and retrieval of data,
analysis of information entered, adding of other existing data bases, geo-
graphic mapping of morbidity «ad mortality data, and routine scanning from
an epidemiological-perspective. The state will develop a systematic re-
porting system to facilitate data entry;
Michigan will be expanding its computerization of Critical Materials
Register data to include the capability to sort, retrieve and analyze data,
perform statistical correlations, incorporate secondary data sources such
as NFDES permit information, environmental quality data, federal computerized
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data bases, and premanufacture notice information pertinent to the state
collected by EPA. The state would like to be able to store and retrieve
the data by geographic area and specific materials by type and quantity used;
North Carolina wants to develop an interactive management information
system that would include the chemical profile data, groundwater quality
data (i.e., geologic, hydrologic and soil base information), river and stream
quality data, population and demographic data, existing state and federal
data bases, manifest system information;
New Jersey would like to expand its already existing computer capability
in using UPGRADE as a core component and incorporating additional information
on environmental quality and monitoring, data, health effects information and
other federal data bases such as MED-UNE, TOX-LINE, CANCER-LINE, OHM-TADS.
The expanded computerized system would be a core component of the Toxic Sub-
stances Information Center;
Wisconsin wants to develop a rapid access data base that would allow
them to answer questions on toxic substances exposures and investigate/study
multiple toxics problems. In addition, the state would like to develop a
computerized cancer and birth defects surveillance for automatically indi-
cating abnormal occurrences of these diseases;
' Arkansas is considering the development of a comprehensive computerized
data management system that would incorporate the following: medical,
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coxicological and epideniological data; exposure information resulting from
consumer end use; cancer and birth defects registry data; food and public
water supply contamination data; industrial emission data; information on
industrial and agriculture use of toxics, environmental quality data; all
state survey information including manifest system re/orts; and all related
permit data. Consideration will be given to relevant federal data bases
such as OHM-TADS, CHEM-LINE, TOX-LINE, STORET, and SAROAD.
Half of the X States currently use federal data bases as an integral
part of their toxics programs. For example: New Jersey and Illinois exten-
sively use UPGRADE; Michigan and Maryland report use of TOX-LINE, MED-LIUE,
and CHEM-LINE as well as others; California uses STORET in addition to others;
Virginia also uses a variety of federal data bases and several states report
use of CHEMTREC and OEM-TADS. As mentioned above, those states planning com-
prehensive management information systems are considering the feasibility of
incorporating federal computerized data bases as appropriate.
5. Individual Environmental Programs and Toxic Activities: About ten
of these states have assumed basic enforcement responsibility for six of the
seven environmental programs, while the other Group X States have assumed it
for five of the programs. The systematic infusion of toxics integration,
documentation and control efforts characterizes Group X States.
Many of the X States have excelled in certain program areas not already
discussed. Sophistication in these program areas is necessary for a viable
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strategy and the fact that many of these states show relatively strong ac-
tivity in various areas demonstrates their inclusion in the X category.
The following highlights illustrate the diverse ways X states encourage
and incorporate toxics control activities into environmental management. Ex-
amples chosen are those which appear most interesting and are not necessarily
part of each and every state strategy, but could be. This could be useful to
all states as a tool for reviewing their respective toxics activities and de-
termining whether their toxics involvement is adequate. We have grouped like
activities under the general categories: definitions, monitoring, testing pro-
cedures, laboratory capabilities, standards development/use restrictions, per-
sitting, emergency response, and miscellaneous activities.
A few X . states define terms in such a way as to be more
inclusive and less parallel to their federal counterparts, while being sub-
stantially equivalent. Broad definitions of what is to be regulated can
help to minimize gaps in authorities. This is especially true of potential
emergencies not viewed as severe crises for which broad emergency health powers
cannot realistically be used to control the situation and specific laws
narrowly defining what can be regulated do not cover the substance of concern.
Definitions that can be used for any and all aspects of environmental
protection,rather than having different definitions for each type of regu-
latory activity (e.g., hazardous waste disposal, transport, chemical manu-
facturing, pesticides, water pollution)taay help with regard to intergrating
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environmental program activities as it would provide a connion basis from which
to work.
Maryland's Dangerous Substances Act of 1276 defines hazardous substances
as "any matter that conveys toxic, lethal, or sub-lethal effects to plane,' ac-
quatic, or animal life, or which may injurious to human health, or persists in
the environment, or which causes sub-lethal alterations to acquatic, plant or
human systems through their cumulative or Immediate reactions," Although this
definition pertains primarily to state hazardous waste and transport regulatory
actions, it provides a broad and potentially all-inclusive framework for regu-
lating pollutants. The state further delineates what is hazardous by a listing
process using the various federally-regulated substances as part of the list
\
as well as having state-designated substances listed;
Virginians Toxic Substances Information Act includes a relatively compre-
hensive definition of toxics: "any substance including raw materials, inter-
mediate products, catalysts, final products, or by-products for any manufac-
turing operation or commercial establishment that has the capacity through
its physical, biological, or chemical properties to pose a substantial risk
of death or impairment either immediately or over time to normal functions
of humans or acquatic organisms or any other animal." Apparently, this def-
inition does not cover hazardous waste. However, all other hazardous pol-
lutants in any form but waste could be regulated according to the provisions
of the Act. The Act, however, primarily governs information gathering ac-
tivities important as a first step toward regulatory action. The state ap-
parently must turn to other laws in order to take regulatory action.
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Illinois defines by law acute hazardous waste as "a hazardous waste
that has been found to be fatal to humans in low doses or in the absence of
data on human toxicity, it has been shown in studies to have an oral LD50
tcxicity of less than 50 milligrams per kilogram or an inhalation LDSO tox-
icity of less than 2 milligrams per liter or a dermal LDSO toxicity of less
than 200 miligraias per kilogram or is otherwise causing or significantly con-
tributing to an increase in serious, irreversible, or incapacitating rever-
sible illness." In this,the state is attempting to fill a void in toxicity
information that so often makes regulatory activity difficult when data on
human health effects resulting from exposures to a particular waste in-
conclusive or non-existant.
Nearly all these states have better than average toxics monitoring pro-
grams. They are monitoring, sampling and testing for the federally-designated
or regulated contaminants in addition :to other contaminants determined
necessary by the state. Strong monitoring activities are an important part
of toxics control programs. They provide the environmental quality data so
necessary for indicating where problems exist. They provide the data on con-
tamination in the water, soil and air that can be compared and correlated, if
possiblexwith health data to see if there is a cause and effect relationship
or a strong indication thereof. The data gathered through monitoring pro-
grams is not only necessary for regulating federally-designated contaminants
for which standards controlling their discharge and emissions have been de-
veloped but are also necessary for detenning new harmful pollutants in need
of regulatory action.
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In addition, improvement of monitoring techniques can speed up the
identification of specific problem areas for prioritizing environmental pol-
lution control activities. Pollutant screening methods, computerized moni-
toring networks, extensive fish-flesh analysis, among other techniques, can
prove useful for more accurate and rapid characterization of a state's en-
vironmental quality.
Maryland has an ambient air quality monitoring network consisting of
17 automated remote stations linked by telemetry to a central computer that
controls the stations and provides real time data display and data processing
capabilities. The state's air program monitors concentrations of sulfur di-
oxide, carbon monoxide, coefficient of haze, photo-chemical oxidant, oxides
\
of nitrogen, wind speed, and wind directions. Maryland also has a mobile
air quality monitoring laboratory consisting of a van with two gas chrcrao-
tographs equipped with 4 different detectors, portable power generators, and
an analytical lab. It is capable of determining a variety of ambient air
toxics including pesticides, sulphur and phosphorus compounds, low boiling
hydrocarbons, and vapors, and can make determinations of concentrations with
distance from the source as well as following a plume;
encourages a team approach toward field sampling of air, water,
soil, human and a-n-tmai tissue. Integrated teams include physicians, bio-
statistians, monitoring experts, laboratory /analytical staff, epidemiologists,
and environmental health professionals;
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New York State's fish-flesh monitoring program analyzes a variety of
fish species for heavy metals and a variety of chlorinated organic chemicals
using over 100 stations covering major waterways on a state-wide basis. Em-
phasis on fish monitoring is due to the fact that fish concentrate chlorin-
ated hydrocarbons present in atiuatic environments that would otherwise be
evidenced only in very low concentrations in the water column making it diffi-
cult to determine what is present in the water. Extensive use of fish tissue
analysis can assist in making determinations more accurately;
New Jersey is compiling an extensive set of data on metals and volatile
organics present in the air. Atomic absorption techniques are used to ana-
lyzes samples for the presence of lead and other heavy metals. At the same
time and places, the state takes samples of volatile organics in -the air
and analyzes them for selected carcinogens and toxics. Approximately 23 com-
pounds* including routine sampling for lead, manganese, arsenic, zinc, nickle
and spot checks for chromium, ciadTimmi and mercury* are monitored for. In
addition, the state has an extensive groundwater sampling and testing pro-
gram for 50 chemicals including heavy metals, chlorinated low molecular
weight hydrocarbons, and pesticides;
Illinois's air monitoring program includes sampling for sulfur dioxide,
nitrogen dioxide, ozone, carbon monoxide, hydrocarbons, particulate matter
and metals such as lead, zinc, iron, copper, cadmium, and arsenic.
New testing procedures or sampling methodologies such as various equip-
ment modifications, improved in-stream bioassays, adaption of in-vitro
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tsutagenicity tests, biochemical, physiological and behavioral study nethods,
and techniques for coaputing metabolic and clearance rates for humans provide
progressive steps toward overall improvement of environmental quality moni-
toring and analysis efforts. Improvements in these areas and others can in-
crease the accuracy of monitoring activities, decrease the time spent in lo-
calizing problem areas and provide better data for human health risk assess-
ments .
Illinois's work in the study of trace organics in water discharges has
resulted in the development of new sampling methodology and the fabrication
of a pump for simultaneous quantitative concentration of aqueous samples by
several methods. They use mathematical theory of sampling and have,developed
equipment especially designed to reduce errors involved in collecting samples
containing large numbers of organic compounds present at trace levels. In
addition to using traditional chemical analyses of samples for priority and
other trace pollutants, modifications of the Ames bacterial mutagenicity
testing procedure are being researched by the state in cooperation with the
University of Illinois and the SIU School of Medicine. To date, the state
has used this technique to quantify the toxicity and mutagenicity of a mix-
ture of 11 toxic, mutagenic and Inactive compounds in about 50 combinations
in TA98, TA100 and TA1537;
Illinois is conducting a pilot study of in-stream bioassay method using
a benthic organism and will establish a network of biologic monitoring sta-
tions capable of using a combination of biologic data (e.g., pathologic
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changes, bioaccumulation, water column analytical data, and mutagenic data
rroia extracts of organisms in the samples);
Illinois is working on a methodology for computing metabolic and clear-
ance rates in humans from animal data for independent assessments of human
health hazards of compounds already identified through monitoring efforts;
New York is planning to develop chemical screening procedures that
screen for toxic effects of mutagenicity or teratogenicity and wants to es-
tablish protocol for the Ames test already used on a preliminary basis for
screening bottom sediments for mutagenic activity. New York would like to
be able to use the Ames test as a scanning method for effluents, sediments,
leachate, and biota followed by chemical analyses using gas chromatography
and spectroscophy;
New Jersey's short term in-vitro mutagenisis testing for air and water
samples whereby the ability to analyze environmental samples for mutagenesis
and carcinogen.esis through short term bioassays would be useful for re-
flecting the .presence or absence of a wide range of toxics and may provide
indications of the synergistic action of chemicals in the environment. Per-
fection of the test,in. addition to statistical studies of health effects,
will help the state evaluate health risks of specific environmental contam-
inants. State-wide screening made possible through this testing protocol
would help speed up examination of overall contamination and determination
of localized problem spots where carcinogens and niutagens are entering the
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environaent as veil as supplenent direct risk assessments of pollutants cur-
rently done by aatheaiatical extrapolations;
New Jersey is currently performing biological and ecological testing of
water to: detect chronic effects of toxics; determine what additional sub-
stances ought to be tested for and monitored; and determine whether syner-
gistic effects or other interactions have an effect. The state will be using
chemical analyses and also biological and ecological studies in which certain
species would be chosen for biochemical, physiological and/or behavioral
studies including analysis of enzymes that might be altered by pollutants,
physiological measurements of variables known to be altered by stress and
behavioral traits known to be subject to modification by chemicals.
Strong laboratory capabilities are necessary for a viable toxics pro-
gram. This is especially true for the identification and analysis of "ex-
otics" and trace elements of other toxics in the environment and animal and
human tissues. Without extensive environmental and health laboratory ex-
pertise, the gathering of environmental quality and human health effects
data serves a limited purpose and the initiation of control activities would
stand on unsure ground. Most X states have better than, average laboratory
capabilities and several have consolidated environmental-related laboratory
services to provide for centralized servicing. Consolidation of services
can be useful for facilitating exchanges, of expertise among lab personnel,
enhancing learning and on the job training/development, cooperation among
personnel on complicated and extensive analytical problems, bringing together
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the environmental contaminant analysts and those most proficient in the ana-
lysis of poisons in human tissues, and the cooperative use of sophisticated,
expensive equipment.
Maryland has very extensive and specialized laboratory
capabilities and can test and confirm almost an un-
limited spectrum of chemical toxicants and carcinogens
including nitrosamines, kepone, phenols, pesticides,
and other organics. Lab services also include bio-
logical testing of humans, i.e., blood lead levels,
urine fluoride, asbestos in tittues, hematological
testing, and testing for precancerous and cancerous
conditions. Only lead is screened for on a routine
basis;
Illinois's Department of Public Health Toxicology La-
boratory has received nationwide recognition for for-
ensic toxicology and has extensive experience in pes-
ticide analyses from the various media. The Laboratory
is working on new analytical methods to identify sub-
stances and trace quantities in human tissues and cur-
rently performs routine examinations of body samples
to determine manner and cause of death. Samples are
analyzed for drugs, poisons and unusual chemicals.
Oklahoma has laboratory instruments capable of reading
very low levels of toxics in the air, water and food.
The development of criteria standards and use restrictions for non-fed-
erally regulated contaminants are areas where states can be active in address-
ing environmental problems unique to the state or a few states, especially
where nationally-developed standards for all states may be an unnecessary use
of federal dollars and staff time. Other states experiencing similar prob-
lems can benefit from a fellow state identifying a need, taking the lead to
address the need and spending the "front end time" to devise an appropriate
standard or use restriction. Some Group X States are working in this area,
the results of which may be of use to other states.
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Maryland is now proposing regulations for the control of the use of as-
bestos-containing serpentine rocks on roads, parking lots and other similar
surfaces;
Wisconsin requires oiost paper and pulp mills to conduct chemical analyses
of water effluent;
Wisconsin has developed guidelines for the restricted use of several pes-
ticides - eldria, deldrin, lindane, chromium, and mercure;
Okalhoma*s Water Facilities Engineering Service, through its rules and
regulations on wastewater pretreatment requirements and primary standards cri-
t
teria for public water supply facilities, has established a system by which
staff engineers evaluate potential effects of industrial wastewater discharges
on sanitary sewers to ensure that the waste does not contain toxics that will
kill the bilogical organisms needed for adequate biotreatment of the wastes.
Screening of industrial waste with regard to volumes and strength of toxic
materials is needed to ensure compatibility. Recommendations are made to ad-
just waste content when compatability is absent and enforcement takes place
under local ordinances, if necessary;
Virginia is finalizing regulations governing its industrial ethanol con-
trol program. Rules concern the use permitting that will probably affect far-
mers using ethanol for non-commercial purposes. Regulations also include per-
mitting requirements for the operation of alcohol plants, and providing for plant
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security including rules on required production reporting, maintenance of in-
ventory records and controls, and disposition reporting so as to ensure that
alcohol production is not diverted to illegal uses;
Puerto Rico, under its NPDES program, is revising its industrial and
municipal water discharge permits to include specific effluent limitations
for toxics based on EPA guidelines developed under FWPCA. While implemen-
ting pretreatment requirements under Section 307 of FWPCA, the Commonwealth
will assess and reduce the contributions of toxics from industrial discharges
of wastewater into municipal wastewater treatment systems;
Maryland correlates toxic substances data from NPDES permits with indus-
trial chemical survey data for identification of potential water contamination.
Hazardous materials emergency response is an important element of a
toxics strategy. Although X states generally have comprehensive emergency
response plans for hazardous materials accidents, several states have pin-
pointed a deficiency in their overall capabilities to respond and protect
the public health. For the most part, emergency medical services is the
only medical component present at a toxic spill. Awareness of the need for
environmental health professionals trained in recognizing the health effects
caused by polluting emissions of, for example, a wastetreatment plant fire,
characterizes many of the Group X States orientation toward improving their
response capabilities. Determination of the need for community-wide evacu-
ation, monitoring of the area affected for after-incident health effects,
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providing environmental haalth advice to on-scene physicians and assisting
in the clean up operation to ensure that a health perspective prevails are
all areas of concern that are not usually addressed. Several X States are
addressing these needs in various ways.
Maryland has a medical response unit designed to respond to health ef-
fects problems caused by toxic spills and emergency leaks. Expert teams in-
vestigate and supply medical and toxicological advice through site visits,
environmental sampling, reviewing medical records of victims, and other en-
vironmental health activities;
Wisconsin is looking toward developing an emergency response health plan
i
outlining medical responsibilities that go beyond the traditional emergency
medical services activities. The plan would include guidelines on: potential
health effects that would necessitate evacuation; medical tests needed to
screen for adverse health effects; reporting mechanisms needed to establish
early warning for detection of unexpected exposures that might not be mani-
fested until well after the accident is over; after-incident sampling proto-
col; appropriate government roles for responding to environmental health ef-
fects caused by toxic accidents; supplies, equipment and training needs.
Maryland and Illinois are investigating similar approaches;
Okalhoma would like to see established state-federal interagency haz-
ardous materials emergency response teams consisting of a coordinator, legal
advisor, field inspectors, transport officer, laboratory coordinator, epi-
demiologist, and a media coordinator;
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Arkansas wanes to identify high risk facilities and transport corridors
for targeting prevention activities;
New Jersey's Office of Hazardous Substances Control systematically re-
views all spill prevention plans of major hazardous materials storage facil-
ities. Several states require such plans;
Michigan's CMR is used for determining which facilities must develop
pollution incident prevention plans. Each facility using or storing any CMR
listed substance must prepare a plan that sets forth procedures on preventing
pollution, emergency cleanup methods, surveillance used to detect possible
pollution, and methods of keeping inventories. Plans must be made available
' to employees handling CMR listed substances and all spills of CMR listed ma-
-~ I
terials must be reported to the state.
Group X States engage in some additional activities that may be of in-
terest to others and characterizes the level of relative sophistication at-
tained by this group of states.
North Carolina's eutrophication project addresses the problem of accel-
erated nutrient enrichment in rivers and estuaries through a system of class-
ifying state waters as nutrient sensitive. The classification carries with
it water quality standards on nutrients. In addition, the state is evaluating
the trophic status of its waters;
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New York is instituting a bulk storage program the control surface or
subsurface tanks, mostly holding petroleum or petroleum products, found to
be or suspected of leaking and polluting the environment. The program is
just starting and consists of the following elements: identifying environ-
mental problems and hazards caused by leaking bulk storage tanks; preparing
or certifying criteria for siting, fabricating, installing, monitoring,
testing, replacing, rehabilitating, and abandoning tanks; preparing state-
wide regulatory programs for preventing leaks; informing industry, local
officials and public on the environmental problems and hazards caused by
tanks; and encouraging local governments to exercise control wich regard
to siting and installation of bulk storage tanks;
Oklahoma has a cross connection control program designed to protect
citizens from toxic contamination of potable water supplies by testing
plumbers on techniques used to prevent back siphonage of toxic materials
from sewers into the water system. Back siphonage from a hotel air con-
ditioning unit is suggested as the cause of Legionnaires disease;
Arkansas has included in its hazardous waste management code a pro-
vision for health monitoring and health hazard identification whereby prior
to the operation of a new commercial hazardous waste facility, the state may
request the apporpriate health agency to perform a community survey to es-
tablish baseline health data. Investigation, of health conditions among a
statistically representative portion of the surrounding population and per-
tinent epidemiological investigations may be conducted in the future, as
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deemed appropriate. Establishment of baseline data will provide a norm
against which health effects occurring at later dates can be compared to
determine if significant changes have taken place that may be linked to em-
issions of the hazardous waste facility.
Group Y States
States characterized by the following description include: Arizona,
Connecticut, Colorado,* Delaware, Iowa, Kansas, Kentucky, Louisiana,* Mass-
achusetts, Minnesota,* Montana, New Hampshire, Pennsylvania,* Rhode Island,
South Carolina, Texas,* Utah, Vermont, Washington and Wyoming.
1. Interagency Management Mechanisms: Use of formal, gerrr\c^.&n~ ecmrri
admissions or processes designed to encourage more comprehensive management
of dangerous chemicals characterizes most of the Group Y States (14 out of 20)
Such efforts vary, but they include the institution of permanent committees,
boards, commissions, formal planning processes, or study group systems that
usually revolve around a central focus or theme. They emphasize integrating
relevant state agency activities and functions that cut across the media-
specific, operation-specific and product-specific environmental programs.
The central focus tends to be operational, with the most prevalent being
hazardous materials incidents. May of these states have interagency, co-
operative efforts to control pesticides, as well. Examples of various mech-
anisms include:
* States for which additional information may indicate a change in grouping.
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In 1979, Louisiana established an Environmental Control Commission by
law with the primary function of developing unified state-wide policies on
hazardous waste management. The Commission has the power to issue regula-
tions and coordinate environmental management functions among seven major
departments which have named representatives to the Commission. These de-
partments cover a wide range of responsibilities for various aspects of dan-
gerous chemicals management (e.g., hazardous waste, hazardous materials,
pesticides, air quality, surface and drinking water quality, and emergency
response to hazardous materials spills). Although its principal mandate is
to coordinate activities among the seven departments as they relate to haz-
ardous waste, the Commission has been involved in effecting some coordina-
tion and integration in hazardous materials emergency response operations
and air and water quality activities;
Massachusetts has a permanent Secretariat, the Executive Office of En-
vironmental Affairs, charged with apportioning major environmental control
responsibilities between two key departments - the Department of Environ-
mental Quality Engineering and Environmental Management. The former engages
in regulatory and enforcement activities for hazardous waste, air, surface
and drinking water programs and the latter concentrates on policy develop-
ment initiatives. The Secretariat also acts to coordinate and mesh a mis-
cellaneous collection of environmental programs housed in three other de-
partments - the Departments of Fisheries and Wildlife, Food and Agriculture,
and Metropolitan District Commissions (Divisions of Environmental Planning
Environmental Quality);
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Utah has a State Advisory Council on Science and Technology consisting
of 12 technical members from the state university system and various indus-
tries and 8 state agency heads. The Council examines a broad range of tech-
nical and scientific issues, many of which include those relating to envi-
ronmental pollution control. The Council establishes various conmittees to
focus inquiry on specific problems;
Iowa's Central Planning Commission coordinates a formal planning process
that involves all relevant sections of the state's Department of Environmental
Quality including air, surface and drinking water quality, and hazardous waste
areas. Planning sessions are convened to assess and accommodate inter-program
Impacts and clarify staff responsibilities whenever prospective changes or new
initiatives in environmental control are considered;
The Kansas Department of Health and Environment operates an intradepart-
mental study group system among its air and water quality, hazardous waste
and occupational safety and health component divisions. The systems' overall
goal concerns comprehensive examination of the community impact of hazardous
waste and other private chemical industry activities. Study groups assess
problems ar*4 make recommendations for action taking into account the affected
population and its environment. Publication of a final technical report and
the integration of activities often emerge, including the establishment of
joint testing procedures, analyses, surveys, or inventories facilitated
through cooperative efforts of relevant staff;
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The Texas Energy and Natural Resources Council, established in 1979,
acts as an independent agency designed to develop broad intergrative policy
and effect overall coordinated planning among relevant state agencies working
on state energy and environmental concerns. The Council consists of \12 state
agency representatives, 4 legislators, 4 citizens, and a governor's advisor.
Although the Council has no regulatory, enforcement or monitoring responsib-
ilities, it makes recommendations to the governor and state legislature for
improved management. The Council establishes working committees to address
specific issues, one of which includes toxic chemical wastes;
In 1978, the Governor of the State of Washington established by execu-
tive order the Hazardous Materials Management Committee as an advisory /policy
\
group made up of 15 state agency representatives. The Committee focuses on
hazardous materials emergency response and transportation issues and is de-
signed to effect better cooperation and coordination among all agencies having
responsibilities in these two areas as well as to provide a focal point for
working with local governments;
Wyoming's Governor formed a Hazardous Materials Committee by executive
order in 1979 specifically designed to effect better coordination and im-
proved management in the overall area of hazardous substances control. Repre-
sentatives of six major agencies handling air and water quality, hazardous
waste management, transport, and emergency response needs meet regularly
to discuss and make recommendations for enhancing cooperation among agencies
and program activities that interrelate;
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In 1978, the Governor of the State of Vermont established a Hazardous
Materials Management Committee consisting of representatives from four major
departments (Public Safety, Agriculture, Civil Defense, and Labor and Indus-
tries), two major agencies (Environmental Conservation and Transportation),
the State Fire Fighters Association, and the State National Guard. Although
the initial focus of the Committee involves addressing hazardous materials
emergency and transportation issues demanding interagency input, its mandate
is expanding to include other areas of inquiry requiring enhanced inter-
agency coordination, cooperation and communication Ce.g., hazardous waste
and environmental monitoring and sampling equipment needs);
Pennsylvania has an interagency Environmental Quality Board that adopts
rules and regulations for the protection of health, safety, welfare, and
property including air, water, and other natural resource protection. It al-
so acts to_coordinate the administration and enforcement of various environ-
mental laws.
The use of ad hoc, temporary task forces also characterizes Group 7
States. They are usually interagency bodies established for a short-term
duration to focus inquiry on specific issues or crises.rather than broader
concerns ihandled by the permanent committees discussed previously. Often
they study management issues such as review of environmental authorities,
program or activities to determine gaps, overlaps and inconsistencies and
recommend improvements. Some examples include:
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In 1978, Connecticut established a Hazardous Materials Spills Environ-
mental Emergency Task Force which analyzed potential hazardous materials
problems and recommended organizational changes in the relationships between
public health, safety and the environment. The Task Force consisted of repre-
sentatives of the Departments of Environmental Protection, State Police, Trans-
portation, Motor Vehicles, and the Office of Civil Preparedness, the National
Guard, the State Fire Marshall and the Connecticut Chiefs of Police and Fire
Chiefs Associations. Based on their final report, the Governor issued an ex-
ecutive order clarifying agency responsibilities for hazardous materials emer-
gency response, calling for the development of a comprehensive management
program thereof, and establishing the need for legislation to fill identified
gaps in emergency hazardous materials authorities. The Hazardous Materials
Management Unit was created within the Department of Environmental Protection
with oversight responsibility .for pesticides, hazardous waste disposal and
transport, and oil and chemical spills for all aspects of state management in-
cluding planning, regulating, licensing, monitoring, training, enforcement,
and coordination;
The Governor of Kentucky established an Asbestos Task Force comprised
of representatives from the Departments of Education, Natural Resources and
Environmental Protection and Human Resources as well as the Cabinet for
Public Protection and Regulation to Investigate problems of asbestos in
schools;
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Massachusetts has an 18 member Special Legislative Commission on Haz-
ardous Waste to address waste facility siting issues;
Rhode Island has a task force made up of the Departments of Environ-
mental Management and Health and the Water Resources Board, with the Office
of State Planning acting as lead agency. The task force is currently working
to pull together a comprehensive goundwater management program;
Arizona established the Hazardous Materials Program Review Committee in
1979. The Committee, consisting of several state agencies, has the purpose
of studying and recommending legislative changes and organizational improve-
ments in hazardous materials emergency response as well as examining the
feasibility of coordinating all state hazardous materials management programs.
The Committee works directly under the auspices of the Governor and has al-
ready recommended that responsibility for regulating the transport of haz-
ardous materials be shifted from the Arizona Corporation Commission to the
Department of Transportation.
Functional integration spanning the various environmental media and
hazardous materials operations and products is characteristic of a few of
the Group Y S-ates. Such integration efforts include: pulling together all
relevant environmental laboratory services under one office; the develop-
ment or modification of hazardous materials emergency response plans so that
they are more comprehensive and cover a wider variety of agency functions
for handling of transportation as well as fixed site accidents involving not
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just oil spills but all types of hazardous substances resulting in air, water
and land contamination; the encouragement of joint environmental inspections;
one-stop permitting activities and pre-design conferences for industries.
Among Group 7 States, coordination, cooperation and communication on
issues not covered by the permanent committees, ad hoc task forces or func-
tional integration activities, occur in an informal way. Informal net-
working and information-sharing among state agencies primarily occurs as a
reaction to an imminent problem or crisis situation for which state program
managers perceive a real need to obtain and share information with each other.
For example; air and water quality program managers rarely exchange informa-
tion, except when a particular pollution problem reaches emergency propor-
tions* and it is readily apparent that the problem involves both air and water
quality issues; the state health authority is rarely consulted by environ-
mental program managers unless the pollution incident reaches emergency pro-
portions and a serious health crisis is Imminent. Informal, ad hoc exchange
of information with regard to routine concerns appears to be the norm as well
as the preferred method as documented by Group Y officials.
2. Health Effects Monitoring & Studies: Several Group Y States have done
isolated studies and a few states are doing some ad hoc monitoring. All Y
States note the necessity of doing so and are extremely interested in becoming
involved in this area. They are collecting more sophisticated environmental
quality data through their monitoring programs but have little state-level
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health related data with which they can perform correlations and examines
trends between illness and disease incidence and environmental .contamination.
They recognize the need for employing environmental epidemiologists and tox-
icologists, although for the most part there exist no specific, organized pro-
grams in environmental epidemiology or toxicology. Major obstacles include
lack of staff, time and funds and also to some extent a lack of awareness and
support on the part of environmental managers for state health authorities
taking an active, participatory role in the day to day management of environ-
mental programs.
In addition to the examples found in the compendium to this report, Group
Y activities of interest include Massachusetts' Department of Public Health
preparation of health profiles on 351 cities and. towns which contain statis-
tical assessments of the incidence of 60 diseases; Utah's monitoring of work-
related illness rates; and Washington's studies of the.health,problems assoc-
iated with formaldehyde in prefabricated homes, worker exposure to contamin-
ants found in the coal tar, aluminum and wood-working industries, and arsenic
exposure of workers in copper smelter plants.
3. Information Gathering; Systematic information gathering efforts of
all Group Y States with regard to industrial chemical production and/or use
data is limited for the most part to hazardous waste generation and tracking
information (volume and type) and/or pesticide manufacturing and use data.
In addition, a couple of these states periodically collect other types of
chemical use data; for example, Iowa's survey of chemical use in school
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science laboratories and Kentucky's investigations of the presence of as-
bestos in schools.
4. Computerization of Data; Approximately eleven states in this group
are in the process of,or seriously considering»computerization of collected
data. A few states indicate that they computerize air emissions and water
quality data, and several states use federal or private computerized data
bases. Those mentioned in this latter category include STORET, OHMTADS, and
CHEJJTREC. Two of these data bases are specifically designed to assist users
to respond more effectively to hazardous materials emergencies. In our dis-
cussions with states, we did not talk with computer operations officials or
technical experts; rather, we talked to program managers and governor's aides.
Computer operations and technical staff may use or be more aware of useful
computerized data bases either within the state or those operated by the fed-
eral government or private sector. The apparent lack of computerization and /or
use of already existing computerized data bases on the part of program managers
could be an indication of little state use at all, or perhaps a lack of com-
munication between computer operators and technical staff and environmental
program managers.
5. Individual Environmental Programs/Nature of Toxics Control Activities;
Host of the Group Y States exhibit strong, individual environmental pro-
grams that for the most part parallel federally-established programs with re-
gard to definitions, standards, and activities. In addition, most of these
states have assumed basic enforcement responsibility from the federal
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government in at least four out of the seven program areas. About half of
chose states, however, have acquired basic enforcement responsibility for
six out of the seven. All of these states have begun or are actively pro-
moting action in toxics control, primarily in their surface and/or drinking
water quality programs and in some cases in their air quality programs. In-
tegration of strong interest and action in toxic substances control in the
ongoing environmental enforcement programs, however, has been accomplished
on an ad hoc basis. For a few states, quite a bit of effort in toxics con-
trol seems to be occurring as a result of the EPA/State agreements for 1980.
However, it is difficult to say conclusively that the concerns on paper have
actually been translated into concrete actions.
Examples of where states are modifying the basic federal programs and
integrating toxics-related activities follow.
Connecticut has a statute concerning the use, production, storage and
disposal of chemicals as listed in 40 CTR 116 and as designated in Section
311 of the FWPCS, whereby manufacturers must submit to the nearest local
health director upon his/her request, a list of such chemicals. The Act
includes provisions for the treatment of trade secret information. The
state also has a statute on information and notice requirement for employers
using listed carcinogens within the workplace and one that lists carcinogens
for which producers/users must submit an apn*j*O report to the Commissioner
of Environmental Protection and Health Services.
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Kansas issues federal and state pesticides export permits, its air pro-
gram occasionally conducts air analyses of heavy metals in excess of federal
standards} and within the NPDES permit program, the state occasionally ex-
ceeds federal minimum treatment standards for discharges;
Kentucky carries out required inspections of incinerators (random sam-
ples) and performs laboratory analyses to determine if permitted substances
are being burned. The state uses TVLs developed by OSHA for worker exposures
for establishing ambient air quality standards for non-federally regulated
contaminants
Louisiana Department of Agriculture's pesticide regulations, include a
requirement that toxic pesticides or those considered highly dangerous to
man or domestic a-nimalg must be distinctly colored or discolored;
New Hampshire's groundwater program requires that groundwater quality
meet the requirements of the federal safe drinking water standards. The
state's volume exemption for hazardous waste generators complying with mani-
fest system requirements is set at 100 kg and manifest reporting will be done
on a load by load basis.
Rhode Island has no volume exemptions for hazardous waste generators
required to meet manifest system reporting-requirements, and toxicity cri-
teria for hazardous waste are based on ten times the federal drinking water
standards. The state has its own air quality standard for air emission
-------
resulting from the burning of waste oil. The drinking water program main-
tains a strong emphasis on extensive testing of exotics and organic chemicals
within three communities and with the help^ of EPA is tracking the sources of
such contaminants;
Washington has developed state air emissions standards and monitoring
program for fluoride and for total reduced sulfur gases. State laws defines
hazardous waste using a two-tiered classification system (.i.e., extremely
hazardous and dangerous categories, the former being defined as those wastes
exhibiting acute or chronic toxicity and the latter being defined as wastes
that are physically harmful such as flammable or explosive and those with low
toxicity levels. The criteria for establishing the degree of hazard and the
need for regulation involves determinations amde on a case by case basis as
opposed to designating specific waste streams as hazardous and hence auto-
matically regulating them as they appear on the list.
Wyoming has developed ambient air quality standards and a state per-
mitting and monitoring system for the control of hydrogen sulfide and hydro-
chloric acid vapors;
Vermont uses the OSHA-developed TLVs to establish a system of prioritizing
and regulating air emissions for pollutants not federally regulated. The
state has an ambient air quality standard for lead emission, and is conducting
intensive monitoring of air contaminants (25% of which are known or suspected
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carcinogens) present in several residential communities as a result of wood-
stove use;
Delaware plans to use EPA-developed wastewater effluent guidelines on
toxics for 21 primary industries and 5 classes of toxic pollutant in issuing
NPDES permits for new and renewed discharges. The state is involved in a
lake and pond eutrophication program and participates in a regional ozone
study. The state extensively collects fish tissues and evaluates them for
the presence of heavy metals and organics,
In addition, Pennsylvania, Arizona and Kentucky are considering compre-
hensive toxics legislation. Arizona's Governor is currently putting together
\
a package of recommendations including suggestions for legislation designed
to cover all aspects of toxic substances control and to initiate comprehen-
sive management mechanisms to coordinate and streamline current practices.
The goal is to enable the state to have central coordination and control
over all aspects of toxics substances control, now dealt with by ten (plus)
state agencies. .
Group Z States
States included in this grouping include Alabama, Alaska, American
Samoa, District of Columbia, Florida, Georgia,* Guam,* Hawaii, Idaho, In-
diana,* Maine, Mississippi, Missouri,* Nebraska,* Nevada,* New Mexico, Ohio,*
Tennessee,* West Virginia,* and the Virgin Islands.*
*States for which additional information may indicate a change in grouping.
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"- '-:.:5 'laer.cv Manageme ic Mechar. isns: Nearly all states in this group
cc not use f;-iz~.} zswoisnt icnvrl-tees, ccrrrr^ss-ior.2 cy fscaessss. They rely
primarily on formal and informal temporary management mechanisms (i.e., cask
forces, workshops, committees) established on an ad hoc basis, and on infor-
mal information sharing among state program managers as the need arises.
Notable exceptions, however, include:
c
Alabama's Environmental Health Administration within the
Department of Health holds regular bi-weekly meetings
of representatives of the various state agencies having
responsibilities for hazardous substances management.
Meetings cover policy development, monitoring, regula-
ting, standards-setting, enforcement and audit issues
as they relate to the media, operations, and products
(i.e., air and water quality, hazardous waste, and pes-
ticide concerns);
since the early 1970s, Nevada has maintained an Environ-
mental Commission as a division of the Department of Con-
servation and Natural Resources. It consists of the
four heads of the Departments of Agriculture, Forestry,
Wildlife, and Water Resources, a representative from the
State Board of Health, and four public citizens appointed
by the Governor. The Commission meets regularly to dis-
cuss cross-cutting environmental issues handled on a day
to day basis by the representative departments. The
Commission is quasi-judicial and has regulatory and en-
forcement responsibilities.
Most of the Group Z States have established ad hoc temporary task forces
of earmittees or use informal work-group processes to address specific en-
vironmental issues or management-oriented problems. For example:
In 1979, Florida established an interagency Hazardous Waste Task Force
to review state hazardous materials emergency response operations and infuse
a multi-media approach in preparedness planning response activities and
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af ser-incident evaluations. The ultimate goal is to delineate relative stare
agency responsibilities for hazardous materials eraergency response operations;
.Mississippi's Bureau of Environmental Health conducts informal working
group meetings designed to examine coordination problems among the surface
and drinking water quality, pesticides, hazardous waste, and air quality
staff activities of the Department of Health, Agriculture and Commerce, and
Natural Resources. Their goal is to identify and address gaps and dupli-
cations in the management of environmental activities, especially those re-
lated to hazardous waste management ;
Tennessee's Governor has initiated an interagency review of hazardous
waste management options focusing on legislative needs, handling and dispsoal
practices, «*»«* inventories of hazardous waste generators;
Idaho has an interagency task force to improve the state's hazardous
materials emergency response capabilities and develop a written plan delin-
eating various state agency responsibilities;
has an interagency Groundvater Protection Commission reviewing
releva-.t authorities and problems pertinent to this aspect of water quality
a,TVj hazardous waste management, ""he Commission consists of representatives
from the Departments of Human Services, Conservation, and Environmental Pro-
tection.
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ritKO^i^nzl ir.zssra-:vn activities alaost entirely involve one-stop
permitting practices. Several Z States are actively working toward im-
plementing consolidated permit procedures and a few others are examining
their feasibility. Under its Environmental Procedures Coordination Act,
Alaska is instituting a consolidated permit application format and def-
initions for all related permitting regulations and coordinating these
c
efforts with EPA's master permitting guidelines. Single source permitting
in Georgia is accomplished by mandating that the Division of Environmental
Protection and the Department of Industry and Trade coordinate the review
of permit applications, the issuance of permits, and the follow up monitor-
ing of compliance with permit requirements. Mississippi coordinates per-
mitting practices by having all permits program in an informal way by hav-
ing all permit applications circulated for review among all relevant en-
vironmental program managers.
Approximately half of these Group Z States are preoccupied with writing
and/or reworking their hazardous materials emergency response plans. Al-
though some states such as Tennessee, have comprehensive plans in place,
others such as Alabama, Alaska, District of Columbia, Florida, Idaho, New
Mexico and West Virginia consider this aspect of hazardous substances manage-
ment a higher priority than others.
Other than the types of interagency coordinative mechanisms described
above, all Group Z states depend heavily on informal, ad Inoo information
sharing and coordination when the need is perceived by various program managers,
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Approximately sixty-three percent (.63%) of these states seem to rely almost
totally on this method.
2. Health Effects Monitoring and Studies; Sixteen of twenty Group Z
States evidence no health effects monitoring/study efforts, although con-
siderable interest exists among the states' health officials. Four states,
however, perform isolated studies or monitoring efforts:
Alaska's Department of Environmental Conservation is
studying the potential relationship between the dis-
ease giadiasia and chemical contaminants in drinking
water. It is suspected that the disease may be caused
by the transmission of unfiltered chemical contaminants
in surface waters;
Florida's Department of Health and Human Services and
the Department of Environmental Regulation are con-
ducting a joint study of the potential health effects
associated with toxic waste sites in the state;
Mississippi's chemical laboratory has a cooperative
agreement with EPA to study the health effects of
some chemicals and the Department of Toxicology of
the University Medical Center does research in iden-
tifying new treatments for human exposure to toxic
Missouri informally monitors the incidence of cancer
through its voluntary cancer registry.
3. Information Gathering: Systematic information gathering efforts of
Group Z states with regard to industrial chemical production and/or use
data is limited for the most part to hazardous waste generation and tracking
information (volume and type) and/or pesticide manufacturing and use data.
Mississippi, however, maintains a computerized list of chemical manufacturers
located in the state. Missouri has a voluntary cancer registry, and had pro-
posed a lav on cancer reporting requirements that was ultimately defeated.
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'* Caaputarlzatior. of Data; , Twa.cf..these states indicated that they
are currant!? computerizing hazardous vaste generation data and seven states
are studying the feasibility of,or are actually in the process of, computer-
izing manifest system reports, pesticide data, or vatar quality data, Alaska,
however, is studying the feasibility of implementing a state-wide management
information system to include all data necessary to characterize the environ-
C
mental conditions in the state.
One state reported use of CHEMTREC and OHMTADS and three states reported
that on occasion they use the 7SCA inventory data available through EPA.
5. Individual Environmental Programs/Nature of Toxics Control Activities:
Approximately ninety percent (90Z) of the Group Z States have assumed
basic enforcement responsibility from the federal government in three or four
out of the seven key environmental programs. Approximately ten percent (10%)
have assumed primary enforcement responsibility for six out of the seven pro-
grams. For the most pare, these state-run programs adhere directly to fed-
eral guidelines. Approximately seven states report some specific activities
designed to document and control toxics problems, especially in water quality,
while the remainder have toxic-related activities planned for future imple-
mentation.
Examples of some of the more interesting of these states follow.
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Alaska is currently conducting an ambient air lead study a-d organic
and inorganic chemical analyses or drinking water samples. The state's five
year plan places increasing emphasis on monitoring and testing for toxics in
the water quality programs, and doing more laboratory analyses of organic,
inorganic, trace elements, turbidites, and bio sampling for specific toxics
found, and linking them the NPDES permitting practices;
The District of Columbia will be developing a plan to deal with toxic
chemical wastes of hospitals and laboratories, establishing an air quality
monitoring network for measuring lead concentrations, and assessing the de-
gree of toxics problems in the area;
\
Georgia will sample state waters for toxic substances and initiate con-
trol through 2JFDES permitting program. The state will also initiate vola-
tile organic chemical regulations for the air program;
Idaho will be examining toxic disposal of waste and toxics chemical
storage problems in a selected county and will develop a state-wide program
on the disposal, storage and use of toxics containers;
Indiana is looking for ways Co enhance inter-program cooperation for
using data collected on toxic substances;
Maine has developed regulations on air emissions of sulfur compounds,
and will develop an acid rain monitoring and analysis program. The state is
currently studying and documenting ozone violations;
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The Dep<=rr=erit of Toxicology ac Missis?!.1*3 University Medical Center cu~-
reatly =a.r.taias information on all :o::ic subs ranees -ade, sold and used :...
che dtate along with records of toxic substances, their chemical and physi-
cal aake-up, effects on humans and recommended treatments for exposure, and
provides a 24 hour information service to public citizens and government
officials;
Nebraska is currently monitoring groundwater and landfills for toxics
and will develop post-emergency lafa support capability and timely access to
toxicological and medical data;
New Mexico has a groundwater monitoring program which emphasizes toxics
identification and is in the process of rewriting regulations to require all
those discharging toxics into groundwater prepare detailed plans specifying
type, quantity and concentration of the toxic discharges. The state pes-
ticide program regularly exchanges technical information with the State Poi-
son Control Center;
West Virginia is currently monitoring for toxics in drinking water.
The state would like to expand interagency coordination beyond emergency
situations and begin to unify approaches to toxic substances control. Also
it will be developing a plan to evaluate acid mine drainage problems through
sampling and analysis as a first step toward designing an acid rain manage-
ment program;
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Intargroug Goners.;"
Contrast betveen i::e three groups across che five descriptions
an understanding of how their needs differ.
Intergroup Coordination , Communication & Cooperation : In general , all
C
X States encourage interagency coordination, cooperation and communication
through the institntionalization of a toxics integration strategy. This
strategy is implemented by a relatively centralized coordinating mechanism
with specfically designed management tools. About 75" of Group Y States use
various forms of permanent interagency coordinating mechanisms to integrate
like environmental activities. These, however, are organized around the fo-«
eal points of hazardous materials emergency response, transportation opera-
i
tions or hazardous waste management rather than ccxics. Tew of the Group Z
States use permanent interagency committees, consuls sion:: or boards to inte-
grate broad environmental management concerns. Rather, Z States use temp-
*
orary interagency task forces to develop policy and recommend activities for
handling very specific Issues (e.g., hazardous waste siting as opposed to
overall hazardous waste management).
On the whole, 1 and Z states use more ad hoc task forces than X states
which for the most parr, rely on subcommittees for studying specific issues.
Neither Y nor Z States reported any specific toxics control ad hoc groups or
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--_:-': forcas, although toxics issuer --robsbly arise wi:'-,;-.: task forces on
esergency management, hazardous waste, .^roundvater, and -o forth.
On the whole, X States integrate toxics activities through the estab-
lishment of clearinghouses, central repositories of information, formal in-
formation sharing tools such as hazard alerts, memoranda of understanding
c
and joint permitting practices more than other states. Although Y and Z
States do integrate like environmental management functions to some extent,
their efforts primarily center in response planning.delineating appropriate
state agency roles for crisis situations, one-stop permitting and some con-
solidation of laboratory services. Y, and especially Z, States rely heavily
on informal networking and information exchanges, and most informal informa-
tion sharing takes place under emergency conditions. Approximately 902 of
the Group Z States rely almost completely on ad hoc intaragency coordination
through temporary task forces or informal channels for day to day concerns.
State organizational arrangements have evolved as a result of: a specific
emergency situation or threat for which a temporary task force is established
to coordinate agencies' response to pollution accidents Ce.g., spills or per-
vasive PCS contamination of gtrLmgl feeds) or a series of mismanaged pollution
crises pinpointing the need for permanent coordinating mechanisms.
Group X States recognize a need to establish formal mechanisms and a
systematic approach toward environmental management that encourages regular
exchanges of information. Having experienced severe toxics crises, (e.g.,
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Lcvi Canal ia Hew York and kepone contamination in Maryland and Virginia).
having accumulated alarming environmental quality data and observed distur-
bing trends in disease incidence, these states have integrated environmental
management around a toxics focus and are actively striving to be proactive
and comprehensive in their management schemes. Reduction of the quantity
u
and type of pollutants entering the environment and long-term protection of
human health through their various program activities highlight their pro-
active orientations.
Many of the permanent organizational arrangements of the Y States and
task forcing of the Z States demonstrate that their concerns rest in the
emergency management, transport and hazardous waste areas. lit emergency
management, longrange prevention or reduction of damages activities center
in mitigating a spill or other hazardous materials accidents. Mitigating
the immediate and longer-range health effects that may be associated with a
chlorine leak, for example, is apparently not as much of a concern as it is with
the X States. Hazardous waste issues tend to be viewed in terms of cleaning
up abandoned sites and tracking waste through the manifest system to be sure
that undesirable dumping does not continue to plague the future. Y and Z
States do not seem to be initiating strong action to reduce the amount or
/
type of toxic wastes or to be addressing the health implications related
to hazardous waste sites. Whether pollutants should or should not be en-
tering the environment because of their potential long-range health impli-
cations is not of key importance. Rather,effort is focused on what level
is tolerable as prescribed by the federal government. Both questions need
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co be ask^d ; H owever, the key differatice is that X States ask bcr>., while
" and Z Scaiis seen only to ask the lacter. While most Y States ^r.d a few
Z States shov a concerted effort toward ensuring raore integrated environ-
aental aanagesent, the tendency remains . scmewhat reactive and piace-
ceal rather than proactive and comprehensive. The kind of issues they de-
teraine as necessitating interagency coordination, the issues that aay be
c
overlooked in the process, the membership of the interagency bodies (rev
have a public, occupational or environmental health member), and the
apparent lack of activity in the area of long-term health hazard impli-
- cations all point to this conclusion. This seems to be even more true of
Z States.
Officials of Y and Z States have mixed feelings about the effectiveness
of formal interagency mechanisms to enhance coordination, cooperation and
consaunication. Some feel they increase turf problems and slow down pollution
control progress by creating another layer of bureaucracy with more paper-
work and red tape. Others feel they decrease turf problems, provide a
aechanism for increased awareness of what others are doing in similar areas,
enhance the possibilities of exchanging notes on respective staff experiences/
expertise that may help others with similar problems, and in Che long run
nay help to achieve more comprehensive management of hazardous materials.
Host states agree, however, that regardless of the disadvantages, interagency
coordinating mechanisms do increase awareness of the activities of their
counterparts and as such provide a forum for greater information sharing es-
pecially among those state agencies that rarely communicate on a regular basis.
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In addition, about 252 of che Z States specifically mentioned the need
far acre formal aaaagement strategies designed to effect coordination of en-
vironmental policies and their implementation.
All things considered, ad hoc networking remains che predominant method
for fostering coordination andccommunication among Y and particuarly Z States
for most environmental issues. We surmise that such an approach results in
serious gaps in the state's ability to-coordinate, communicate and cooperate
sufficiently to foster comprehensive environmental management that prevents
problems. Fostering effective ad hoc, informal communication depends on the
program manager's awareness of who is doing what in the state bureaucracy,
the existence or non-existence of turf problems, the amount of time available
s
to share knowledge, and the perception of the importance of information shar-
ing on a day to day basis.
la addition, hazardous materials emergency response is the predominant
area in which 7 and Z States formally and informally cooperate and exchange
information. Emergency situations are by no means the only arena where co-
ordination, cooperation and communication must occur for effective manage-
ment. A pollution incident is not really perceived as an emergency until
it reaches the proportions of a Love Canal or an accident such as a chlorine
tank spill producing an instantaneous explosion. For most states, the con-
cept of a hazardous material emergency does not include the concern for
potential long-term health implications and the effects of degradation of
the environment. Nor does it include concern for acute health effects that
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zay result during cr afrer a discrecs'-hazardcus -acarials incidenc in addi-
:ion to che traditional emergency medical concerns. The concept of emer-
gency also dees not include the element of crisis mitigation through the re-
duction of the nunber and type of pollucants entering the environment on a
day to day basis. If formal interagency sechanisms are primarily designed
to handle crises or a limited number of concerns, if the view of environ-
mental emergencies remains narrow, and if most organized information sharing
takes place on an ad hoc basis, or organized basis only for crises, states
should question whether they are perhaps overlooking vital environmental
management elements and whether a more comprehensive strategy should be de-
vised. Serious consideration of these potential deficiences is warranted
in Y and Z States; also, X States should evaluate the extent to which their
proactive orientation and "comprehensiveness" are implemented at the opera-
tional level.
Health Sffacts_Monitoring_& Studies: Group X States are much aore sophis-
ticated than others in health effects monitoring and studies. They are doing
significant work in environmental epidemiology and toxicology, and are sys-
tematically collecting or establishing tools to collect illness and disease
incidence data (e.g., cancer registries, worker exposure/illness data or in-
formation on the extent of hospitalization due to toxic exposures). Several
Group Y States have undertaken significant, but ad hoc, health effects
studies and a few have attempted to collect disease or illness data. Most
Group Y State health officials are intensely interested in this field. Z
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Scares, as a whole, have done very little in this area, although four stacks
documented specific ad hoc efforts.
Y and Z states find their toxics activities somewhat hampered by rela-
tive lack of health effects study and monitoring. Those states that are
making concerted attempts are such closer to being able to document, analyze
and ultimately control toxic contamination effectively. Systematic collection
of health data remains a vital component for toxics control as evidenced by
X State activities. This usually requires lavs mandating worker illness,
physician documentation and disease incidence reporting to the state. Infor-
mation gathering requirements that sufficiently protect the privacy of indus-
try and the public but are more specific than traditional emergency health
authorities are needed, yet they are apparently lacking in most of the 7 and
Z States. Efforts need encouragement where they do not exist, and technical
and f-ttwif-fgi assistance to further work already begun.
Information Gathering: Systematic collection of sophisticated production
and.use data on a prioritized number of chemicals, or plans to do so, charac-
terize X States. Group T and Z State efforts are primarily centered around
collecting hazardous waste generation and/or pesticide production and use in-
formation.
The extent to which production and use data is collected on chemicals
other than pesticides, and substances other than waste, is an important as-
pect of proactive toxics management. Those states that are predominantly
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cal users, as opposed to pr^cucers, will have different problems.
Their concerns nay resc primarily vith worker expcsuras to chemical process-
ing in che industrial complex. In =any ways, the ability of a state to regu-
late _ chemical use properly and procect its workers will depend not only on
its perceived need to do so, but also on the proper labelling of chemicals
produced in another state and the knowledge it has of what is being used in
the state. The extent to which proper labelling is not provided and the ex-
tent to which the state using or producing chemicals does not know what is
being used or produced in its industrial complexes hampers the state's abil-
ity to protect public and worker health.
Understanding the properties of chemicals used or produced in a state
(concern over chemicals at the beginning of the life cycle as opposed to
siaply at the end of it, i.a,, waste) and not just limiting such, knowledge
to pesticides could assist orates in their public protection roles. With-
out adequate information to characterize vulnerabilities, control strategies
become irrelevant.
Computerization of Data: Three quarters of Group X States have computer-
ized, or are planning to computerize, data of one kind or another (e.g., waste
manifest, water and air quality, pesticide, health effects, and chemical in-
ventory data). In addition, six states have developed, or are planning to
'develop, elaborate computerized management information systems for integrat-
ing diverse kinds of environmental and health related information retained
by the state and available from other data sources. Many of the X States
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extensively use, or are planning zo use, federal and private computerized
data bases such as CHESISEC, OHMTADS, CEEMLEIE, MEELINE, TOXLINZ, STORE!,
SARAOD, CANCERLDiS, UPGRADE. About half of the Group 7 States are compu-
terizing some data, mostly on an ad hoc basis, with fev states1 using fed-
eral or private computerized data bases. Those mentioned, however, were
CHEJUREC, OEMTADS and STORE!. cNo comprehensive management information sys-
tems were reported as in operation or planned among the Group Y States.
Nearly half of the Group Z States are computerizing some data or are planning
to do so, however, most are in the planning stages. Few Z States make use
of federal or private data bases.
Very few states across all three groups mentioned the use of the TSCA
^
inventory data. States' comments as to why they do not do so include: usu-
ally the data that the state needs is confidential; slow turn-around time
when requesting TSCA information from EPA, and the state usually needs to
know as soon as possible; and the TSCA inventory is of little help when
trying to determine the possible effects of a chemical mixture as data con-
cerns pure substances. Complaints about the usability of the TSCA inventory
data usually were made by Z States, while few 7 or Z States have used the
data and hence had no comments. The drawbacks to the use of TSCA inventory
data have prompted X States to do their own chemical inventories.
The relative lack of computerization of data and the use of outside
data bases can hamper states' trying to manage diverse kinds of data. Com-
puterization would allow for more rapid and efficient use of the data collected.
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Management information systems, especially thoss chac are interactive ar.c
for which data can be entered systematical!;/, would enhance sraces' abi_itv
to observe trends and make correlations. The correlation of various kinds
of data is necessary if states are going to document health effects so that
appropriate control actions can be initiated.
The relative lack of computerization, and especially the use of existing
federal data bases by program managers, could reflect three problems: non-state
use in general; the lack of communication between computer and technical special-
ists and environmental managers; i.e., between those who actually use these
systems and those who could make use of the information for decision-making
purposes, or lack of sufficient knowledge about existing data' bases at state
and federal levels and/or federal and state communication gaps. Environ-,
mental, managers need to become wci're- -vare of the benefits of computerizing
state data and using federal and other private data bases. Funding is a
basic obstacle; however, if states could see the costs and benefits they might
spend scarce funds in this area. In addition, the on-line and subscription
costs of federal data bases may be prohibitive and centralized servicing of
information requests should be explored.
Individual Environmental or Toxics Programs; Eighty three
percent (83Z) of Group X States possess strong individual programs in six
of the seven environmental program areas reviewed. The other states have
assumed basic enforcement responsibility from the federal government for five
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cut of che seven. Through toxics integration strategies, Group X Stares are
systematically incorporating toxics control activities into environmental
management. Fifty percent C50S) of Group Y States have strong individual
programs in 6 out of the 7 areas and the remainder, 4 out of 7. These states
as a whole have not, however, systematically infused toxics control action
into overall environmental management as Z states have, but do engage in
some interesting toxics control efforts on an ad hoc basis (usually within
the water program areas). Ten percent C10Z) of the Group 2 States have as-
sumed basic enforcement responsibility for 6 out of 7, the remainder have
done so for 3/4 of the the 7. These states place relatively little em-
phasis on specific,toxics control activities within individual environmental
management programs, although concern for toxic problems exists. Much of
\
their effort is apparently going into assuming basic inforcement responsib-
ilities.
It appears that having strong individual programs may be a necessary
first step prior to assuming the task of creating overall management strate-
gies to coordinate programs and incorporate a toxics emphasis as appropriate.
States working on establishing a viable water quality program or passing a
hazardous waste management act in order to be able to assume federal re-
sponsibility may not have the time or the resources to spend in looking at
the whole picture. To the extent they can be encouraged to look at the
management aspects while implementing individual program pieces they
should be". Suggestions obtained through information sharing with other
states may be helpful in raising toxics integration management issues.
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In addition, states beginning td' Imp lament environmental cualiiy soni-
teriag programs, upgrade and expand laboratory and enforcer-eric staff capa-
bilities are ac the stage of assessing their vulnerabilities. Obviously this
is a necessary step prior to being able to initiate control stracegias.
Characterizing a state's environmental quality with respect to tcxics is>
additionally,more complex and requires strong support capabilities to be
firmly in place in order to assess the state's toxic vulnerability in par-
ticular. Those states that are well along the way toward iapienenting strong
programs will be more ready and able to look toward better aanageaent tactics
for comprehensively handling problems in a more coordinated way. Mere re-
sources can then be freed up to concentrate on specific, complex toxics
problems identified by the various individual programs. Also,resources could
be freed up to concentrate more on human health implications inherent in toxics
control rather than simply concentrating on the environmental degradation and
enforcement of the federal pollutant criteria standards. Given a more favor-
able climate, creativity in management strategies might then ensue.
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TOXICS ACTIVITIES WHICH "X" STRATEGY STATES APPEAR TO EMPHASIZE
(Omission of certain activities does nbt mean they 4" not exist, in Lhe state. Tlieua ar« emphuuus,
ORGANIZATION
State Agency Toxics Office
X
X
X
X
X
X
X
X
A
1*
Interageney Committee/Task Force
X
X
X
X
X
X
X
X
Governor's Office Lead
X
X
X
X
X
Public/Industry on Committee/Task Force
X
X
X
X
K
LEGAL AUTHORITY
Executive Order
X
X
X
X
X
X
X
X
X
X
X
Regulatory Authority
X
X
X
X
Planning Authority
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ft
&
H
J?
i
a
1
I
X
X
D
X
P
X
1)
Assessment of Economic Impact
D
X
D
P
MECIIAt
INT
Formal Interageney Agreements
D
X
n
Tl« nf F-«"tel"?T»e A.ditrlm-ist-rmti'W* StMieturftS
'
1
1
1
1
1
X
X
X
X
X
X
X
X
X
X
X
ust
GR
Resource Sharing
P
D
P
X
i
X
X
1)
IS FOR
TION
f
4
(A
t
&
U
g
rl
U
i
p
D
D
X
P
Consolidated Permit Process
P
I
D
D
D
Involvement of Educational Institutions
,x
X
'x
X
X
j
1
X
IH FORMATION GATHERING
AND PROCESSING
Inventories of Chemical Production/nee Dara
P
X
X
D
X
Industry Information Disclosure Requirements
X
X
Chemical Hazard/Priority Assessment
D
D
D
X
X
D
P
P
X
8
H
1
H
H
D
p
X
X
X
X
Chemical Data Registry /Resource Center |
P
X
D
X
X
1)
II
u
1
3
S
1
I
C
J
r-
a
T
t
1
*
i.
*
C
t
i
.
i
P
D
D
D
D
P
D
P
Agency/Cons&ittee Annual Reporting Requirement ]
X
X
| Agency Management Inventory/ Directory
P
X
OTHER TOXIC}} STATE ACTJVJTI1S
Health Effects Studies/Monitoring
X
X
X
X
X
X
X
X
| Development of Scientific Testing Procedures |
D
X
X
X
D
| Development of Chemical Use Standards |
X
P
X
Investigations j
X
X
X
X
X
X
x
Penalties/Enforcement Focus |
X
JL
X
X
b
f
T
1-
(V
3
i
^
u
u
5
n
1
i
1
I
i
1
D
0
X
X
P
X
p
j Training - j
X_
X
| Local Involvement |
P
X
P
2?
1 State-Ir-dustrv Chemical Informatics Exchanges
P
X
X
-
p
| State-? saeral Activity Coorcinatirr.
I)
X
K
X
X
P
X
X
( Public I _£ or=ation/?2rticipatios i
p
I'Rjoimu;-:
j Reauctisn of Toxics Use/Exposure
X
X
A
X
x.
X
1
1*
u>
s
r\
1
M
O
o'
m
o
«
n
f
r
t
r
£
X
X
X
X-.
X
£.-
\ Intensify Health Effects Studies/Jfonitcring
X
X
A
X
Expand Inf creation &a: Baring Activititf
X
X
X
-------
V. STO2SABY OF STATE DANGEROUS CHEMICALS MANAGEMENT ?! -ITICZS
This compendium summarizes specific state chemical management practices
and activities which promote the concept of integration among all enviror^-r.-
tal media, operations and management functions. It is divided into three
broad parts on strategies, legislation and specific innovative or noteworthy
programs.
We have chosen to summarize management strategies, legislation and inno-
vative programs with a sampling of state activities, rather than "laundry list"
piecemeal descriptions of every state and territory. This reflects the fact
that the vast majority of states do not function under an integrated toxics
control strategy synthesizing all toxics-related programs and activities, but
many have specific programs worthy of inclusion in an integrated state strategy.
The twelve states found to operate under an integrated toxics strategy
are documented. It should be noted that this summary does not profess to in-
clude all innovative toxics-related state programs, but merely is as thorough
a sampling as could be compiled from the interviews and materials provided by
state officials. All fifty states and territories were contacted and mater-
ials on each were received, developed, compiled and analyzed, with the excep-
Mon of Oregon, North and South Dakota, and the Northern Mariana Islands which
were not completed due to time constraints.
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Examples included were chosen to provide useful information for gover-
nors, their aides, state officials and other managers responsible for control-
ling the adverse impacts of chemicals in the environment. It is recognized,
however, that some programs may have undergone changes, or may be even further
developed than indicated at the time the data were obtained in the fall of 1980.
It is, of course, impossible to include all the organizational, admin-
istrative, legislative and funding details one might wish to read here about
individual programs. For this reason, two key contacts (the designated gov-
ernor's aide and state agency official) for each described state strategy or
program appear at the end of each description. Also, a full list of contacts
reached in all states and territories appears in Section V. They may be con-
tacted by any reader who would like to obtain more detailed inf onaation about
any state toxic management programs or activities.
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State Toxics Integration yaaaeenent ^Strategies
This part of the report examines tweleve state integrated toxics manage-
ment strategies. It includes factors such as the impetus for the strategy,
legislative authority, date and extent of reorganization or institution, ob-
jectives and current implementing activities.
ARKANSAS
Arkansas' strategy for integrating toxics substances management was ini-
tiated from recommendations of a state Toxics Substances and Hazardous Mater-
ials Policy Committee. This Committee was established by Executive Order 78-2
in 1978 for the purpose of conducting an in depth study of the nature of the
toxic substances and hazardous materials problems in Arkansas, their cause(s)
and their potential solutions. It is comprised of representatives from the
state departments of Labor, Office of Emergency Services and Governor's Office.
On December 22, 1978, the Committee forwarded a report to the governor
entitled, "On the Arkansas Strategy for Toxic Substances and Hazardous Mater-
ials." It recommended a state toxics control strategy involving a "workable,
highly visible framework for decision-making, prevention and control within
all affected levels and branches of government."
In preparing the study, the committee conducted numerous public hearings
and interagency meetings, as well as a survey and analysis of all relevant
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stace and federal programs with authority ST application over the manufactura,
transportation, use and disposal of tcxic suostances.
The report addresses the following toxics management problems in Arkan-
sas:
1) continued pressure for-economic and technical growth;
2) a depleting resource base;
3) lags in and misdirections of earlier government Cstate and
federal) programs;
4) inadequate knowledge of chemical effects (environmental and
health);
5) lags between the creation of chemical-related problems and
their wide-spread recognition;
6) inadequate systems to properly manage pertinent information
(e.g., interactive data system); and
7) institutional arrangements which result in economic;, techni-
cal and environmental decisions to be made without due con-
sideration for the total impact of such decisions.
The state decided to institute a strategy through which diverse activities and
participating agencies could be coordinated, with their efforts targeted toward
specific areas of responsibility consistent with existing resources and stat-
utory authorities. Accordingly,- a four-tiered organization involving the gover-
nor's office, the Committee, working committees established under the Committee,
and participating state agencies was established, rather than a new centralized
state management authority.
Arkansas' Toxic Substances and Hazardous Materials Committee focuses on
coord-tnating and orga^zing all dangerous <*h«»*cal management activities across
state agency tines, across various environmental media, operations, products
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and gc--5 .-.sent management functions. " Thus, the Corarnlttee's scope is vicar
than TS3»z of the existing hazardous materials committees in other states.
For example, the Committee established a Prevention and Control Subcommittee
responsible for a consolidated permit program which is one of the few attempts
we found to review industry permits strictly in connection with toxic sub-
stances.
- The Arkansas plan also initiates toxic substances management in the exec-
utive branch, and utilizes existing state mechanisms rather than increasing
state regulatory agencies or programs. Although the strategy is in the early
development stages, with subcommittees being established and information gath-
ering activities still needed in order to design specific programs, it is evi-
dent that Arkansas' 'approach incorporates its perceived needs and existing re-
sources, with attainable state goals.
Prescribed activities of the strategy are clustered into five principal
management areas;
1) intergovernmental cooperation and coordination
2) information management
3) hazard assessment
4) hazard prevention/control
5) crisis response
The Committee, working with the governor's office, is primarily respon-
sible for intergovernmental cooperation and coordination. To do this they:
1) gather and disseminate information
2) solicit public comment
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3) establish cross agencv reporting methods
4) improve coordination between state and federal programs
5) examine state agency hudgets for the most efficient means
of implementing the strategy
6) encourage a ran 1M-agency approach to problem solving
7). promote interagency pools of specialized equipment and
supplies
8) review lavs, regulations and programs concerning radio-
active materials
A Subcommittee on Information Management will examine the use of common
computerized data bases and recommend a shared management information system.
Various duties and responsibilities are assigned to the agencies working on
this particular subcommittee. Several interesting aspects of information
management will be addressed by the subcommittee:
1) assuring the integrity of data and information;
2) use of existing data bases such as CHEMTREC, OHMTADS, etc.;
3) examination of industrial use and potential toxic chemicals
exposures, especially in regard to plant conditions; and
4) inclusion of existing priority lists, alert notices for po-
tential problems, and institution of a central computer
file for such lists and notices.
The Subcommittee on Assessment will design a program to monitor the ef-
fects of dangerous materials on the worker, environment, food and public water
supplies. This program will include trend analysis, epidemiological studies
and monitoring of water, soil, food, human tissue, aquatic life and the work-
place, and TH»«»haTH gma to retrieve reports on toxcity, unusual exposures, and
relevant health information registries. The subcommittee is also charged with
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the development of agencv reporting and assessment procedures to elicit in-
formation from which the subcommittee can develop recommendations. The sub*
committee will also examine trend data on state economic dependence on haz-
ardous substances, and identify the economic and institutional factors af-
fecting the development of alternatives.
The Prevention and Control Subcommittee will develop alternative ways to
reduce the use of toxics and hazardous materials. Rather than create any cen-
tralized regulatory programs, the goal is to extend existing regulatory au-
thorities and activities to accommodate local needs and incorporate opportunities
available under federal programs. This requires examining existing regulatory
and preventative programs to identify gaps, overlaps and inconsistencies, pro-
mote public awareness of the regulations,,and provide for modified or consoli-
dated regulatory programs were appropriate. The subcommittee will consider
modifying permit procedures required under the state air, water, land reclama-
tion and solid waste acts in order to integrate state and federal permit OTO-
gr»ma. Committee tasks may include:
1) consideration of total environmental and health impacts
of any facility;
2) solicitation of public comment prior to permit issuance;
3) formalizing procedures for gathering toxicological in-
formation from industry;
4) promoting a regular flow of chemical-related data from
the permit process to state data base; and
5) requiring that snill prevention and contingency planning
be a permit requirement.
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A Crisis Response SubconHn-tetag is responsible for coordinating =rs::s-
portation-ralated chemical emergency response through various agencies.
Training of local emergency medical personnel is identified as an important
element of crisis response and will be a subcommittee concern. Additional
tasks include:
1) identification of high1"density risk areas;
2) payment of cla-ims to widows and dependent children of per-
sonnel killed while on duty;
3) establishment of a contingency fund for protection, analytic
and communications equipment; and
4) consideration of emergency services office's need for author-
ity to coordinate resources in crisis situations
At a time when' an increase in regulatory agencies and activities is
viewed as ^necessary and wasteful, Arkansasf approach to managing chemicals
on an iacegracaa -
-------
CALIFORNIA
^ aa effort to achieve aaximun coordination and cstnnunicatlon aaong
various state agencies and their toxics control activities, a California
Toxic Substances Coordinating Council was established by executive order in
February of 1980. The Council functions primarily to coordinate and to
inate duplication and gaps in state toxics management activities.
C
Heads or deputies of the following agencies sit on the Council:
1) Department of Industrial Relations (occupational health
and safety)
2) Air Resources Board
3) Water Resources Board
4) Department of Health Services Cdrinking water and haz-
ardous waste)
5) Department of Food and Agriculture (pesticides)
6) Department of Human Resources
7) Department of Business and Transportation (hazardous
materials transport and spill cleanup)
The governor's representative serves as the unofficial chairperson or coordin-
ator of the Council.
Public concern and media coverage of growing and complex problems assoc-
iated with toxic chemicals, in concert with the executive branch's involvement
with the Federal Inter-Regulatory Liaison Group (ISLG) led to creation of the
state strategy and council. Under an executive order, the Council is author-
ized to coordinate state toxics management activities either through policy
integration or coordinating interagency actions such as joint hearings, in-
spections, monitoring and laboratory analyses.
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The Council is developing a state policy for aaaaging carcinogens within
all environmental aedia (air, land, water, workplace). The Council will have
ao regulatory authority over the policy, but ic will encourage integrated reg-
ulation development by the separate agencies on the Council. California cur-
rently has a carcinogens act which relates solely to the occupational environ-
ment, requiring carcinogen users to report exposure and commerce-related infor°
mation to the Department of Industrial Relations. The Council's carcinogenics
policy would substantially expand the scope of the present carcinogens act by
covering all media, operations and management functions associated with car-
cinogenic substances.
The State toxics strategy emphasizes information exchange, penalties for
*
violations of toxics-related regulations and, wherever possible, incentives
for industry compliance, rather than focusing solely on the development of
more extensive regulations. The forthcoming carcinogens policy mirrors this
approach, with no intent by the Council to develop carcinogens regulations.
It is projected, however, that the separate agencies will ultimately develop
requirements for controlling and reporting information on carcinogenic sub-
stances thus providing a comprehensive, integrated carcinogens policy for the
entire state.
Through the Council's work on integrating toxics management activities,
concensus on the following priorities.have evolved:
1) reduction of the overall use of toxic substances;
2) recycling and other waste reduction activities;
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3) cl-sam:? and reduction of health and environmental damage
due ca chemical exposure.
Governor's Office Contact
Mr. 'Peter Weiner
Special Assistant to the Governor
for Toxic Substances Control
Office of the Governor
Sacramento, California
(916) 322-7691
Agency Contact
(Same as the Governor's Office)
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ILLINOIS
Illinois' strategy coordinates Department of Public Health and Illinois
Environmental Protection Agency activities, and also includes activities of
the state Pollution Control Board, the Illinois Institute of Natural Resources
and the state aedical and educational community. In addition, the state has
incorporated "uabrella" definitions and coordination powers into the Illinois
Environmental Protection Act of 1970 as amended. This is further described
in the next part of this report.
The Department of Public Health, one of -the tvo major agencies implemen-
ting the state toxics strategy, has operated an informal incident response
program since 1972, and it was formalized in 1978. The Office of Health Reg-
ulation, in the Department's Division of Environmental Health and Sanitation
administers the Environmental Toxicology Program, the broad objective of which
is to collect and analyze information in order to determine the relative con-
tribution of environmental factors to disease incidence. To the extent pos-
sible, the program is also responsible for recommending environmental control
activities designed to reduce the occurrence of such diseases.
The Environmental Toxicology Program staff conducts investigative, sur-
veillance, analytical and educational activities and obtains information on:
1) human health effects of toxic chemicals;
2) interaction of multiple chemical agents;
3) scientific bases for criteria and standards development
for chemical-related evaluations; and
4) risk/benefit analysis for evaluating the economic impact
of recommended control methods.
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The main goal of trie program' involves developing an effective
cations network among state and federal agencies, health professionals, phy-
sicians and universities as necessary. The state also hopes to increase the
probability of receiving early warning of potential hazards through the com-
munication network. The formation of an intra-departmental environmental
health task force constituted the first step in implementing this goal. The
"" ~ ~~~~""~"~~^"^"~~~~~~ !_
task force is responsible for establishing clear lines of communication be-
tween the Department of Public Health's environmental health, laboratory,
epidemiology and biostatistical experts, as well as relevant federal agencies,
and other state and local health officials.
To date, this communications network has investigated and fostered inter-
agency communication only on a problem-specific basis . The Department of Pub-
lic Health has proposed the following additional activities:
1) identifying potentially cooperative agencies, institutions,
groups and individuals and listing a primary contact for
each;
2) compiling a guide identifying applicable programs including
research, laboratory, data management and investigation
capabilities of those listed in number (1) above; and
3) developing a workshop for participating network personnel
to describe the objectives and workings of the network.
The type of information sharing the state wants to encourage through this
network primarily involves:
1) human or att*TK*l illness or death caused by exposure to a
toxic substance;
2) unusual illness or death in which toxic substances are sus-
pected but not confirmed as contributing factors;
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3) results of investigations cf toxic substances incidents;
4) routine and special re-oorts jf environaental aonicoring
in the state; and
5) results of research that =ay be of use in future investi-
gations .
Emphasis will be on extensive coverage through local agencies and indivi-
duals who contact the public, and the information will be compiled and period-
ically analyzed for state and national trends and comparisons, in order to
identify emerging hazards.
A second major program goal is to expand the existing surveillance pro-
gram to investigate acute exposure and more long term health effects studies.
Some of the completed research includes:
1) a study of approximately 360 households where the chemical
Lindane had been used for over twenty years, conducted in
cooperation with EPA and the University of Iowa;
2) a community assessment in central Illinois to identify health
effects resulting from exposure to selected chemicals, es-
pecially exposure to an organic phosphate compound during a
major fire in northern Illinois; and
3) studies identifying numerous pesticides and related products
as well as PCBs In state waters, finding that fish in some
areas often fall to meet FDA requirements for mercury, PCBs,
and other residues.
The state recognizes that, unlike more traditional public health programs,
the methodology for studying effects of environmental chemical exposure has
not been fully developed. Investigative techniques, laboratory procedures
and environmental epidemiology methods must be developed through the experience
of public health officials in responding to actual chemical exposure incidents.
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At the present time, field investigation is a major emphasis of the
state Eavironnental Toxicology Progran, vith central and regional office
staff combining their expertise to design and execute investigations of toxic
exposure. However, insufficient field staff, a growing case load and a lack
of adequate technical procedures for identifying the sourceCs) of exposure,
present severe limitations.
Criteria to identify cases of toxic exposure is the highest investiga-
tion priority of the surveillance and field investigation staff. The infor-
mation needed for review in making such a determination includes:
1) the toxic substances involved;
2) available analytical methods for detecting toxic substances
in humans and the environment; and
3) whether the impact may be to an individual or have potential
broad public health impacts.
Questionnaires and samplings of appropriate media (air, water, food, soil,
human and *n-;mai tissue) will be issued, and investigative teams including a
physician, biostatistician, monitoring expert, laboratory staff member, epi-
demiologist and an environmental health professional will be organized. Lab-
oratory analysis will be done at the Department of Public Health's Toxicology
Laboratory in Chicago. This lab has a great deal of experience in forensic
science and has access to the University of Chicago School of Public Health's
environmental laboratory facility.
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The Illinois Environmental Protection Agency (IZ?A) has priaary respon-
sibility for protecting the public from toxic and carcinogenic environmental
pollutants through regulation. The IZ?A operates extensive air and water
acnitorlng programs, including monitoring for non-federally designated contam-
inants, organic chemicals, pesticides and other toxic contaminants. One study
involving trace organics contained in industrial effluents, has resulted in
the development of new sampling methodology and equipment specially designed
to reduce sampling collection errors.
The IEPA, with USEPA Region V assistance, has also identified and prior-
itized the major chemical industries that discharge pollutants into state
vaters. For over two years, selective facilities have been sysgo^atically
*
\
sampled, with many carcinogens identified in discharges. Work is presently
underway to characterize the composition of municipal facility discharges
subject to pretreatment standards, using a method of simultaneously testing
for toxic compounds known as the Ames in vitro test.
The IZPA is setting up a network of biologic monitoring stations to pro-
vide biological (pathologic,' bioaccumulation and mutagenic) data which could
possibly be used to establish a state water monitoring program for toxic and
mutagenic compounds.
Beyond the activities of these two agencies, the Illinois Pollution
Control Board exercises quasi-legislative and judicial authority over state
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environmental cone-ems, conducting 'heirir.^- jn violaticns of environaenca".
scandards and regulations, reviewing petr'-ictis for variances and reviewing
denial of permit decisions, in addition to reviewing -and adopting environ-
mental regulations. The Board, established by the Illinois Environmental
Protection Act of 1970, is an independent body comprised of five technical
experts appointed by the governor for three-year terms, with no more than
three being of the same political party at any time.
The Illinois Institute of Natural Resources, established in the 1978
amendments to the Illinois Environmental Protection Act, is primarily invol-
ved in conducting studies to measure present resources, predict future needs
and determine economic impact of proposed pollution control regulations. The
Institute proposes regulations for environmental protection, generates data
for the decision-""^ ng process and promotes -and coordinates environmental ed-
ucation programs in the state.
A favorable combination of factors including the availability of per-
sonnel, similarity of purpose of the two major state agencies involved in
toxics control, the new state-supported effort to control toxics, and the
availability of expertise from the medical community and teaching institu-
tions, have made it possible to initiate a comprehensive, multi-agency pro-
gram in environmental health at this time. Through its association with the
University of Illinois School of Public Health, the Department of Public
Health has established working relationships with other regulatory agencies
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and the research community. A potential communications network azong local
heal:h departments, physicians, veternarians, poison canters ana .--cher in-
stitutions also exists throughout the state. With federal assistance through
a ISCA Section 28 grant to the Department of Public Health for developing this
communications network among all these elements, the Illinois strategy for in-
c
tegrated toxics management is becoming institutionalized and beginning to en-
compass more of the specific elements involved in managing dangerous chemicals.
Governor's Office Contact
Mr. Rich Carlson, Assistant to
the Governor for Energy & Natural
Resources
Office of the Governor
State House
Springfield, Illinois 62706
(217) 782-3212
Agency Contact
Mr. David Schaeffer, Science Advisor
Division of Water Pollution Control
Illinois Environmental Protection Agency
2200 Chtirchill Road
Springfield, Illinois 62706
(217) 782-1654 '
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MARYLAND
Maryland's strategy for integrated toxics managanseac includes a Gover-
r.or's Council on Toxic Substances and the Department cf Health and Mental
Hygiene's Environmental Health Administration (EHA), supported by state legis-
lation covering information reporting of health impacts of toxic substances,
cancer and occupational diseases. The Maryland Department of Health and Mental
Hygiene has primary responsiblity for toxic substances control in the state,
with most federal and state environmental programs under the department's En-
vironmental Health Administration. Overall coordination is provided by the
Governor's Council on Toxic Substances.
Established in March 1978 by the Secretary of Health and Mental Hygiene
with the governor's approval, and by legislation in 1979, the Council is mod-
eled to some extent on Maryland's successful Kepone Task Force. Some of the
work begun by the Kepone Task Force is being continued by the Council.
The Council is comprised of experts from the public and private sectors
as well as representatives from agencies with regulatory authority for con-
trolling toxic substances. Its membership is drawn from: University of
Maryland, Johns-Hopkins University, AFL-CIO, Chamber of Commerce, one member
each from the Senate and House of Delegates, and the Departments of Natural
Resources, Agriculture, Licensing and Regulation, Transportation, State
Planning, Economic and Community Development, and the State Fire Marshall's
Office, State Police and Civil Defense and Disaster Preparedness Agency.
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The council is ruled by a constitution and pursues its rcaii and duties
through subcsssslttaas on Episodes, Long-Range Planning. Zcor.cmic Impact and
Health Effects. The council provides opportunity to develop cctcnon action
plans between state agencies; shares resources, facilities and data; increases
cooperation in compliance and enforcement activities; and has established an
c
"alert" system for handling toxics emergency episodes. Most of the council's
efforts are directed toward prevention of future hazards through the develop-
ment of long-range plans and programs. The council's regulatory approach has
been welcomed by state agencies, industry and the public, and may well serve
as a national model.
Within the Department of Health and Mental Hygiene's Environmental Health
Administration, toxic substances control is primarily administered by the
Division of Regulation and Program Development, the Division of Environmental
and Industrial Disease Control and the Toxic Substances Registry.
Formally established in January, 1978, the Division of Regulation and
Program Development draws personnel and expertise from many state programs.
The Division was established in order to integrate and coordinate toxic sub-
stances activities which cut across other progrfmrnatic lines of the EHA and
serves as a resource unit, not only to the Department of Health and Mental
Hygiene, but to other state agencies as well. The division reports to the
Director of EHA who is also the state TSCA coordinator, and is charged with
maintaining EHA liaison with all involved state and federal agencies.
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":e chrust :f che program is
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these alerts were circulated to all 300 surveyed industries with a supple-
aental reporting fora to be returned by those industries using the toxics.
' The realization, however, that the survey effort fell short of a desire-
able degree of comprehensiveness has resulted in an expansion of the program.
The new system, referred to ascthe Toxic Substances Registry, was initially
developed through a 1978 TSCA grant in order to expand the inventory by phy-
sical sites and quantity of chemicals covered, and to systematize the infor-
mation into a common data base. A great deal more information has been added
to the registry inventory fron agencies involved in toxics control, universities,
public health schools and cancer centers in the state. The main objectives
of the Registry have been to:
1) survey local, state and federal government agencies to
determine the exact nature of available data;
2) conduct a literature search and survey other state efforts
in this area;
3) design a hierarchical data retreivable structure for users;
4) ensure comprehensiveness of data as a valid base for epi-
demiological and other investigations;
5) install a Toxic Substances Registry on a central computer
accessible to all cooperating agencies through terminals;
6) develop cooperative agreements with various data sources
for retreival and maintenance of data; and
7) systematically update data.
The Division of Regulation and Program Development also coordinates moni-
toring activities of EHA to provide correlation of toxics data with permit
actions taken by the department; toxics data from NPDES permits is, for in-
stance, correlated with the industrial chemical survey information in the
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::.;i5try to determine the potential Crater contamination occurring in the
stace.
Established in July, 1977, the Division of Environmental and Industrial
Disease Control consists of medical, nursing, industrial hygiene and epidem-
iological experts, and is responsible for developing preventative programs
for diseases arising as a result of occupational or community exposures to in-
dustrial-related hazards. The Division operates within the EHA, and works
with the Toxic Substances Control Program providing medical input and receiving
strong technical and scientific support in dealing with environmental problems.
The Division serves as both an investigative unit and a consultation service,
emphasising maximum cooperation between industry, labor and public health au-
thorities to provide safe working conditions and adequate medical surveillance
of high risk groups. The following are the ongoing activities of the Division:
1) working to design and implement epidemiological studies re-
lating to toxic substances and based on information from
the Division of Regulation and Program Development, as
well as occupational disease reports and environmental
health complaints;
2) developing strategies to study disease patterns among iden-
tified high risk groups, and evaluating the availability
of appropriate medical care particularly in industry;
3) working to design and implement reporting, surveillance
and investigation of industry-related diseases;
4) establishing a medical response unit to address health
effects of emergencies involving spills and leaks of
carcinogenic and toxic substances;
5) acting in concert with the Division of Regulation and
Program Development as consultant to various programs
within EHA to monitor and evaluate standards for con-
trolling toxics based on toxicity studies and epi-
demiological data; and
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6) providing medical and technical ccnsulraticr.s zo in-
dustry, labor, physicians and the general public.
.Finally, the Division of Cancer Control in the Aging and Chronically
111 Administration has maintained a successful cancer screening program op-
erated through local health departments, and has coordinated medical insti-
tutions ' reporting to Maryland's Cancer Registry Systaa. Although hampered
by past laboratory resistance to reporting requirements, the system should
be greatly improved by the Division's attempt to receive cancer related in-
formation through alternative channels. Hospital based tumor registries
will transmit cancer reports to the state registry promptly upon diagnosis,
and the state universities have agreed to assist the Department of Health
and Mental Hygiene by helping hospitals develop and maintain their registries
and by performing egid'^ological studies in high risk areas.
This complex of interagency and interorganizational support activity
has substantially strengthened the state toxics integration strategy.
Governor's Office Contact
Mr. John Griffin
Executive Aide
State House
Annapolis, Maryland 21404
(301) 269-2804
Agency Contact
Dr. Max Eisenberg, Special Assistant
for Environmental Health & Science
Office of Environmental Programs
Department of Health & Mental Hygiene
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-2740
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The sain focus of Michigan's coxic -r^stances management strategy in-
volves an extensive computerized information system known as the Critical
.Materials Register fCMR) operated by the Department of Natural Resources'
Office of Toxic Materials Control. Its goal is to identify existing or po-
tential toxic substances problems through the analysis of data on toxic sub-
stances use, discharge and emission as available in annual CMR reports, Air
Priority Chemical reports and other information sources.
CMR information is currently stored in a computer system maintaining
data only in a lis_t_f oraat. Consequently, the state's first strategy objec-
tive is to develop a computer svstea to sort and analyze all data collected.
These data include characteristics of industrial facilities and receiving wa-
ters of the state. A computer capacity to store data according to geograph-
ical location, specific materials utilized and type and quantity of such
material is also needed.
A second objective is to develop a computer^ystem to use secondary
sources of toxic substances information (federal as well as inter and intra
state data bases) to supplement present CMR data.
The Critical Materials Register was authorized in 1972 by an amendment
to the Michigan Water Pollution Act of 1963. A CMR Advisory Committee com-
prised of environmental specialists from industry, government and the aca-
demic community designated by the Director of the Department of Natural
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lisources provides advice tc the director on the development and revision
of the CMS as "well as advice and recommendations on the overall toxics pro-
gram.
The first critical materials list was created in 1971, but as the rum-
bar of variables, chemicals, industries, etc. expanded, it became increasingly
complex. The state then developed a more objective system for selecting chem-
icals to be listed in the register, and by 1978 had developed a sodel for ev-
aluating chemicals for possible inclusion on the CMR, based on a numerically
scored hazard assessment.
It should be noted that no attempt has been made by the scats to list
«
all chemicals which may be hazardous under any or all conditions. The pur-
pose of the register is to develop and maintain a list of critical chemicals
from a water pollution perspective. The Department of Natural Resources is,
however, beginning to develop a similar air emissions priority list for use
by the air pollution program under the authority of the Michigan Air Pollu-
tion Act of 1965, as amended. A separate air list is necessary as a result
of air pollution regulatory authority being delegated under a media specific
statute, as is water pollution control authority. The methodology, purpose
and use of the air register will be essentially the same as the CMR; and it
is anticipated that a computer system will be developed to integrate the two.
The major use of the CMR involves identifying businesses using or dis-
charging toxic substances into waters of the state in amounts which could
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cause environmental dansge. The ultimate'purpose is to target environmental
program activities toward preventing potential problems. Facility descrip-
tions and designs are evaluated in connection with the list to determine if
the listed materials are likely to be discharged, and whether such discharges
are likely to result in environmental degradation. Follow up inspections and
analysis may then occur. Other uses of the CUR include:
1) all NPDES permits and applications are reviewed by the Office
of Toxic Materials Control in light of environmental and
health related information from the CMS. in order to avert
potential damage from a particular toxic substance;
2) all chemicals listed must be considered in a pollution inci-
dent prevention plan developed by each facility using or
storing any of the listed materials;
3) the Department of Public Health uses the data to identify po-
tential impacts on human health through exposure to water
contaminated by listed materials;
4) the Air Quality Division currently utilizes the data to in-
vestigate possible fugitive, emissions from critical ma-
terials storage facilities and processing facilities; and
5) selective survey/questionnaire mailings are made to obtain in-
formation from industry on manufacturing, distribution and
disposal practices, and regulation and warning notices are
issued to businesses which have listed materials in use and
discharge patterns similar to a known problem, in order to
rectify, abate or prevent potential environmental/health
hazards associated with such industry practices.
The CMR has many cross-media, cross-agency and cross progran uses. The
register involves the integration of information collected through traditionally
media specific programs as well as the integration of information collected by
federal sources. It allows the state to organize its environmental programs
around the functions of toxics information gathering, analysis, dissemination,
use and input into the regulatory process.
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In initial:, che CG could be an extremely interesting tsol for state
aanagers involved in prioritizing those chemicals which need to be rsest closer,
watched and controlled. In developing a separate air emissions priority list,
the state recognizes that chemical effects in water and the atmosphere are
different. A report being'developed by the Office of Toxic Materials Control
describing how the critical materials program was developed, how it was im-
plemented, the computer programs utilized, and the sampling protocols and in-
vestigative aethods used, will be valuable when available.
Governor's Office Contact
Mr. Don Inman, Special
«Assistant to the Governor
State Capitol - Room 1
Lansing, Michigan 48909
(517) 373-3427
Agency Contact
Mr. Rich Powers
Michigan Department of Natural
Resources
Office of Toxic Materials Control
Post Office Box 30028
Lansing, Michigan 48909
(517) 374-9640
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NEW;JERSEY
ITeu Jersey's strategy for comprehensively controlling and arising ccxic
substances problems involves various state agencies and units of the Depart-
nent of Environmental Protection ODE?). In 1376 the governor issued a direc-
tive mandating a program to reduce the exposure of New Jersey citizens and the
environment to carcinogenic and..toxic substances. The impetus behind this di-
rective was an increasing awareness of the casual relationship between environ-
mental pollution and human health effects.
The primary unit in the DEP involved in implementing the strategy is the
Program on Environmental Cancer and Toxic Substances (PECTS). with the Office
of Hazardous Substances Control providing the necessary media specific activi-
ties.
The state attempts to distinguish three primary sources of toxic haz-
ard:
1) exposures that occur as a consequence of a catastrophic fail-
ure, such as explosion, spill or transportation incident;
2) exposures tnac result from current routine emissions into the
environment from many different sources such as industry,
agriculture and motor vehicles; such emissions may be into
air or water by way of the solid waste stream and may be
continuous or transient phenomena both in time and space; and
3) current exposures that result from previously reduced toxic
agents such as abandoned chemical dumps and landfills.
The combined efforts of the PECTS program and the activities of the Of^
fice of Hazardous Substances Control attempt to address each of these three
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T-ajcr i^icgjrias. This tri-ievel distinction between the ".t~ = = of potential
to:ti.;s prcblens provide useful goal orientation to""state program strategy or-
ganization:
The state has identified seven basic functional activities for imple-
menting its toxic substances program:
1) environmental monitoring
2) resource organization
3) problem definition
4) field response
5) regulatory need evaluation
6) internal program integration
7) program integration with other units
As the lead group in DEP charged with conducting an intensive effort to
identify the sources, levels and effects of toxics substances in the state
and to coordinate the department's overall approach to toxic substances con-
trol, PECTS has tvo major objectives; 1) to look at risk and hazard assess-
ments, and 2) to look at environmental fate. The risk and health hazard
assessment section conducts much of the data collection activities and sub-
sequent analyses in order to relate environmental data to human health ef-
fects, primarily dealing with carcinogens but also encompassing other types
of health effects. The environmental fate section is concerned with the be-
*
havior of toxic substances in the environment and their effect on natural re-
sources .
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PEC75 does substantial -sonitorlng. However, due to the fact that trxici
substances data are very Halted in New Jersey, PECTS placed heavy emphasis
on designing, contracting for and analyzing results from environmental proj-
ects for the first two years. PECTS thus made broad surveys to torcLcs com-
pounds in the environment its first priority. Preliminary monitoring surveys
conducted by New Jersey include:c
1) the use of state-related data from an EPA analysis of air
samples for volatile organics. and preparation of a table
showing compounds found in New Jersey samples with, some
frequency and in fair high concentrations;
2) collection and analysis of air samples for the presence of
lead and other heavy metals using atomic absorption tech-
niques ; collection of additional air samples of volatile
organics and analysis thereof for selective carcinogens
and toxics; subsequent preparation, of charts listing the
number of samples taken per metal and per organic com-
pound and the range of median concentrations of those
samples;
3) sampling and testing of over 400 public and private wells
in 21 counties for carcingenic compounds considered po-
tentially hazardous to human health and the environment;
results of the organics, pesticides and metals analyses
showed several cases where federal drinking water stan-
dards were not met for pesticides and organics, and 12
instances where standards were not met for metals; and
4) a series of shell and fin fish samples were also collected
ac various locations around the state in order to de-
termine the PCS levels in their tissues.
PECTS is also involved in evaluating chemical risks through statistical
i
studies of health effects in the state. The state hopes to determine which
environmental and ccnnnunity variables are most clearly associated with a par-
ticular disease by collecting- demographic, mortality, industrial and geo-
logical data and by sponsoring an extensive project to correlate this wide
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-;j.r.ga of envirangental, occupational, athr.ic and social variables with aor-
rality in Che stiate and surrounding region. The szste has examined:
1) National Institute of Health statistics showing New Jersey
near the top of the nation in total cancer death rates
for both sexes and both whites and non-whites;
2) toxic chemical problems derived fron the large number cf ,
serious spills, explosions and other accidents;
3) its chemical industry in'-a national perspective and how it
ranks in terms of the number of cheaical facilities, new
capital expenditures, and number of employees;
4) lung cancer studies and their relation to air pollution and
water pollution Cespecially one conducted in Louisiana re-
lating suspected and known carcinogens to polluted drinking
water from the Mississippi);
5) infant mortality rates in Sew Jersey as compared to the whole
nation from the National Center for Health Statistics (NCHS); and
6) state and national rates for selective cardiovascular diseases
that are age standardized and compiled by NCHS.
To assist PECTS in its information gathering and analysis activities, the
state has acquired the use of a powerful and easily used computer system called
UPGRADE. Developed by the President's Council on Environmental Quality, UPGRADE
is used for analysis of graphic and statistical data combined with health and
environmental data. PECTS Is expanding UPGRADE to include the health and en-
vironmental data gathered by New Jersey DEP as well as other states. New
Jersey was also the first state to utilize the UPGRADE system.
The PECTS program also includes the Toxic Substances Information Center.
with the UPGRADE system constituting a major element of the center. The Re-
source Center has resulted from a state recognition that:
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1- regulatory agen:i=s r-squire current data in order =o as-
sure that their incisions are made on Che basis of iosc
recently availabla ^aca;
2) vast amounts of info rmation from a wide variety of sources
need to be integrated into a comprehensive and usable
form for technical as well as policy and decision-making
staff;
3) emergency situations require, in a short period of time,
concise information regarding chemicals and their effects.
-------
The DZP's Of flea of Hazardous Sussr-ir.ces Control, as the se^'tid inte-
gral component of the toxics strategy, is charged with on-site response to
hazardous substances spills and ether emergencies, in addition to coordina-
ting- the department's efforts to ensure the integrity and safety of facilities
utilizing large quantities of hazardous substances. Each specific division
(air, land, water, pesticides)':located within the Office of Hazardous Sub-
stances Control is responsible for the development, implementation and enforce-
ment of the BEP's overall toxic substances strategy.
The Office was organized in 1970 as the overall coordinator for hazardous
materials disposal, but its duties were expanded in 1977 in order to meet the
mandate of the state Spill Compensation and Control Act. The office's spill/
emergency response, containment and cleanup activities and review of indus-
trial facilities' spill prevention pl^nj is supported by the Spill Compensation
Fund generated by a tax on transporters of hazardous materials between major
New Jersey facilities. The Emergency Spill Response Unit in the office op-
erates sophisticated laboratory facilities and sponsors numerous emergency re-
sponse seminars and training courses for local fire, law enforcement, trade
and government groups.
An Engineering Review Group in the office con.iucts technical reviews of
industrial spill prevention and cleanup plans, and reviews water quality
certifications, permits and grant applications as part of an interdepartmental
consolidated permit process.
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Governor's Office Contact
Mr. Jeffrey Light, Assistant
Counsel to the Governor
Governor's Counsel's Office
State House
West State Street
Trenton, New Jersey 08625
(609) 292-7400
Agency Contact
Mr. George J. Tyler, Assistir.z
Cocsnissioner for
Management
Department of Environmental Protection
Post Office Box 1390
Trenton, New Jersey 08625
(609) 292-8058
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'SEW"YORK
New York's present strategy for controlling toxics focuses primarily en
developing statewide technical procedures for locating past and present sources
of toxic substances contamination, assessing their iapacts, and developing
aanagement techniques for controlling toxic substances problems that will in-
tegrate the responsibilities of state and local governments, and to assure co-
ordination with federal programs. This strategy has developed over the past
three years, and is the result primarily of the state's awareness that technical
and aanagement deficiencies existed in state environmental pollution control
programs.
The state has identified four toxic substances problems underscoring the
need for a toxic strategy which is presently being developed:
1) the existence of chemical waste dumps in Niagara and Erie
Counties requiring remedial engineering and population
resettlement action;
2) mercury contamination of fish in Syracuse's Onondaga Lake
from industrial discharges resulting in a prohibition
on fishing;
3) PCS contamination of fish in the Hudson River Valley (from
Hudson Falls to New York City) resulting in restriction
on sport and commercial fishing in the Valley; and
4) contamination of a sole source groundwater aquifer on Long
Island by chlorinated hydrocarbons resulting in well use
restrictions and a continuous testing program.
The existing toxics control strategy is based on the toxicological and
laboratory expertise of the state Department of Health and the regulatory and
resourse management powers of the state Department of Environmental Conserva-
tion (DEC). The Office of Toxic Substances was established in 1978 in the
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executive branch of DEC to provide leadership, coc.-v'. nation, strategy develop-
ment and program planning expertise to che Dthe.- wi^ncies and divisions within
DEC on toxic substances issues. While the actual implementation of the strat-
egy rests with a wide variety of program divisions, the Office serves as the
department's focal point for interaction with other state and federal agencies,
industry, citizens and the scientific community.
Over the past three years, New York's toxics strategy has based its ac-
tivities around three major programs:
1) an industrial chemical survey which identifies chemicals in use
in the state according to industry, county and watershed, and
is based on a survey of 5,000 industries conducted in 1978.
The information is presently computerized and referenced ac-
cording to the chemical abstract reference number;
2) a statewide fish monitoring program analyzing a variety of fish
species for the presence of heavy metals and a variety of
chlorinated organic chemicals. Over 100 monitoring stations
are included covering all major waterways; and
3) a track-down program utilizing a variety of techniques including
the analysis of macro invertebrates grown in artificial plas-
tic environments as a means of locating the sources of toxic
substances pollution to a water body.
At present, New York is focusing on developing a systematic procedure to
locate potential toxic substances In the environment, assess their environmental
and public health significance, and develop rational management procedures. On
the scientific technical level, the state is developing relatively simple, in-
expensive eh«""-fcal screening procedures that would allow broad classes of toxic
substances to be analyzed in sediments, waters and bio tics. On the management
level, the state is attempting to extend the range of presently known or available
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toxic subsTian^as management techniques and to adapt then to local goverrre-ts.
A pilot program is attempting co develop these tasting methods and prccad.ras
and the neeced tzar-agement relationships to deal with toxics in Erie and 5>:ho-
harie counties. It is anticipated that these procedures, techniques and manage-
ment plans will then be applied on a statewide basis to control toxics problems,
The pilot program is comprised of six major components:
1) research and development; the state will be utilizing its in-
dustrial chemical survey reviewing it in light of known
toxicological hazards in the counties to determine the broad
classes of chemical substances appropriate for scan tests.
Effective, simple and relatively inexpensive approaches to
developing scan tests will be particularly examined, in-
cluding training locals to collect and analyze samples;
2) county-wide surveys: historical information, the industrial
chemical survey, the state hazardous waste survey, NPDES
permit Information, etc. will be utilized here as well as
Including the state's inter-agency hazardous waste disposal
task force and the Erie County interagency toxic substances
task force;
3) county-wide sampling and analysis will be conducted utilizing
screening techniques identified in the research and develop-
ment phase as well as current practices;
4) priority rankings will be determined to narrow the list of po-
tential toxic substances problems to those with apparently
significant impacts warranting further investigation;
5) In-depth investigations of these top priority problems;
6) management alternatives and plans which will include: deciding
on objectives, examining alternatives, describing the op-
timum management steps needed, agreeing on responsibilities
for each step, calculating costs and time incurred and cal-
culating expected benefits.
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Tli= :ffice of Toxic Substances has been operating as a coordirative
prig ran v-.,>.in the DEC for several years, and there appears to ?e no aove
to airer the existing organization. The state does, however, see the need
to develop more efficient, effective management and technical procedures to
operate within^ this existing structure and has developed a fairly compre-
hensive strategy to address these needs. The New York six-pronged strategy
c
addresses a vide range of operations (information gathering, research, pro-
cedures development, sampling, screening, investigation, etc.) which will
be applicable to all environmental media.
Governor's Office Contact
Mr. Frank Murray
Program Associate
State Capitol - Room 227
Albany, New York 12224
(518) 474-1288
Agency Contact
Mr. Bob Collin, Chief
Toxic Substances Control Unit
Department of Environmental
Conservation
50 Wolf Road
Albany, New York 12233
(518)' 457-2462
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NORTH "CAROLINA
Carolina is initiating a broad toxic and hazardous ^substances
nanagement strategy based on the recognition that hazardous V3s:as represent
only a fraction of the total chemical problea in the stata. A growing real-
ization that toxic and hazardous substances are produced snd used in a variety
of-"ways that may be injurious go human health in the short and long run, ccn-
bined with occurrences of such incidents as midnight dunping of PC3s and other
illegal disposal practices, have triggered the state initiative to implement
a comprehensive toxics control strategy.
The impetus for a comprehensive strategy dates from ?C3 spills along a
North Carolina highway in 1978, when complex management questions for the
governor's office and state agencies responding to the spills were raised.
Confusion over responsibilities and authorities spurred the governor to issue
a staff directive to develop a management strategy for the coordination of
chemical management functions within the state. Two presidential management
interns were subsequently employed by the state to assist in the development
of a comprehensive management strategy.
The North Carolina strategy combines two efforts: a governor's task force
on hazardous and low-level radioactive waste, and a state toxic substances
project. The governor's task force is supported by advisory groups concen-
trating on hazardous wastes, lowlevel radioactive wastes, public informa-
tion and research. The task force is presently preparing a plan for safely
managing hazardous and low-level waste in North Carolina in conjunction with
implementing the-Federal Resource Conservation and Recovery Act of 1976.
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The Toxic 2 ibstances Project "is '^complimentary jnject partially funded
under a Section 23 TSCA grant with four aajor objectives:
1) to develop a profile of chemical substances produced, used
and accumulated as waste in North Carolina;
2) to assess the human health effects of selected substances
profiled (i.e., those deemed likely to have significant
adverse health effects);
3) to identify sources, levels and duration of human exposure
in North Carolina to the selected profiled substances;
4) to develop and begin implementing a plan to control these
substances for which adverse effects are judged to ex-
ceed beneficial use. This control may range from pro-
duction shut-downs to production and use practices
guidance and modification of disposal methods.
The scope of this project, which is the cornerstone for the comprehensive
strategy, covers all state management functions from policy development to en-
forcement, examining all elements of the chemical life cycle (manufacture, use,
processing, transport, sale and disposal), involving all levels of government-
(local, state and federal), as well as the citizenry, media and private in-
«
dustry.
The intent of the strategy is to use actual experience as a basis for
determining how best to meet state responsibilities for controlling toxic
substances. This will ultimately form the basis for future executive or
legislative toxics control action. Under the state TSCA grant, this strategy
is implemented through an automated information system. Data to be collected
by the state under this project includes:
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1) groundwacer data from the Department of Natural Resources
and Community Development, including s ^logical, hydro-
logical and soil base data;
2) river and str08"" q^lity data;
3) chemical data using federal SIC codes, state gathered in-
formation on chemical plane locations in the state, the
amount and size of the plants, types of chemicals pro-
duced, location and characteristics of chemical storage
sites in the state and statistics on the transportation
of chemicals in the state;
4) population/demographic data for siting and exposure level
determinations; and
5) other existing national and international chemical-related
data bases.
The primary element of the management information system is a priority
ranked inventory of chemicals manufactured in North Carolina, based -on a NIOSH
\
occupational hazard survey and the North Carolina list of manufacturers. The
Research Triangle Institute at North Carolina State University will compile
the chemical inventory and prioritize a list of 1,000 chemicals with back-
ground stannaries for each. The chemicals wUl be given a rating or chemical
priority number based on the following factors:
1) the total volume of the substance produced or used in the
state;
2) the volume of the substance produced by county;
3) the severity of potent!*'* harm to human health or the en-
vironment attributable to the chemical.
A specific aspect of this inventory will be the close examination of the six
largest hazardous chemical users and/or producers in the state already identified
by the Department of Human Resources' survey on hazards involved in handling
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chsrical wastes. Here, the enohasis- will *e placed on manufacturing charac-
teristics and the specific chemicals associated with these industries.
All the data collected is to be computerized, and the data base of the
prioritized chemicals will be combined with the additional data bases de-
scribed above. The total management information system is designed to be in-
teractive in nature, and will assist decision-makers in taking investigative
or regulatory action. By developing an extensive chemical data base (incor-
porating chemical properties, adverse health effects, prevailing conditions
of exposure, etc.) the state will have an improved analytical procedure and
organizational basis to determine the level of monitoring, enforcement and
regulation necessary to safely control toxic substances in the state.
The state has formed an inter agency coordinating body to provide overall
guidance to these specific toxics-related programs. The coordinating body is
comprised of representatives from existing state agencies involved in toxics
control. In addition, various groups will be formed within this body to ad-
dress specific toxics problems (health effects monitoring, hazardous waste
disposal, environmental impact assessment), drawing from the member agencies
with expertise in the specific issue areas being addressed.
Thus, North Carolina appears to be well on its way to implementing an
integrated management strategy for controlling toxic substances. In doing
so, the state has employed a reorganizational strategy not unlike other in-
tegrated strategy states such as Oklahoma and Arkansas in which an interagency
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coordinating body comprised of existing toxics-related agencies is utilised.
The North Carolina Toxic Substar.ces Project is the cornerstone of the strategy,
with the chemical management information system being the major focus of the
project.
While integrating the activities of various state agencies, private in-
dustry and the public, North Carolina is focusing on all aspects of chemical
management production, use, processing, transport, disposal, monitoring,
enforcement, regulation, etc. In this regard, the state acknowledges the
need to understand and be prepared to handle present and future toxics prob-
lems, and acknowledges that a comprehensive management strategy is the most
effective and often most cost efficient means of controlling dangerous chemi-
cals.
Governor's Office Contact
Dr. Quentin Llndsey
Science & Policy Advisor
Office of the Governor
116 West Jones Street
Raleigh, North Carolina 27611
(919) 733-6500
Agency Contact
Dr. Donald Hulsingh
Toxic Substances Project Leader
16 West Martin Street - Suite 810
Raleigh, North Carolina
(919) 733-2770
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OKLAHOMA
Oklahoma's management strategy f.r controlling toxic substances is based
on the Oklahoma Pollution Control Act of 1968 as amended, establishing a
Pollution Control Board to coordinate activities of member agencies and organ-
izations. The Pollution Control Act broadly defines "pollution" and "the en-
vironment," and the Pollution Control Board has been delegated far-reaching
u
authority to prevent and abate pollution throughout the environment.
The Pollution Control Act also mandates that the Department of Pollution
Control act as the "executive arm" or overall coordinator for the Board. Orig-
inally created to address water pollution issues, the Board has been expanded
in its membership and responsibilities to encompass virtually all environmental
and health-related programs carried out in Oklahoma. A total of nine members
comprise the Board with two citizens and seven representatives from state ag-
encies. At least ten monthly meetings are held with five members needed to
constitute a quorum, and the state attorney general acts as legal counsel.
The Board's mandate was extended in 1971 to improve coordination of en-
vironmental pollution control programs. The Board, with the Department of
Pollution Control acting as its executive arm, has the authority to act on its
own initiative in certain situations and has the following specific responsi-
bilities:
1) to coordinate and eliminate duplication of agency efforts;
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2) to compel m«nber agencies' to~jnvestigata and file reports
on suspect -i-i poll
3) to conduce ciucl^s, investigations, research and demonstra-
tions for :ha irsvention of environmencal pollution;
4) Co assume jurisdiction in a pollution problem when an ag-
ency fails Co aeet its responsibility, when no agency
has legal jurisdiction or when there is an overlap or
conflict in authority;
5) co hold hearings, issue notices, subpoenas, administer
oachs, and cake testimony as necessary for enforcement ;
6) to provide the opportunity for a complaint to be heard
before the board;
7) Co establish and maintain central reporting for all rules
and regulations;
8) co maintain an up-to-date record of the availability, ac-
quisition and disposition of all federal, state and other
monies;
9) to establish and maintain a system whereby a citizen re-
porting a violation co the board passes the report on to
Che proper agency, and maintains records of actions taken
on each reported violation; and
10) to conduct educational training programs related to pollution.
The Department's executive responsibilities include coordinating all pol-
lution control activities of other state agencies, as veil as being designated
the lead planting agency for Che state's comprehensive water quality management
plans and Che Implementing regulatory agency for the federal Clean Water Act,
dean Mr Act and the Resource Conservation and Recovery Act. Other member
agencies of Che Board, and their respective responsibilities, include: Che
Oklahoma Water Resources Board whose duties presently include consideration
of revisions involving more stringent standards for toxic substances and es-
tablishing groundwater standards; Che state Department of Health's Water Quality
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Laboratory vfaich performs chemical.analyses of pvrilc drinking water supplies:
::.e stace Departaent of Agriculture which regulars pesticides and fertilizers
and operates its own analytical laboratory; the Conservation Commission which
compiles information and conducts studies on the relation of district programs
to one another and other resource conservation programs in the state; the In-
dustrial Development Departaent which supports and assists interested parties
c
in developing new and expanding existing industrial facilities in the state and
provides environmental regulatory information to industry; the state Department
of Wildlife Conservation which enforces pollution control laws in protecting
fish and wildlife and is responsible for determining the value of any forest or
wildlife losses for recovering damage costs for the state as well as individuals.
Additional Board responsibilities include requirements to continue study-
ing the feasibility of coordinating and combining state pollution control ac-
tivities and to submit an annual progress report with any recommendations to
the Oklahcaia Senate and House. Also, the act mandates that any research in-
formation made available to the Board be transmitted to the Continuing Education
Center for Ecology Information at East Central State College, and made avail-
able to the public upon request.
Toxics c uerns are woven into this broad integrated environmental strat-
egy through various toxics evaluation programs. The state Department of Health
has laboratory instruments capable of reading very low levels of toxics in air,
water, and food. Whei. this equipment is on-line in the state's Water Quality
Laboratory, virtually any toxic substance can be tested for within these media.
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The Air Quality Service in Che Department of Health is actively ...rkins to
control lead emija^ons from facilities in Stillwacar and Barr_«villa, and
is evaluating air emissions of mercury and arsenic. The Water "acilities
Engineering Service has specific pre-treatment requirements for waste water
treatment facilities. The Water Quality Laboratory collects and analyzes fish,
water and sediment from selected monitoring sites; special evaluation of FCBs
at too locations in the state resulted in an additional Health Department ap-
propriation to purchase needed analytical equipment to continue the study.
The lab also provides analytical and technical support in the event of a toxics
related spill or emergency. The Consumer Protection Service operates food con-
trol programs to prevent toxics from entering the food chain in the manufacture,
processing or sale of food products; milk, for example, is periodically tested
for the presence of pesticides, herbicides -and antibiotics. The Environmental
Protection Service has a plumbing program (the Cross Connection Control Pro-
gram) designed to test plumbers on their ability to prevent back siphonage of
toxic materials from sewers and water supply systems, as well as training and
certifying water or waste water treatment plant operators in ways to avoid
toxic contamination of water supplies, streams ?tid lakes.
The Occupational and Radiological and Health Service investigates and
assists individuals accidentally contaminated by toxic substances in the home
or workplace.
In addition to these on-going program activities, the state engages in
the following specific toxic evaluation programs:
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1) the Industrial Waste . Ivlsior. -.of the Industrial and Solid
Waste iervica determines the environmental effects of
actual or potential leachate or industrial waste dis-
charge; investigates toxic material complaints; and
assists other agencies in -isposin^ of unusual chemicals
(e.g., state school assistance in disposing of old chem-
icals).
2) the Environmental Epidemiology Division within the Epi-
demiology Service was established in an effort to de-
velop an interdisciplinary approach involving the
environmental and medical aspects of toxic exposure.
The Division serves as a consultant on any toxics
problem encountered by the state, assists in problem
evaluation design and data collection. Data are used
to prepare reports, fact sheets and public information
material. In addition, the section serves as an in-
formation source through its development and main-
tenance of a toxics reference library and resource con-
tact list of other state and federal agencies.
Oklahoma appears to have successfully initiated a toxics integration manage-
ment strategy through a three-pronged procedure. First, a relatively compre-
hensive general piece of environmental legislation was enacted - broadly de-
fining what is considered the environment and pollution within that environment.
Next, the act instituted a Pollution Control Coordinating Board responsible for
overseeing the protection of that environment and the abatement and prevention
of pollution. Finally, the Board is comprised of a wide variety of state agencies
involved in both health and environmental concerns generally, and toxics control
specifically. As a result, the state's existing regulatory, agency structure
remains primarily unchanged - with toxics monitoring and abatement activities
occurring within existing agencies - and the Board serves as the mechanism for
coordinating these agencies and programs under the single concept of toxic sub-
stances .
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Governor's Office Contact
Mr. Ed ?ugh, Senior
Administrative Assistant
Governor's Office
State Capitol
Oklahoma City, Oklahoma 73105
(405) 521-2342
Agency Contact
Mr. Mark Coleman, Deputy
Commissioner
Environmental Services
State Department of Health
Post Office Box 53551
Oklahoma City, Oklahoma 73152
(405) 271-5204
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Puerto Rico's Environmental Quality Board (EQB) is currently developing
an integrated toxic substances control strategy and a coordination mechanism
funded, in part, by an EPA Section 28 grant under the federal Tcxic Substances
Control Act (TSCA). Although EQB has individual programs for toxic substances
control -with regulatory powers^ legislative authorities and administrative or-
ganizations for information gathering, control and enforcement actions, the
current toxic substances activity represents a «** of commonwealth and federal
agency involvement with a media specific focus. The commonwealth, however,
feels that integration is needed to ensure comprehensive treatment and an ac-
tion focus that is not duplicative in design and implementation.
/
Factors such as the conflict between economic development and increased
potential for toxics control problems, the occurrence to toxic crises such as
the mercury contamination of Los Corozos Creek, and worker exposure to danger-
ous levels of birth control hormones and mercury and studies examining the
correlation between chemical exposures and pulmonary and cardiovascular dis-
eases have prompted the recognition of the need for a comprehensive strategy
to control toxic chemicals. A sound toxics strategy is seen as a mechanism
by which Puerto Rico could prevent the occurrence of similar problems in the
future, mitigate any future crises that may result from the trends noted above,
and define a mechanism for handling health and environmental emergencies in the
event they cannot be prevented.
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The proposed toxic substances control program includes the following
goals:
1) development of a toxic substances control strategy that co-
ordinates Puerto Rico's efforts to limit human and envl-
'] exposures to toxins;
2) development and establishment of coordinative mechanisms to
carry out the strategy that takes into account the coor-
dination of various pollutant sources and environmental
inventories being presently conducted or contemplated for
the future;
3) development of chemical and toxic problem area priority
lists;
4) implementation of the established coordinative mechanisms
on order to control the top priority chemical and toxics
problems;
5) development of a pollutant incident prevention plan to
better enable the commonwealth to respond to health and
environmental emergencies;
6) development, establishment and promotion of an active pub-
lic participation plan to provide for citizen input into
the EPA/EQB decision-making process; and
7) evaluation of project effectiveness.
The Public Policy EnviroT]«g^tal Act of June 18, 1979, as amended, estab-
lished the EQB and gives Puerto Rico broad authority to protect health and
welfare, prevent environmental degradation and enhance the relationship of
man with the environment.
The toxics program will be managed by EQB's Solid and Hazardous Waste
Office, and in conjunction with the goals outlined above, the office will
the role of state and local governments in toxic substances management
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and intends :: coorz_r.aca ics toxics ''p'rogran activities with relevant activ-
ities of crier state and federal agencies. While attempting to create a
better management system for toxic substances problems, Puerto Rico will be
looking for ways to lessen the economic burden on industry as well.
Although Puerto Rico's strategy is in the development stages it indi-
cates the commonwealth's commitment to promote formalized coordination and
cooperation in environmental .management that will link together programs
and activities presently organized around media specific lines, provide cross
agency information sharing and promote federal/state/local/citizen/industry
interaction in an effort to confront the need for controlling toxic chemicals,
Governor's Office Contact
Mr. Frederick E. Rushford
Federal Programs Officer
Office of the Governor
La Fortaleza
San Juan, Puerto Rico 00901
(809) 724-7900
Agency Contact
Mr. Pedro A. Gelabert, President
Environmental Quality Board
Post Office Box 11488
Santurce, Puerto Rico 00910
(809) 725-3898
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VIRGINIA
Similar Co other integrated state strategies, Virginia's focus is on
developing an extensive information gathering system on the nature of chea-
ical use in the state. The Virginia Toxics Information Act of 1979 defines
its purpose and scope of state information gathering activities on a broad
c
enough basis to encompass all aspects (media, operations and products) of
toxic substances control.
Virginia approaches toxics control on primarily a preventative basis.
Prevention measures are viewed as those designed to protect a variety of
organisms, in*?!1"^ T*g animal a Ktnnanq a-nA plants , as well as inanimate mater-
ials and structures.
The state has the authority to:
1) inspect chemical-related industries;
2) enter premises for inspection;
3) assess penalties for violations of the act;
4) require industry to disclose information; and
5) provide for the confidentiality of industry informa-
tion by state officials.
These activities are administered by the state Board of Health, the state
Health Commissioner and the state Department of Health, which assumes majc-
responsibility as the state toxic substances information agency. As such,
it assumes the following powers and duties:
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i. developing and operating a sy-ates of reoorrine iub.stan^es
posing a high or unreasonable risk to health :r the =n-
vironment;
2) collecting information from any source on toxic substances
to avvir! possible duplication of reporting activities;
3) cataloging the information collected;
4) instituting proceedings to compel information disclosure;
5) reviewing and evaluating information to determine if it
is relevant material for making toxicity determinations;
6) promulgating a list of Class I substances as those de-
termined from toxicological and other scientific data
to pose the greatest threats to human health or the
environment, specifying the amounts that pose such
risks; and
7) providing dontmentation to support the list, giving no-
tice of sucn a listing and holding public hearings.
The Toxic Substances Advisory Council was established to review and eval-
uate policies with respect to toxic substances, make recommendations to the
Board and provide technical assistance and advice as needed. It consists of
five appointed members and twelve ex-officio members. The Governor appoints
one member each from the areas of agriculture, medicine, labor, industry and
local government. Ex-officio members are chairpersons of the following state
organizations: Water Control Board, Air Pollution Control Board, Board of Con-
servation and Economic Development, Labor and Industry, Marine Resources, Ag-
riculture and Consumer Services and the Council on the Environment. Thus,
the Council is very much an interageney advisory group combining represen-
tatives from a wide variety of environmental and health interests and encom-
passing the media, product and operation of the specific program and its ac-
tivities.
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rther important elements of the strategy include the requir-saent for
as aaaual report on the status of toxics control made to the Virginia As-
sembly and Governor. This report, by outlining such aspects of toxic sub-
stances control as federal activities in the state, applicable federal
statutes, state organizational set up for coordinating toxic control activ-
ities and description of specific state toxic substances program activities,
serves as an excellent coordinating tool in itself, not seen in other state
toxic integration strategies. By detailing the toxics activities and organ-
izational structure in Virginia, the state has essentially developed an ac-
cessible annually updated directory for state and local officials to determine
who has authority and responsibility in a specific area of toxic substances
control.
Governor's Office Contact
Ms. Joy Hanson
Executive Assistant
Governor's Office
Richmond, Virginia 23219
(804) 786-2211
Agency Contact
Dr. John Hilckin, Director
Bureau of Toxic Substances
Department of Health
Richmond, Virginia 23219
(804) 786-1763
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WISCONSIN
Wisconsin's strategy focuses on tne development of a model state ?ro-
graa in environmental epidemiology. The Environmental Epidemiology Section
of the state Department of Health and Social Services applied for a Section
23 ISCA grant in 1978 to develop this model program to identify, investigate
and alleviate or minimize toxics effects on the public and the worker, with
ii
special priority given to protecting fetuses, infants and children. The
program's objectives include:
1) identifying the negative health Affects and minimizing
adverse toxic exposures;
2) conducting epidemiologic investigations into the casual
factors of human morbidity or mortality;
3) coordinating state activities to alleviate or minimize
exposure to toxics;
4) ensuring accurate laboratory analyses on or of toxics;
5) participating with the University of Wisconsin Preven-
tative Medicine Department and other state departments
and the State Medical Society in developing a center
for the physiological/psychologicalevaluation and
diagnostic workup of individuals suffering from ad-
verse reactions to toxics; and
6) determining the extent and adequacy of existing toxics
regulations and sampling procedures.
The Section proposed a six-pronged plan to Implement these ojectives:
1) the expansion in scope and depth of the study of formal-
dehyde vapor related health problems. Study staff had
already experienced difficulty in developing a research
design and methodology for determining the influence of
temperature, ventilation, humidity, etc. on testing
procedures, pointing out the need to expand the scope
and depth of the state's environmental epidemiology
program;
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2) provision of diagnostic and laboratory services as nec-
essary support for the environmental epidemiology
program. As a result, a model plan specifying the
minimum diagnostic and laboratory services needed by
a state environmental epidemiology department, its
cost, types of professionals and extent of educational
training required would also be developed;
3) development of a computerized cancer and birth defects
surviellance system able to automatically indicate
any specific cancer <5r birth defect that is occurring
beyond expected levels based on past trends and a com-
parison to similar areas of the state;
4) development of a rapid access information retreival sys-
tem, cataloguing and 1*v*«»-g-{"g the Section's extensive
information files into a single interactive computer
system;
5) development of model interdepartmental agreements to be
used between state agencies to clarify roles, juris-
dictions and relationships between departments; and
6) development of a model state emergency health response
plan for hazardous materials spills, fires or explo-
sions including provisions for evacuation responsi-
bilities, reporting mechanisms for health officials,
duration of environmental monitoring after an emer-
gency, early warning surveillance mechanisms, etc.
The expansion of the formaldehyde vapor project was the only portion of
the proposal specifically funded by a US EPA TSCA grant in 1973. The state
Department of Health and Social Services did, however, reorganize itself un-
der the Division of Health to include the Section on Environmental Epidem-
iology charged in general with identifying and controlling toxic and hazard-
ous substances found in the environment, defined as the occupational, rec-
reational and residential settings of Wisconsin citizens.
Specific environmental health areas in which the Section has already
documented problems Include;
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1) multiple reports of in-r;-e- exposure Co formaldehyde vapors
froa foaa. insulation an--'or parricle board;
2) four episodes of human illness (one fatal) related to gases
emanating from liguid aanure systems (currently unregu-
lated} ;
'3) Shebcygaa River contamination by PC3s with fish registering
levels well above FDA tolerance levels;
4) landfills near Milwaukee adversely affecting private water
veils vhere only standard water analyses completed but
reported occurrences of illness;
5) significant increase in lung cancer. stomach cancer and
cardiovascular disease reported, with the state aware of
the need to study the taconite problem resulting from a
high level of use of pesticides by grain elevators;
6) significant excess of angiosareomas (liver cancer) that the
state suspects may be linked to the existence of state
lakes heavily treated with arsenic; and
7) a 70% attack race at a Wisconsin high school from solvent
exposure during a roof replacement.
The Section has initiated interdepartmental activity" on er.vir~r=ental
health issues through discussions on a number of topics including:
1) the feasibility of adding occupational questions to birth
certificates, to the history form for the state Early
Periodic Screening, Diagnosis, and Treatment Program
(EPSDT), and to information collected on infants with
metabolic defects;
2) adding laboratories involved in toxic substances testing
to the Division of Health's Laboratory Certification
and Proficiency Testing Program; and
3) a total and comprehensive revision of disease reporting
statutes with the Communicable Disease Section.
At the present time, death certificates with toxic substances involvement are
regularly reviewed, questions about lead exposure are now asked on all children
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screened by the EPSDT Program and blooc tests are done for lead on a pilot
basis, and the Bureau o£ Prevention morbidity newsletter carries information
to local health departments, hospitals, doctors and the public on health
problems related to toxic substances.
At Che Interdepartmental level, beyond representing the Department on
multi-departmental activities (Pesticide Technical Advisory Council, Gover-
nor's Task Force on Hazardous Materials Incidents, Governor's Task Force on
Hazard Abatement), the Section has already established a close working rela-
tionship with various programs in the Department of Agriculture, Natural Re-
sources, Justice, Energy, Transportation, Emergency Government and Industry,
Labor and Human Relations.
This strategy advanced by Wisconsin's Department of Health and Social
Services emphasizes the need to place health effects surveillance and re-
search at the same level as environmental pollution control programs. It
is the state's position that the epidemiologic approach to disease preven-
tion and control, although known and successfully applied throughout the
state for communicable disease control, has not really even begun its devel-
opment for environmentally caused health problems. And while the problems
of environmental epidemiology are extremely complex, with appropriate meth-
odologies still in need of development, the state views the utilization of
ep-f«i«»*i-tolosic techniques in each state for communicable disease control as
an unquestioned indicator that the same technique could be applied in each
state's environmental field.
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Governor's Office Contact
Mr. Mar.-. Popovich
Office of the Governor
State Capitol
Madison, Wisconsin 33702
(608) 266-1212
Agency Contact
Ms. Kay Dally
Department of Health &
Social Services
Division of Health
Bureau of Prevention
Section of Environmental
Epidemiology
Post Office Box 309
Madison, Wisconsin 53701
(608) 266-9711
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State L'abrella and O'her Mctevorthy Toxics-Related Legislation
This portion of the report reviews several pieces of state legislation
that either directly mandate procedures for controlling toxics or provide
examples of comprehensive "umbrella" legislation delegating broad operational
and oanageaent authority to the state for controlling pollution in all en-
vironmental media.
CONNECTICUT
Connecticut has enacted legislation covering reporting, labelling and
notification requirements for manufacturers and users of carcinogenic sub-
stances. Chapter 340d, Section 19-169q of the Connecticut Codes mandates
that any individual who uses or produces any carcinogenic substance in the
manufacture of any chemical, product or material must file an annual report
to the Commissioner of Environmental Protection and the Commissioner of
Health Services. This report must include:
1} the method of disposal of any waste generated by the man-
ufacture of such item, product or material;
2} the amount of each such carcinogenic substance used or
produced during the preceding year;
3) the amount of each such carcinogenic substance currently
being held in inventory; and
4) the method utilized to transport such carcinogenic sub-
stance.
Public Act Number 80-130 provides a listing of chemicals/elements con-
sidered to be earcinos«M»*g substances', including "all others determined to
be
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Connecticut Public Act Number 80-257 ests'c liiha« information anc no-
tification requirements for earn lovers in the state using carcinogenic sub-
stances in the workplace. The act requires every such employer to:
1) post a list of all carcinogenic substances as described
above which he/she uses or produces is. manufacturing
any item or for purposes of research, experiaen'ts or
treatments of any kind. The list must be readily
available for employee viewing and updated to reflect
any changes in the state list of carcinogens vithin
90 days;
2) furnish to each employee upon offer of employment, or on
January 1 of each year, a list of all such carcinogens
and the danger Inherent in an exposure to such a sub-
stance; and
3) provide education and training programs for new employees
during their first month of employment, adequately des-
cribing the presence of such carcinogens in the workplace
and proper methods of avoiding harmful effects from such
substances by keeping exposure within allowable limits.
Connecticut's Public Act Number 80-398 specifies labelling requirements
for hazardous substances which prohibit:
1) the introduction or delivery for introduction into commerce
of any misbranded or banned hazardous substances
2) the alteration, mutilation, destruction, obliteration or
removal of the whole or any part of the label of a naz-
ardous substance if such act is done while the hazardous
substance if held for sale after shipment in commerce
and results in the hazardous substance being misbranded
or banned;
3) the receipt in commerce of any misbranded or banned haz-
ardous substance and the delivery for payment or other-
vise;
4) guaranteeing that substances delivered or sold are labeled
properly;
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5) the f^ilura to allow entrv and inspection legally re-
quired, or failure to penaic the authorized copyinz
cf records: and
6) the introduction into commerce, delivery or receipt of
a hazardous substance in a reused food, drug or cos-
aetic container or a container not identified as re-
used but identified as food, drug or cosmetic con-
tainer; this will result in the substance being con-
sidered a misbranded substance.
In addition, Public Act Number 80-464, Section 1 requires any industry.
manufacturing fira or corporation Cexcept retail pharmacies) which mixes or
produces for commercial sale any elements or compounds listed in 40 CFR 116
and designated as hazardous substances in Section 311 of the federal Clean
Water Act to submit a list of all elements or compounds mixed or produced
during the past year to the Health Director in the town, city or borough
where such elements or compounds are mixed or produced within 30 days of the
director's request.
All records developed under these various information disclosure require-
ments are subject to public inspection, although there is a provision for the
state's maintenance of industry trade secrets. This set of carcinogenic and
hazardous substances information disclosure acts is unique in its attempt to
focus on a particular class of chemicals, carcinogens, stressing both their
adverse health effects, and their commercial and occupational utility.
The cumulative effect of these statutes is to make employers, as well
as employees, aware of the health effects associated with certain chemicals
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-,-Lr.-. v'-iich they work, thereby control-ling their potential adverse effects.
The st3.cu.tas 3.1.30 have a comprehensive application applying ;o a-: tivities
in all environmental aedia, addressing a wide variety of management func-
tions (inspection, reporting, education, training) and operations C-^r.ufa
ture, sale, use, transport, disposal).
Governor?s Office Contact
Ms. Linda Hershman, Assistant
Office of the Governor
Hartford, Connecticut 06115
(203) 566-4340
Agency Contact
Mr. Steve Malish, Chief
Toxics Hazardous Section
Preventable Disease Section
Bureau of Health Promotion
& Disease Prevention
Department of Health Services
Hartford, Connecticut 06115
(203) 566-8166
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ILLINOIS
The Illinois Environmental Protection Act of 1270, as amended, is a
comprehensive "umbrella" environmental statute. Its purpose is: "to es-
tablish a unified statewide program supplemented by private remedies to
restore, protect and enhance the quality of the environment and to ensure
that adverse effects upon the environment are fully considered and born by
those who caused them." The statement of purpose also recognizes that:
"air, water and other resource pollution, public water supplies, solid waste
disposal, noise and other environmental problems are closely interrelated
and must be dealt with as a unified whole in order to safeguard the environ-
ment."
This Act mandates using all environmental media, .management functions
and resources to coordinate and consolidate state environmental protection
programs. In this respect, the act enables the state to focus on toxic or
hazardous chemicals as the pervasive element in all environmental pollution
concerns, instead of focusing on the individual environmental mediums ad-
versely affected by chemical pollution.
The Act includes general provisions such as:
1) descriptions of the duties and responsibilities of the
Illinois Environmental Protection Agency and the
Pollution Control Board (both established to carry
out the act's mandate);
2) the confidentiality of trade secrets;
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3) public inspection jf scverr-.=-:. records;
*) enforc: lent procaduras ana requirements;
5) permitting procedures and requirements;
6) penalties for violations of the act and implemen-
ting regulations; and
7) judicial review of A;incy and Beard determinations.
Broad definitions of pollution in the various environmental medias of
air, water, land, refuse disposal and atomic radiation are also included.
For example, chemical contaminants are incorporated into the general water
pollution definition:
"such alterations of physical, thermal, chemical, biological or
radioactive properties of any waters of the state or such dis-
charge of any contaminant into any waters of the state as will
or is likely to create a nuissance or render such waters harmful
or detrimental or injurious to public health, safety or welfare,
or to domestic, commercial, industrial, agricultural, recreational
or other legitimate uses or to livestock, wild animals, birds,
fish or other aquatic life."
The act also encompasses the health-related implications of chemical ex-
posure in the environment in its definition of acute hazardous waste:
"a hazardous waste that has been found to be fatal to humans in
low doses or in the absence of data on human toxicity it has
been shown in studies to have an oral LD50 toxicity of less than
50 miligrams per kilogram and an inhalation LC50 toxicity of less
than 2 milograms per litre or a dermal LD50 toxicity of less than
200 miligrams per kilogram or is otherwise causing or signifi-
cantly contributing to an increase in serious, irreversible
illness."
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Governor's Office Contact
Mr. Rich Carlson, Assistant to the
Governor for Energy & Natural
Resources
Office of the Governor
State House
Springfield, Illinois 62706
(217) 782-3212
Agenc- Contact
Mr. David Schaeffer, Science Advisor
Division of Water Pollution Control
Illinois Environmental Protection
Agency
2200 Churchill Road
Springfield, Illinois 62706
(217) 732-1654
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OKLAHOMA
The Oklahoma Pollution Control Act of 19cS, as amsr^ad, is a compre-
hensive scare environmental statute designed to improve coordination and
consolidate environmental programs and activities. In this regard, the
act serves as a type of "unbrella" statute enccapassing all environmental '
media, relevant laws, agency activities and responsibilities. Through its
broad definitions of "environment" and "pollution," the act lays the foun-
dation for a comprehensive, integrated state approach to managing toxic sub-
stances.
In the Act, "environment" encompasses the outdoor atmosphere on and un-
der the surface of the land and waters of the state. "Pollution" of this
environment includes the presence of any substances or contaminants, including
noise, in quantities which are or may be potentially harmful or injurious to
human health or welfare, property or plant and animal life.
To implement control and abatement of environmental pollution, the
statute establishes an Oklahoma Department of Pollution Control and a Pol-
lution Control Coordinating Board to enforce all relevant environmental pro-
tection laws and to promote the maximum utilization of existing resources in
state agencies having existing and subsequent pollution control responsi-
bility.. Thus, by including all environmental mediums, state agencies, rele-
vant lavs and functions, this integrated act is designed to compensate for
deficiencies or inconsistencies in existing media-specific pollution control
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laws and regulations. This is primarily accomplished by detailing trie au-
thorities and responsibilities of the Coordinating Board in conjunction vith
the Department of Pollution Control, including:
coordinating management functions
eliminating duplicacive efforts
compelling state investigations
entering into inter agency agreements regarding the
acquisition of scientific, technical and admin-
istrative services
collecting and disseminating information among ag-
encies and the public
The act specifies information gathering and reporting requirements simi-
lar to Virginia's Toxic Substances Information Act. It requires that the De-
partment of Pollution Control:
1) establish and TiainrgiTT a central repository for rules and
regulations pertaining to pollution control in the state;
2} maintain a record of the disposition of federal and state
funds for pollution control activities;
3-) establish and maintain a system for citizen report of
violations of pollution control laws and regulations; and
4) establish a public information program on environmental
man a gt*n\em r .
Representatives of the Pollution Control Coordinating Board are also au-
thorized to enter and inspect any property, premises or establishment, except
those used exclusively as private residences, where a contaminant source is
located, constructed or Instailed.to ascertain compliance with state laws and
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raguliticr.s. The act also requires a-11 confidential business in:creation
regarding trade secrets, production methods, etc., discovered during in-
spections or investigations to be withheld free public hearings and- kept
confidential, provided that doing so dees not prevent the use of such in-
formation when subpoenaed in judicial proceedings for prosecution of vio-
lations of the act.
Any information or research material acquired by the Board of the De-
partment is required to be transmitted to the Continuing Education Center
for Ecology Information at East Central State College, where the information is
made available upon public request. The Board is also required to continue
studying the feasibility and success of integrating the pollution control
activities of the various state agencies, and to submit an annual report on
this management issued to the Oklahoma House and Senate with any pertinent
recommendations. This requirement presents a potential vehicle for a compre-
hensive description of state management coordinating activities around the
issue of toxic substances.
The Oklahoma Pollution Control Act serves as a statutory control in all
environmental media and is designed to enhance the comprehensive coordina-
tion of pollution control activities in the state as well as toxics infor-
mation gathering activities.
Governor's Office Contact
Mr. Ed Pugh, Senior
Administrative Assistant
Governor's Office
State Capitol
Oklahoma City, Oklahoma 73105
(405) 521-2342
Agency Contact
Mr. Lawrence Edmison, Director
Department of Pollution Control
Pollution Control Coordinating Board
Post Office Box 53504
Oklahoma City, Oklahoma 73152
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VIRGINIA
The Virginia Toxic Subssaneas Information Act CTSIA) of 1979 is a broad
based piece of environmental legislation primarily concerned with enabling
the 3gate to gather information on tosic substances in the state. The Act
specifically authorizes and requires investigations and inspections cf chem-
ical-related industries and gathering information therefrom. This provides
a comprehensive mandate for pollution control or environmental protection
based on an awareness of the hazards associated with toxics in the state.
The Act's stated purpose is rather broad in scope and encompasses a
number of interesting features:
"The state Department of Health shall administer and provide a
comprehensive program of preventative, curative and restorative
environmental health services; to educate the citizenry in
health and environmental matters; to develop and implement
health resource plans; to collect and preserve vital records
and health statistics and assist in research; to abate hazards
and nuissances to human health and the environment, in both
emergencies and otherwise, thereby improving the quality of
life in the Commonwealth."
Provisions of the Act are administered by the state Board of Health, state
Health Commissioner and the state Department of Health.
Another interesting facet is the act's delegation of authority to the
Board of Health for issuing special orders and regulations to meet any emer-
gency not provided for by general regulations in order to supress public
h*Mtlth nuisances and communicable, contagious and infectious diseases. These
two particular points in the Act (e.g., purpose and delegation of emergency
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authority) seem cr provide the state with fairly extensive povers, bctr. in
r = ;ard 10 what activities the Board and the Department of Health car. insti-
tute to control toxics and emergency orders for protecting public health.
Regarding information gathering activities, one section of the Act deals
with an authorized state official's right to entrv and the procedure for is-
L
suing warrants to inspect for information gathering and monitoring purposes.
In order to lawfully enter another's property to inspect, the state designated
inspector must have the property owner's (or custodian's) consent. If con-
sent is denied, the Commissioner of Health or designee may apply for a varrant
to inspect.
The Act.specifies the type of information manufacturers are recuirad to
report to Che state:
1) name and location of the commercial establishment;
2) names and estimated quantities of raw materials utilized
by the establishment;
3) catalysts;
4) final products.
The Act also requires that any commercial establishment utilizing a raw ma-
terial, catalyst, process solvent or final product, or manufacturing any
Class I substances meeting or exceeding specific amounts specified by the
Board of Health must report the following information regarding this use to
the Board:
1) name of the toxic substance;
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2) known or reasonably expected to be known chemical nroper-
ties of toxic substance not readily available in stan-
dard reference texts;
3) appropriate means or methods of detoxification or de-
contamination;
4) manner and extent of toxic substance emission into the air,
water and workplace or environment in general;
c
5) whether or not there is a foreseeable risk of danger that
the substance will adversely affect sewage, other waste
treatment, solid waste disposal systems and employee
health due to exposure.
The Act also requires any establishment that utilizes a substance not
listed as Class I, but knows or reasonably expects to know that the sub-
stance is toxic under the circumstances of its manufacture and ziay pose a
substantial threat to human health or the environment, to report this to the
\
Board. These report requirements also apply to any employee, agency, holder
of any patent, consultant or independent contractor.
The Act has a section on confidential business information in which the
Board is not allowed to release information on secret processes, patents,
etc., to anyone, including the federal government, unless the agency or in-
stitution is required by law or regulation to have such information and a
wri-ten request for that information is made.
Throughout all of these provisions and reporting requirements, the Act
utilizes a broad definition of toxic substances. Toxics are considered to
be "any substances including raw materials, intermediate products, catalysts,
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final produces or bvprcduc." of any s'srmf acturing cierati.cn ccr.du^tec on'a
c-DLzr.ercial establishment chat has the capacity through its physical, bio-
Icgicai or chemical properties to pose a substantial risk of death or is-
paiment, either immediately or over time, to the normal functions of huaans,
aquatic organisms or any animal." Thus, ia defining tcxic substances ir.
rems of posing a substantial risk of death or i^pairtsent, the Act encom-
passes not only immediate crisis situations, but the long range chronic or
cumulative effects of chemical substances.
The Act also requires an annual report on the status of toxics control
in Virginia to be made to the General Assembly and the Governor. The report
is a useful information tool in itself, as it includes such information as
the state organizational structure for controlling toxic substances, pertin-
ent federal statutes and agencies involved in state toxics activities, state
methods for improving iateragency/program coordination on toxics issues, and
a general overview and annual orientation toward controlling toxic substances.
Thus, the Virginia Toxic Substances Information Act provides the state
with the legal mandate for collecting toxics information, lays out the or-
ganizational structure for analyzing and acting upon the information col-
lected, and provides an annual reporting mechanism to maintain surveillance
over the general toxics control strategy.
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Governor's Office Contact
Ms. Joy Manson.
Executive Assistant
Governor's Office
Richmond, Virginia 23219
(804) 786-2211
Agency Contact:
Dr. John Hiickin, Director
Bureau of Toxic Substances
Departaent of Health
Richmond, Virginia 23219
(804) 786-1763
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Innovative' Programs, Projects and Studies
This portion of -'.-.= report -describes a variety cf innovative state pro-
grass, projects and studies related to dangerous chericals taansgenent. They
include: emergency response, enforcement tactics, health effects studies, in-
formation gathering, integrated environmental planning and review, management
inventories, networking activities within and among states, standards develop-
ment for non-regulated chemical contaminants, testing procedures, training,
and working with industry and local governments.
Sone of the activities highlighted here are parts of integrated state
toxics management programs, while others are discrete activities which are
noteworthy as potential elements of an integrated program.
EMERGENCY RESPONSE
leva. - Portable "spill liarzry" far regional emergency response cffia'lals.
The Compliance Division of the Department of Environmental Quality has
developed a portable library to aid emergency response personnel in identifying,
controlling and abating chemical emergencies. The Division has compiled a
"Spill Library" containing reference materials describing chemical properties.
human and environmental impacts and procedures to contain chemical spills in
the air, land and water.
The state is divided into six major emergency response regions, each
with a specific emergency response plan, trained personnel and a copy of the
spill library. The library is portable, and a trained emergency response
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official in each region is on 24 hour call with the library to respond co
hazardous materials incidents.
Governor's Office Contact
Mr. Elmer "Dutch" Vermeer
Admin1strative Assistant
State Capitol
Des Moines, Iowa 50319
(515) 281-3064
Agency Contact
Mr. Pete Hamlin-, Director
Compliance Division
Department of Environmental Quality
Henry A. Wallace Building
8900 East Grand
Des Moines, Iowa 50319
(515) 281-8854
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The Kentucky Disaster Plan includes a specific section dealing with
emergency response to hazardous materials incidents referred to as the Annex
Q_Plan. The plan provides the framework for actions to be taken when a haz-
ardous aaterial is released into the environment threatening injuries or
deaths or property damage or degradation of the environment. Annex Q spe-
cifically addresses the cooperation and coordination of the resources and ac-
tions of the industry, local, state or federal government needed to remove the
threat to public health, welfare and safety caused by a hazardous materials
incident.
The plan includes sections on general disaster response organiza&ion,
tasks required of local and state government according to specific agencies,
a list of contacts for technical assistance according to type of emergency
and hazardous material involved, and a section of the concept of operations
to be carried out in the event of a hazardous materials emergency.
The concept of operations section breaks down response procedures into
the following directives:
1) reports of potential or actual hazardous materials acci-
dents are to be made to the nearest local emergency re-
sponse official;
2) local officials will immediately contact the Kentucky
State Police and State Fire Marshall, and should at-
tempt where possible -to determine the type of haz-
ardous material involved;
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3) local officials vill, if .the situation warrants, activate
the local EOC. coordinate multiple service operations,
request outside assistance acd implement.local emergency
broadcasts as necessary;
4) the first state agency on the scene assumes operational
control until the state agency having primary responsi-
bility for the major threat posed by the incident re-
ports to the scene;
5) the operating agency on the scene will contact the Disaster
and Emergency Services Duty Officer if necessary, and if
more than two state agencies are involved, DES is notified
by the senior member of the agency exercising operational
control;
6) DES coordinates all further response, including the notifi-
cation of the following state agencies if not already no-
tified:
Fire Marshal
Bureau of Highways
Department of Agriculture
Kentucky State Police
Department for Natural Resources
& Environmental Protection
Division, of Explosives & Blasting
Department of Human Resources
7) the onsite Command Post is established at the vehicle of the
senior Kentucky State Police Officer, and the senior member
of each state agency present reports to the Command*Post
upon arrival at the scene and departure;
8) the State Emergency Operations Center (EOC) is kept informed
of local emergencies to the F3"*"* extent possible, and
may be activated by the Executive or Assistant Director of
DES or DES Directors of Operations or Response and Recovery.
A*?, state agencies involved will dispatch an authorized rep-
resentative to the EOC;
9) all public information activities and releases are coordinated
by the DES Coordinator at the scene, and all state agencies
refer media inquiries to the DES Coordinator or to the Pub-
lic Information Officer at the EOC;
10) the primary operational authority during the recovery phase of
operations can be shared or transferred upon direction from
the EOC or by agreement at the scene and notification to EOC.
As recovery operations proceed, the nature of the threat may
alter considerably, with the initial threat descreasing while
one or more ether major hazards remaining constant or in-
creasing in intensity.
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."r. addition tc these de-ailec directives for response and recrv-;- rv to
a. '-arard^us -^iterials emergency, the Annex 0 also provides iap;.:ar.t de-
scriptions of the tasks required of local government - initiate investiga-
tion, isolate area, restoring area co normal wherever possible, evacuate
persons from threatened area, and request stats/federal assistance when lo-
cal resources are inadequate - and tasks required of state government, with
these latter tasks being broken down according to the eight state agencies
mentioned in number 6 above.
The section on contacts for technical assistance includes phone numbers
of state and federal agencies as well as industries with expertise in such
areas as hazardous chemicals, poisons, pesticides, military chemicals, air-
craft incidents, railway accidents involving explosives, and water related
incidents. By providing such a highly organized method of emergency response,
stressing not a particular agency as the ultimate authority but identifying
specific areas of concern and expertise, Annex Q attempts to insure the or-
derly flow of personnel, equipment and expertise to the accident scene. The
state reports a large success rate in safely controlling hazardous materials
incidents since the adoption of Annex Q, and reports that a standard operating
procedure that is both efficient and productive has resulted.
Governor's Office Contact
Mr. Rush W. Dozier
Attorney for the Governor
Office of the Governor
State Capitol
Frankfort, Kentucky 40601
(502) 564-2611
Agency Contact
Mr. Charles Collier
Emergency Response Coordinator
Office of the Secretary
Department for Natural Resources
& Environmental Protection
Pine Hill Plaza
Frankfort, Kentucky 40601
(502) 564-3350
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rj ?Z-i aatsgortzes five types of hazardous materials ->.-
2ider.se., -ji-h response far ezeh.
The Tennessee Disaster Assistance Plan also contains a specific seccicn
detailing the procedures to be followed in the event of a hazardous matierals
incident. Tennessee's plan is similar to Kentucky's in that a detailed for-
oat is laid out in the plan including a concept of operations, tasks to be
u
carried out by local and state emergency response personnel, and command and
control responsibilities of each state agency responding to a hazardous ma-
terials emergency. Differences between the two plans occur in the actual re-
sponse and recovery methodology employed.
Initially, the state categorizes hazardous materials incidents into the
following five categories;
Category I Major emergency; contamination and /or fire has oc-
curred; all agencies prepare for systematic opera-
tion in-excess_of_24__hours .
Category II Large spill.
Category III Large spill; possible fire and/or contamination.
Category 17 Large spill; more than 2 kiloliters or 2500 kilo-
grams; moderate contamination.
Category V Small spill; less than 2 kiloliters or 2500 kilo-
grams; Tn^f^inaT fnnfstijfinstt ifln .
Local government tasks for hazardous materials emergencies include :
develop a local hazardous materials response plan,
assign responsibilities for coordinating hazardous ma-
terials accidents to a local government agency,
develop mutual aid agreements with adjacent jurisdictions,
initiate the investigation, isolate the area and restore
the area.
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"When a hazardous inatr-.rials accident is beyond the c.3~irility cf local gov-
ernment, the Directc: cf the scare Offies of Civil Z^r^r.se sr.d Eser-rsr.cy
Preparedness (acting for the Governor) =ay direct assistance fros state ag-
encies no local governments. State agencies with delegated hazardous aa-
cerials emergency responsibilities include:
Office of Civil Defense and Emergency Preparedness
Department of Public Health
Department of Transportation
Public Service Commission
Department of Labor
Department of Agriculture
Department of Safety
Department of Conservation
Tennessee Wildlife Resources Agency
Tennessee National Guard
State government response to a hazardous materials incident is supported
by the Hazardous Materials Response Force (HMRP), coordinated by the Director
of Civil Defense and Emergency Preparedness. The HMRF is composed of approxi-
mately 160 trained personnel from various state agencies, each of which is
issued equipment items to insure safety. In addition, the HURT has access to
any of the five MAXI-VAN trucks containing specialized equipment useful in re-
sponding to hazardous materials incidents (airpacks, respirators, toxic de-
tection equipment).
A Hazardous Materials Response Team (HMRT) is also created in the event
of a hazardous materials incident in order to match expertise with the nature
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of the chemical involved in the emergency. HMRT members are a cadre of per-
sonnel drawn from the HMRF. The HMR? will also be augmented by expertise
from the Civilian Advisory Team. The Team, composed of specialists in haz-
ardous substances, will make recommendations to the HMEF on procedures for
neutralizing the potential harmful effects of hazardous materials.
If the situation presents a serious threat to persons and/or property,
it is the responsibility of State Civil Defense to assume coordination for
those problems related to individuals affected by the incident. When a major
hazardous incident occurs (Category I through IV) State Civil Defense Opera-
tions will notify the Tennessee Wildlife Resources Agency, whose communica-
tions system will serve as the primary system for communication between State
Civil Defense and Che on-scene coordinator. In addition, Civil Defense Op-
erations will secure and dispatch a Public Information Officer (PIO) to the
scene of the incident to serve as liaison and-information officer to the news
media. The PIO will report and remain with the on-scene coordinator and hold
hourly news conferences.
Thus, through the Hazardous Materials Response Force, Team and Civilian
Advisory Team, Tennessee's plan for handling hazardous materials incidents
attempts to work within a defined emergency response framework but to also
approach each incident on an individual basis, directing only those individ-
uals or equipment with specific expertise in the chemical area involved. By
approaching emergency response in this manner, the state is better able to
utilize its personnel and resources in the most effective and efficient manner.
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r Tier's Office Contact
Mr. Keel Hunt, Special
Assistant to the Governor
Governor's Office
State Capitol
Nashville, Tennessee 37219
(615) 741-3621
Agency Contact
Col. W.S. Wallick, Deputy
Director for Resources
Division of Civil Defense i
Emergency Preparedness
Emergency Operations Center
Department of Military Affairs
National Guard Armory
Sidco Drive
Nashville, Tennessee 37204
(615) 741-5131
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EXFOSCSMENT
:.*«i; Ssrsay - In-spcgsnay ^".fcrssnenl: strike force for /tsssrirns X£3tes.
New Jersey's Interagency Hazardous Waste Strike Force is a creative re-
sponse to the complex problems associated with controlling illegal toxic
waste disposal. The Strike Force is comprised of representatives of:
1) New Jersey Department §f Law and Public Safety (Divisions
of Criminal Justice, Law and State Police),
2) New Jersey Department of Environmental Protection,
3) U. S. Environmental Protection Agency,
4) U.S. Attorney's Office of the District of New Jersey.
It was created in July 1979 by executive order and funded by the U.S.
EPA primarily as a result of state recognition that the various state and
federal agencies responsible for controlling toxic waste disposal needed a
coordinated framework within which to function.
New Jersey's Department of Law and Public Safety Division of Criminal
Justice -became involved in investigating and prosecuting illegal waste dis-
posal cases in 1976 when Newark police and fire personnel discovered drums
of toxic waste dumped under an elevated highway in the city posing an immed-
iate threat to the public health and safety. With no specific statute al-
lowing for criminal prosecution of such activity then existing, the Division
in conjunction with the Department of Environmental Protection (DEP) began
working to investigate the incident and determine whether a viable method of
criminal prosecution could be developed.
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STANDARDS DEVELOPMENT
'\-:nruiS>.y znd 7srm^'.t - s&dsvzl szzcyure lirr^z-'.ir. sc-slisd to nc-n-fz-z-z"-..
The federal Occupational Safety and Health Administration (OSEA) has de-
veloped Threshhold Limit Values (TLVs) to protect worker health. Both Ken-
tucky and Vermont state clean air programs have voluntarily adopted ILVs as
a means of assigning emissions limitations to potentially hazardous air par-
(I
tieulates not covered by federal air pollution control standards . TLV is the
necessary recovery time Cor threshhold limit) for workers exposed to hazardous
substances in the workplace.
In Kentucky, the Air Pollution Control Board converts this use limi-
tation for specific chemicals into an ambient air standard where the federal
government has not specified- an emission limitation.
In Vermont, the same methodology is utilized, whereby environmental ex-
posures determined to exceed 102 of the TLV for that particulate are targeted
for detailed investigation. An industry emitting particulates in excess of
10Z of the respective TLV must adequately prove that the emission presents no
danger to the environment or public health. The state, based upon its inves-
tigation and the industry's documentation, regulates the air emissions accord-
ingly.
The integration of already well defined and investigated impact data
from one media (here the workplace) into the rules and standards development
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cf another (in this case, air), exhibits an effective means of consolidating
chemical information collecting activities to achieve not only the protection
of the worker but the general population and the environment as veil.
Governor*s Office Contact
Mri Rush W. Dozier
Attorney for the Governor
Office of the Governor
State Capitol
Frankfort, Kentucky 40601
(502) 564-2611
Ms. Nancy Knox, Special
Assistant to the Governor
Office of the Governor
Montpelier, Vermont 05602
(802) 828-3333
Agency Contact
Mr. Bill Clements, Supervisor
Field Operations Branch
Division of Air Pollution Control
Department of Natural Resources &
Environmental Protection
West Frankfort Office Complex
1050 U.S. 125 South
Frankfort, Kentucky 40601
(502) 564-3560
Mr. Harold Garabedian, Chief
Air Pollution Control Engineer
Air i Solid Waste Program
Agency of Environmental Conservation
State Office Building
Montpelier, Vermont 05602
(802) 828-3395
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TESTING PROCEDURES
of AI-1I5 -z ?t
sis.
New Jersey's Program en Environmental Cancer and Toxic Substances (PECTS)
is demonstrating the utility of invitro biological testing procedures. PECTS
has emphasized developing short term invitro tests that are capable of de-
termining the presence of a wide range of chemical contaminants in a variety
(I
of biologic samples (water, sediments, fish and fauna).
The PECTS program has several objectives in using these invitro testing
procedures (also referred to specifically as the Ames Test):
1) to identify geographic areas in the state that contain sig-
nificant levels of mutagenics and carcinogenics;
2) to demonstrate the utility of such tests for targeting en-
vironmental media for sampling and further in-depth chem-
ical analysis;
3} to demonstrate the feasibility of using such tests as regu-
latory or enforcement tools; and
4) to demonstrate the feasibility of using invitro tests as
surrogates to more in depth chemical tests in monitoring
for compliance.
Invitro tests are important because synergistic effects can be observed
or discovered only in biologic samples, which may contain numerous chemical
elements. In a chemical mixture, for example, only one element may be a
carcinogen, but other elements present may intensify the carcinogenic effect.
In addition, the mixture may be of two or more extremely weak carcinogens
which, when combined, may result in a greatly enhanced carcinogenic effect.
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Thus, biological tests such as the toes Test have an inherently greater abil-
ity ts detect such interactions and variations than the lengthy, more fre-
quently used method of testing individually for those chemicals posing the
highest risk to humans or the environment.
Another advantage to invitro testing is that short term biologic tests
are less expensive to perform than the more detailed specific chemical ana-
lyses. For example, the Ames invitro mutation assay of an air sample costs
approximately $85, while a comprehensive chemical analysis of the same air
sample costs as least $1,000 (as the sample must be tested for each potential
dangerous chemical separately). The more expensive chemical analyses, then,
can be selectively used for specific determinations after an invitro scan
shows that potential problems actually exist. This contributes to a more
efficient and cost saving monitoring program.
Governor's Office Contact
Mr. Jeffrey Light, Assistant
Counsel to the Governor
Governor's Counsel's Office
State House
West State Street
Trenton, New Jersey 08625
(609) 292-7400
Agency Contact
Ms. Judy Louis, Research Scientist
Office of Cancer & Toxic Substances
Research
Department of Environmental Protection
190 West State Street
Trenton, New Jersey 08625
(609) 984-6070
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TRAISUSG
o - Itaticnal 'ficzxrdc'ts nzteyiz's -zminina institute fsr gcvsi^.'r.s :~
offio-izis and 'industry.
The Colorado Training Institute (£11) located in Denver, Colorado is the
first professional school in the country totally devoted to promoting hazar-
dous materials safety through education and training. The school is funded by
the U.S. Department of Transportation through the Colorado Division of Highway
c
Safety, with three full-time employees from the Denver Police Department, and the
Colorado State Police and the Division of Highway Safety operating the overall
program. Instructors are representatives of major national companies and agen-
cies involved in chemical transport, packaging, storage, etc., who volunteer
their time with the assistance of the organizations they represent. Some of
the companies and agencies involved include: Phillips Petroleum, Liquid Air,
*
Amerigas, Dow Chemical, Frontier Airlines, the U.S. Coast Guard and the Colo-
rado Agriculture Department.
CTI is the culmination of nearly a decade of research, course develop-
ment and volunteer participation by representatives from federal, state and
local government and private industry, working together through the Colorado
Committee on Hazardous Materials Safety. The Committee was formed in 1973
when the Denver Police Department organized a meeting of representatives from
federal, state and local governments and private industry to address the is-
sue of hazardous materials safety. The lack of training among emergency re-
sponse personnel at the scene of a hazardous materials incident was the
major focus to the meeting, and a rese.? -ch subcommittee was formed which ul-
timately developed a unique, professional training program and recruited a staff
of instructors with nation-wide expertise.
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3y 1975, CTI trained 1,375 individuals through seminars conducted around
che state. In the same year, the Conraittee sponsored a national seminar in
Denver, with representatives from 41 states and Canada participating. As a
result, several states went on to develop training programs in their states
for state and local emergency response personnel.
The committee was officially recognized in April 1976 when the governor
of Colorado directed all state departments and agencies by executive order to
cooperate to the fullest extent possible in achieving the committee's objec-
tives. These include:
to provide instructions on the safe handling of hazardous
materials to minimize the risk of injury and property
damage during the control and cleanup of an unintentional
release of materials into the environment;
to formulate, develop and present a program of instruction
on the recognition of potential danger involved with haz-
ardous materials during tne normal course of transpor-
tation and storage; and
to support the establishment of regulations, controls, and
procedures designed to ensure the safe transportation
and storage of hazardous materials.
CTI conducts a variety of s^^^s . A three-day hazardous materials
workshop is offered for individuals responsible for community safety in the
event of a hazardous materials incident fire officials , law eoforcement
officers, civil defense personnel and ambulance crews. It includes a com-
prehensive overview of hazardous materials with techniques for identifi-
cation, labeling, shipping papers, first aid, containment and control, .--id
it examines specific classes of materials such as radioactive, pesticides,
industrial chemicals, compressed gas and explosives.
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Another two-week hazardous materials seminir Is conducted by tweaty-
3ev*r. experts from around the country, and is geared toward management and
supervisory personnel who have attended the three-day session. This com-
prehensive course expands on the topics addressed in the three-day course,
emphasizing planning and coordination management.
CTI offers a five-day seminar for shippers and carriers designed for
dispatchers, safety directors, dock foremen, billing clerks or anyone directly
responsible for ensuring that hazardous materials are ready for shipping.
The course attempts to address the common complaint voiced by shipping person-
nel that many training courses are conducted too quickly to allow for compre-
hension of the vast amount of material involved. Extensive time is devoted to.
o^atn-Tn-fng the U.S. Department of Transportation's Code of Federal Regulations,
»
the proper preparation of shipping papers (with special emphasis on the com-
plicated regulations for radioactive material) and proper material labelling
and classification.
CTI also conducts a five-day cargo tank inspection course covering every
aspect of cargo tanks, including safety features and appropriate emergency
action. Aimed at chemical manufacturers and shippers, the seminar stresses
preventative maintenance.
Another four-day commercial vehicle Inspection seminar is designed both
to assist law enforcement agencies in enforcing regulations and to instruct
industry on the proper compliance of commercial vehicle laws.
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The proper management of hazardous materials is viewed not only from
-he perspective of containment and clean up of a spill or emergency, but also
as the proper labelling, classification, handling and transporting of these
materials. In addition, all levels of the public and private sector are in-
volved in the CTI program - from industries manufacturing hazardous materials
and their containers, to shippers and carriers of these materials as well as
state and local emergency response personnel. With the high level of private
industry involvement, both at the instructional as well as participatory end,
the Institute offers a viable means of controlling toxics incidents at the
beginning of the chemical life-cycle through education and training.
While the Colorado Training Institute's curriculum has a definite trans-
portation emergency orientation, it addresses the safe management of hazardous
\
materials comprehensively, through the life-cycle of the material. Its broad
based curriculum is thus important to the development of integrated toxics
management strategies as are the large number of participants from both the
public and private sector and the high level of involvement in the program
by private chemical-related industries.
Governor's Office Contact
Mr. Leonard Slosky, Assistant
to the Governor for Science
& Technology
Office of the Governor
State Capitol
Denver, Colorado 80203
(303) 866-2471
Agency Contact
Mr. Darrel Behrendsen, Director
Colorado Training Institute
1001 East 62nd Avenue
Denver, Colorado 80216
(303) 289-4891
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WORKING WITH INDUSTRY
''cn~yts. - Stcr:s rra -industry cccpsrzttcn. in yedue-'.-js -snl zcr.
Beyond the basic pesticide program required by the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA) , Montana has several specific proj ects
aimed at fostering cooperation Between the state agriculture industry and the
state Department of Agriculture. This cooperative effort includes:
1) the establishment of several Integrated Pest Management C.IPM)
programs aimed at reducing pesticide misuse in specific
cropping systems and training agricultural pesticide users
in the best management practices for controlling pests, at
the same time protecting the health and environment. IPM
programs are provided for under FIFRA, and involve working
with industry to develop and implement the most effective/
efficient procedures for applying pesticides, controlling
pest infestation and protecting the health and environment
in the area of application.
2) working with those applicators who ^ir pesticides prior to ap-
plication, to reduce the number of applications necessary
and, thus, the cost to applicators, as well as increasing
the applicators' awareness of the potential negative impacts
on the environment caused by over nixing and unnecessary
applications .
In addition, the state has established a network of area test plots to
provide baseline information on the environmental effects of pesticides. The
test plots provide soil and air samples for analysis that can be modified and
controlled to produce specific data for Impact analysis. Provisions also
exist for special training of state pesticide enforcement personnel at Fort
Collins, Colorado, in methods of collecting health effects data and working
with health authorities and epidemiologists to increase their awareness of
potential human health effects related to the production and use of pesti-
cides.
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Montana esploys extensive laboratory facilities and experimental chea-
ists to provide analytical capability needed for in-depth studies and it reg-
isters 3051 pesticides prior to use in the state, licenses retail dealers and
applicators, and regulates the sale of pesticides at the retail level. Through
direct and frequent communication and the acknowledgement of mutual needs and
responsibilities, the Department of Agriculture has developed a strong working
relationship with the state pesticide and agriculture community.
Governor's Office Contact
Mr. Ottis Hill, Special
Assistant to the Governor
Office of the Governor
State Capitol
Helena, Montana 59601
(406) 449-3111
Agency Contact
Mr. Robert LaRue
Field Services Bureau Chief
Environmental Management Division
Department of Agriculture
Agriculture Livestock Building
Capitol Complex
Helena, Montana 59601
(406) 449-2944
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WORKING WITH LOCAL GOVERNMENTS
The Department of Environmental Quality Engineering (DEQE) is working
on a plan for informing com^n-fty health officials, firefighters and police
officers about the hazardous waste problem in the state and to encourage their
participation in addressing it.. In addition, DEQE is developing regional
programs to provide technical assistance and guidance to communities through
its regional hazardous waste coordinators. In 1980, DEQE officials had a
state-wide training session on hazardous waste enforcement with over 500 com-
munity officials in attendance to work out this strategy.
DEQE suggests the following steps that communities can take on their own
to begin to assess and address possible hazardous waste problems. First the
state's local Boards of Health are encouraged to help their communities de-
velop a local hazardous waste program. Possible tactics include first iden-
tifying local resources such as:
1) the Fire Department, which issues licenses for storing
and responds to hazardous materials spills,
2) Police Department with the authority to patrol the com-
munity and arrest violators,
3) Board of Health with broad powers for protecting the
public health,
4) Department of Public Works or town engineer with loca-
tions of sewers, drains, etc.,
5) conservation commission with knowledge of wetlands and
other natural resources in the community,
6) Industrial Development Commission, Planning Agency or
Chafer of Commerce with knowledge of community in-
dustries ,
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7) Water Deoartsent Superintendent with knowledge of ground
water sources and drinking water recharge zones, etc.,
in the community, and
8) concerned citizens with specific hazardous waste related
knowledge or experience.
Second, local efforts need to be organized and coordinated along with
local resources. The state has appointed four hazardous waste coordinators
who communicate with the local coordinator, but efforts should be made to
coordinate local officials, concerned citizens and business leaders.
Nest, areas for -immediate involvenent are outlined, and need for devel-
opment of a local hazardous waste management plan is emphasized. Suggestions
include identifying:
1) all the hazardous materials in the community by cate-
gories, classes, volumes, locations and type/age of
containment and looking into hospitals, dry cleaners,
research labs, etc. as other possible hazardous waste
generating sources,
2) what goes on at the co"""i"rty landfill,
3) old, abandoned dump sites by checking maps, photographs,
talking to older community residents, etc.,
4) transportation routes for hazardous materials,
5) map out local water supplies,
6) underground gasoline storage tanks and test for leakage.
Other activities could include developing local emergency action plans,
clarifying local agencies responsibilities, coordinating local enforcement
and providing educational programs for industry, schools and the general public.
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In addition, DEQE also ?T "rides sTiidance in a twelve-step police pro-
caduri for investigating iurr.ng or transporting violations. The technique
is similar to police procedures followed in narcotics cases, whereby all
actions are carefully performed and all evidence is collected and preserved
in order to establish a legal "chain of custody" between the substance and
the violator. These steps include:
1) know the hazardous waste,
2) examine the barrels,
3) if there is probable cause to believe the driver is
transportating hazardous waste, request to see the
license to transport,
4) if he does not have a license it is a crime place
the driver under arrest,
5) if there is probable cause that a crime is being com-
mitted, search the driver,,
6) have the truck towed to a safe place,
7) after seizure* ask the district attorney to issue a
court order impounding the vehicle or a search
warrant,
8) contact DEQE immediately to have samples collected,
9) photograph the truck from all angles,
10) stay with the DEQE staff when samples are being taken
and record ^11 words and numbers on the barrel,
11) when the analysis comes back from the laboratory, and
the district attorney is satisfied, ask him to pe-
tition the court for an Order of Destruction of the
barrels, and
12) remember that the case must be prepared for presen-
tation in court; thus it is necessary to collect
and preserve all evidence, establish a chain of
custody and ensure that all reports are complete,
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Although the focus of this Iccal'-involvement project in Massachusetts
is on hazardous waste, this methodology of providing a liaison and advice to
locals could foreseeable be used for toxics-related issues as well. Ac a
time when public awareness and fears of toxics hazards are becoming widespread,
resulting at times in seemingly irrational public response to virtually any
local development proposal involving chemicals, the development of a statewide
network of local coordinators, community response teams and public "investi-
gators" is a timely and sensible approach to an element of integrated toxics
management.
Governor's Office Contact
Mr. Michael O'Hare, Director
Office of Policy Management Analysis
Executive Office of Environmental
Affairs
100 Cambridge Street
Boston, Massachusetts 02202
(617) 727-9800
Agency Contact
Mr. Anthony D. Cortese,. Commissioner
Department of Environmental Quality
Engineering
100 Cambridge Street
Sultonstall Building - 20th Floor
Boston, Massachusetts 02202
(617) 727-2690
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.Ve-.j Zovk - County "nzssrdcus ixists,s^t&
Another example of scace and local government cooperation to improve
hazardc'.s substances management is the New York County Hazardous Waste Site
Search Program. After the Love Canal emergency, New York forced an inter-
agency task force on hazardous waste to investigate past industrial dumping
practices in Niagara County. Concurrently, a toxics task force began to
u
identify sites in other counties around the state. Thus, in an effort to
coordinate and consolidate these activities, a county-by-county site search
and inventory program was mandated in 1979 by the New York Inactive Hazardous
Waste Disposal Act.
The county-wide search and resulting inventory must include:
1) each site's location,
2) all available information on ownership
3) period of use
4) nature and quantity of materials disposed
5) soil and water conditions
6) T*am«* of industrial generator Cs) producing the waste
Two assessments are required for each site: one,of environmental prob-
lems on or near the site, and one of health problems related to the site.
Environmental concerns are evaluated using information about surface water
contamination, flora or fauna stress and lack of vegetation, fowl, fish or
wildlife at or near the site. The health assessment is the more difficult
due to the scarcity of firm environmental and health data. Thus, most of
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-r.e health assessments are general statements of health concerns determined
by the local health officials, based on several considerations: health cc=-
plaiats and inquiries, the proximity of residences or work environments to
the sitsCs), health department data on public and private water supplies in
the area, and meteorological data for the area in relation to the contents
of the disposal site.
As all counties are not required to follow a strict investigative and
analytic procedure, two counties have developed interesting search and in-
ventory techniques. One county compiled a detailed listing of sites through
a highly visible advertising campaign in which information was solicited from
the general public. This was both an attempt to involve the public for edu-
cational purposes as well as to tap a potentially useful information source
those individuals who have lived in the community for a long time and nay
recall the existence of a long since covered dump site. Another county con-
ducted a detailed search of historic aerial photographs. With careful study
given to those dating back several decades, numerous sites long ago covered
and forgotten were revealed.
This county-by-county approach to inventorying dump sites in the state
capitalized on the realization that local groups and citizens are often more
aware and knowledgeable fhart state officials of toxics-related practices and
activities occurring within specific areas of the state. In addition, better
and more cost efficient results can be obtained when each county develops
its own site relevant management and scientific techniques for searching and
inventorying.
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Governor's Office Contact
Mr. Frank Murray,
Program Associate
Stats Capitol - Room 227
Albany, New York 12224
(518) 474-1288
Agency Contact
(Same as Governor's office contact)
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la aa effort to address the problea of apparently increasing hazardous
aaterials incidents, Thurston County officials surveyed public agencies with-
in the county to determine whether a hazardous materials problea exists. The
findings of the survey indicated that a lack of information available on the
types and amounts of hazardous1-materials manufactures, transported and stored
in the community existed. In addition, numerous county emergency response
officials expressed concern over a lack of prior knowledge regarding potential
problems to be faced in responding to a hazardous materials emergency. It was
their suggestion that if information of this sort was kept on file fcr pre-
fire planning, proper emergency response and knowledge of potential problem
areas, it would substantially contribute to the reduction of injuries and loss
of life and property within Thurston County.
As a result, Thurston County officials requested the assistance of the
Department of Emergency Services in coordinating a risk analysis on hazardous
materials within the county. The department responded by conducting a survey
of seventy-one (71) targeted businesses in the county in an effort to develop
a data base of hazardous materials related information for future emergency
response planning. The Hazardous Materials Questionnaire requested such in-
formation as:
1) the businesses emergency contact person and his/her phone
number;
2) the name of any pesticide/herbicide, caustic/corrosive,
flammable, explosive, oxidlzer, gas or other chemical
produced, transported or stored by the business;
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2> the average quantity handled per raonth of the above nen-
tioned hazardous materials: -
*) the aeehod(s) of transportation by vhich hazardous sa-
teriais are delivered/shipped Co the business (truck,
train, ship, plan, barge, pipeline);
5) the naae of the transporterCs?;
6) - whether any hazardous aaterials emergency response ex-
perts ars eaoloved by the business;
7) what, if any, potential hazardous aaterials problems
appear to exist in Ihurston County.
As a result of the survey, the Thurston County Hazardous Materials Ana-
lysis was completed and published essentially as a director:.- of businesses
involved in hazardous materials activities in the county, broken out into
various categories:
1) hazardous materials handlers in the county,
2) alphabetized listing of chemical classes in use in the
county,
3) alphabetized listing of the county businesses utilizing
hazardous materials,
4) hazardous materials carriers transporting hazardous ma-
terials to retailers in Thurstoa County,
5} a break out of hazardous materials businesses according
to the city/tovn in the county where it is located,
6) businesses utilizing radioactive materials in the county.
A total of fifty C50) businesses are listed in the directory (fifteen of
those being educational institutions), with addresses, phone numbers and types
of chemicals utilized and their associated hazards provided. This directory
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appears not only to provide local 'emergency response personnel vicn easily
accessible information on hazardous materials preser.t in the count;*, but also as
an example of local and state government cooperation in attempting to improve
the overall management structure for hazardous materials control. The state
Department of Emergency Services provided staff time and associated expenses
and the questionnaire was sent^out under state letterhead which may have pro-
vided an additional impetus for businesses to complete and return the surveys.
Volunteers provided invaluable assistance in conducting the county-wide survey.
Governor's Office Contact
Mr. Dave Stevens, Assistant
for Natural Resources
Office of the Governor
State Capitol
Olympia, Washington 98504
(206) 753-6780
Agency Contact
(Same as governor's office)
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VI. STATE
atacis rep:;5enc chose people ve Calked cc in gather!::* information for Che ::GA Toxic
egracion report and/or chose people who the Governor's office suggested should be on
.list. In most cases, names on the list represent both those we talked to and chose
;eocad by the Governor's office.)
.-..L-.3AMA
Mr. Ed Hudsrath
Liaison to Department of Energy
Office of the Governor
3724 Atlanta Highway
!!ontgcmery, Alabama 36130
(205) 332-5010
*r. "illiam I. Willis, Chief Engineer
Environmental Programs
Environmental Eealth Administration
Department of Public Health
Public Health Services Building
434 Monroe Street
Montgomery, Alabama 36130
(205) 332-3176
!£r. A.S. Chipley, Director
Solid & Hazardous Waste Division
3e?artment of Public Health
Public Health Services Building
434 Monroe Street
Montgomery, Alabama 36130
(205) 332-6728
Ur. Jimn Warr, Director
fater Improvement Commission
State Office Building
Ecntgcmery, Alabana 36130
(205) 277-3630
Mr. Glenn Akins, Director
Division of Environmental Quality
Management
DEC Pouch 0
Juneau, Alaska 99811
(907) 465-2640
Mr. Bob Martin, Chief
Water Quality Management Section
Division of Environmental Quality
Management
DEC Pouch 0
Juneau, Alaska 9S811
(907) 465-2644
AMERICAN SAMOA
Mr. Pati raiai
Special Assistant for Environmental Protec-
tion & Executive Secretary of the Environ-
mental Quality Commission
Office of the Governor
Pago Pago, American Samoa 96799
633-4116 (through operator)
Mr. Berger
Pesticides Officer
Department of Agriculture
Pago Pago, American Samoa 96799
ALASKA
2r. Allan Boggs
Environmental Engineer
Solid "aste "lanageaient
Department of Environmental
Conservation
Pouch Box 0
Juneau, Alaska 99811
(907) 465-2671
Hr. Ernst W. Mueller, Commissioner
Department of Environmental
Conservation
Pouch Box 0
Juneau, Alaska 99811
(907) 465-2600
ARIZONA
Mr. Andy Hurwitz
Chief of Staff
Office of the Governor
Phoenix, Arizona 85007
(602) 255-4331
Mr. Bill Williams, Manager
Hazardous Waste Section
Bureau of Waste Control
Department of Health Services
Phoenix, Arizona 85007
(602) 255-1160
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:ir. Jack Vaughn
-^izardous Materials Specialist
I-'.--: or Carrier Division
Arizona Corporation Coaaission
Phcenix, Arizona 85007
lbC-2) 255-3316
Mr. Eaory Vickers
Hazardous Materials Program Coordinator
Arizona State Division of Emergency
Services
Department of Emergency & Military
Affairs
Phoenix, Arizona 85008
(602) 273-9880
General Charles A. Ott, Jr., Director
Division of Emergency Services
5636 East McDowell Road
Phoenix, Arizona 85008
(602) 273-9880
ARKANSAS*
Mr. Walter Skelton
Administrative Assistant
Office of the Governor
Little Rock, Arkansas 72201
(501) 371-8040
Mr. Rob Middleton, Deputy Director
Department of Economic Development
ft"Capitol Hall
Little Rock, Arkansas 72201
(501) 371-2667
Dr. Phyllis Garaett
Technical Advisory Committee on
Hazardous Waste Management
State Capitol - Room 9
Little Rock, Arkansas 72201
(501) 371-1937
Mr. Buddy Parr, Chief
Solid Waste Management Division
Department of Pollution Control
& Ecology
8001 National Drive
Little Rock, Arkansas 72209
(501) 371-1135
CAL'IPORITIA*
Mr. Peter "."einer
Special Assistant Co the Governor for Tcxic
Substances Control
Office of the Governor
Sacramento, California
(916) 322-7691
Mr. Ken Finney
Assistant for Toxic Substances Control
Office of the Governor
Sacramento, California
(916) 322-7691
COLORADO*
Mr. Leonard Slosky
Assistant to the Governor for Science
Technology
Office of the Governor
State Capitol
Denver, Colorado 80203
C303) 866-2471
Dr. Robert Arnott, Assistant Director
for the Department of Health
Department of Health
Denver, Colorado 80220
(303) 320-8333
Mr. Robert Sullivan, Director
Plant Industry Division
Department of Agriculture
Denver, Colorado 80220
C303) 866-2839
Mr. Jeris Danielson
State Engineer
Division of Water Resources
Department of Natural Resources
Denver, Colorado 80220
(303) 866-3581
Mr. Cordell Smith, Director
Division of Highway Safety
Department of Highways
Denver, Colorado 80203
(303) 757-9381
*Todate, contacts have not been confirmed by the Governor's office.
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James I. Mar:-La, Ph.D., Chief
I-Iaca:dous i jjiid "astas Section
Ladi-iticr. a Hazardous Wastes Control
Division
Department of Health
Denver, Colorado 30220
(202) 220-3333
Mr. Joe Prevuznak
i Mr. Mike Hanley
Administrative Aides
Office of the Governor
Hartford, Connecticut 06115
(203) 566-4840
Mr. Steve Malish, Chief
Toxic Hazardous Section
Preventable Diseases Section
3ureau of Health Promotion & Disease
Prevention
Department of Health Services
Hartford, Connecticut 06115
(203) 566-8166
Dr. Steve Hitchcock, Director
Hazardous 'Taste Management Unit
Department of Environmental Protection
Hartford, Connecticut 06115
(203) 566-4924
Xr. Dick Touerville
Transportation Associate Engineer
Division of Traffic
Department of Transportation
Hartford, Connecticut 06115
(203) 273-9880
DELAWARE
Hr. David S. Swayze
Executive Assistant to the Governor
Office of the Governor
Dover, Delaware 19901
(302) 571-3210
Mr. Thomas P. Eichler, Director
Division of Environmental Control
Department of Natural Resources &
Environmental Control
Dover, Delaware 19901
(302) 736-4764
±:-~ Gillian C'sUjurke, Chairman
Transportation Hazardous .laterials
Department of Public Safety
Dover, Delaware 19901
(202) 736-4321
Mr. Robert J. Touhay, Manager
"7ater Resources Section
Division of Environmental Control
Department of Natural Resources &
Environmental Control
Dover, Delaware 19901
(302) 736-4761
Dr. Harry Otto, Manager
Technical Services Section
Department of Natural Resources &
Environmental Control
Dover, Delaware 19901
(302) .736-4771
Mr. Kenneth Weiss, Supervisor
Solid Waste Branch
Division of Environmental Control
Department of Natural Resources &
Environmental Control
Dover, Delaware 19901
(202) 736-4781
DISTRICT OF COLUMBIA
Mr. Ken Laden, Community Planner
Office of Environmental Planning & Management
D.C. Environmental Services
5010 Overlook Avenue, S.W. - Room 410
Washington, D.C. 20032
(202) 767-3181
Dr. Herbert ITood, Chief
Bureau of Occupational & Institutional Hygiene
D.C. Environmental Services
415 12th Street, H.W.
Washington, D.C. 20004
(202) 724-4358
Mr. Angelo Tompros, Chief
Division of Hazardous Chemicals
D.C. Environmental Services
415 12th Street, N.W.
Washington, D.C. 20004
(202) 724-4113
-289-
-------
Mr. V. Ramadass
Bureau cf Air i Water Quality
5010 Overlook Avenue, S.W.
Washington, D.C. 20032
(202) 767-7486
FLORIDA
Mr. Ken Woodburn, Coordinator
Natural .Resources Policy Unit
Executive Office of the Governor
Office of Planning & Budget
The Capitol
Tallahassee, Florida 32301
(904) 488-5551
Mr. Estus Whitfield
Senior Government Analyst
Executive Office of the Governor
Office of Planning & Budget
The Capitol
Tallahassee, Florida 32301
(904) 488-5551
Dr. James T. Hovell, M.D., H.R.H.
Public Health Officer
Department of Health & Rehabilition
Services
1323 Winevood Boulevard
Tallahassee, Florida 32301
(904) 487-2705
Mr. Bob Hawfield, Manager
Hazardous Waste Program
Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32301
(904) 488-0300
Ms. Judy Peckinpaugh
Planning Coordinator
Division of Disaster Preparedness
Department of Community Affairs
Capitol Office Plaza
1720 South Gadsden Street
Tallahassee, Florida 32301
(904) 488-1320
'Mri 3ill Lee
Hazardous Materials Coordinator
Division of Disaster Preparedness
Deparraent of Cooaunity Affairs
Capitol Office Plaza
1720 South Gadsden Street
Tallahassee, Florida 32301
(904) 488-1320
GUAM
Ms. Linda Segovia
Environmental Health Specialist
Division of Environmental Health
Department of Public Health & Social Services
Post Office Box 2816
Agana, Guam 96910
734-2671 (through operator)
GEORGIA
Mr. Gordon Harrison
Congressional Liaison for Natural Resources
& Economic Development
Office of the Governor
State Capitol
Atlanta, Georgia 30334
(404) 656-5767
Mr. Ernie Metivier
Economic Programs Manager
Physical & Economic Development
Office of Planning & Development
270 Washington Street, S, W.
Atlanta, Georgia 30334
(404) 656-3861
Mr. J. Leonard Ledbetter, Director
Environmental Protection Division
Department of Natural Resources
270 Washington Street, S.W.
Atlanta, Georgia 30334
(404) 656-4713
Mr. James L. Setser, Chief
Program Director
Environmental Protection Division
Department of Natural Resources
270 Washington Street, S.W.
Atlanta, Georgia 30334
(404) 656-3838
-290-
-------
Mr. Jim Morris, Chief of Operations
:ivil Defense Division
Department cf Defense
?cst Cffica 3o:c 13C55
Atlanta, Georgia 20315
(iOi) 556-5500
HAWAII
Mr. Francis Lua
Office of Che Governor
State Capitol
Honolulu, Hawaii 96313
(308) 548-5420
Mr. George Yuen
Director of Health.
Department of Health
Post Office Box 3373
Honolulu, Hawaii 96301
Mr. Paul Phillipson
Departaent of Transportation
79 Nemitz Highway
Honolulu, Hawaii 96313
Mr. Hal Barks
Department of Labor & Industrial
Relations
825 Mililani Street
Honolulu, Hawaii 96813
IDAHO
Mr. Paul Cunningham
Governor's Office
State House
Boise, Idaho 33720
(208) 334-2100
Mr. Lee Stokes, Administrator
Division of Environment
Idaho Departaent of Health & Welfare
State House
Boise, Idaho 83720
(208) 334-4054
Mr. Re iney Awe, Pesticide Supervisor
Deparr.rant of Agriculture
PCS: -ffice Box 790
3oisa, Idaho 33701
(208) 334-3244
Mr. San Netringa, Director
Department of Labor * Industrial Services
317 Main Street - Room 400
Boise, Idaho 83720
(208) 334-3950
Mr. Gary Gunnerson, Bureau Chief
Bureau of Motor Carrier Safety
Idaho Department of Law Enforcement
Post Office Bos 34
Boise, Idaho 83731
(203) 334-2130
ILLINOIS
Mr. Rich Carlson, Assistant to the
Governor for Energy & Natural Resources
Office of the Governor
State House
Springfield, Illinois 62706
(217^ 732-3212
Hr. David Schaeffer, Science Advisor
Division of Water Pollution Control
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
(217) 782-1554
Mr. Rama Chaturvedi
Illinois Environmental Protection Agency
Land/Noise Pollution Control Division
2200 Churchill Road
Springfield, Illinois 62706
(217) 782-6760
Mr. John Moore, Director
Land/Noise Pollution Control Division
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
(217) 782-6760
-291-
-------
ISDLAIiA*
Mr. Larry Kane, Chief
Permits & Applications Section
revision of Water Pollution Control
Indiana State Board of Health
1330 West Michigan Street
46206
(317) 633-0761
IOWA
Ilr. Elaer "Dutch" Vermeer
Acainistrative Assistant
State Capitol
Des Moines, Iowa 50319
(515) 281-3064
Mr. Charles C. Miller, Director
Air & Land Quality Division
Department of Environmental Quality
Henry A. Wallace Building
8900 East Grand
Des Moines, Iowa 50319
(515) 281-8853
Mr. Eon Kopla, Chief
Department of Environmental Quality
Henry A. Wallace Building
8900 East Grand
Des Moines, Iowa 50319
(515) 281-8925
Mr. Craig Swatzbaugh, Chief
Waste Water Operations Permit Section
Henry A. Wallace Building
8900 East Grand
Des Moines, Iowa 50319
(515) 281-8991
Mr. Jim Woll, Chief
Air Quality Planning
Air & Land Quality Management Division
Department of Environmental Quality
Henry A. Wallace Building
8900 East -Grand
Des Moines, Iowa 50319
(515) 281-3606
Mr. Jia Brown, Director
Water Quality Division
Department of Enviror.nen.eai Quality
Henry A. Wallace Building
8900 East Grand
Des Moines, Iowa 50319
(515) 281-3606
Mr. David Trott
Labor Safety Officer - Health
Bureau of Labor
307 East 7th Street
Des Moines, Iowa 50319
(515) 281-5797
Mr. M. R. Van Cleave, Supervisor
Pesticides Section
Iowa Department of Agriculture
Henry A. Wallace Building
8900 East Grand
Des Moines, Iowa 50319
(515) 281-8590
Mr. Dennis Ehlert, Director
Office of Safety Programs
Iowa Department of Transportation
Lucas State Office Building
Des Moines, Iowa 50319
(515) 281-5255
Mr. Pete Haniin, Director
Compliance Division
Department of Environmental Quality
Henry A. Wallace Building
8900 East Grand
Des Moines, Iowa 50319
C515) 281-8854
Mr. Henry Bocella
Plans & Preparedness Officer
Office of Disaster Services
Iowa Department of Public Defense
Hoover State Office Building - Level A-29
Des Moines, Iowa 50319
(515) 281-3231
Mr. Jack Gerlovich
Iowa Dept. of Public Instruction
Grimes State Office Building
Des Monies, Iowa 50319
(515) 281-3249
*Todate, contacts have not been confirmed by the Governor's office.
-292-
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Mr. 3ill Muir, Special
Assistant to the Governor
State Capitol - 2nd Floor
Topeka, Kansas 66612
(913) 296-3232
Mr. J. Howard Duncan, Director
Bureau of Environmental Sanitation
Department of Health & Environment
Forbes .Field
Topeka, Kansas 66620
(9l3) 862-9360 Ext. 290
lir. Dave Waldo, Chief
Enforcement Unit
Water Quality Division
Department of Health & Environment
Forbes Field
Topeka, Kansas 66620
(913) 296-9360
Mr. Howard Saiger, Director
Bureau of Air & Occupational Health
Department of Health & Environment
Forbes Field
Topeka, gangaa 66620
(9i3) 296-9360
Mr. John Irwin, Chief
Occupational Health Section
Department of Health & Environment
Forbes Field
Topeka, Kansas 66620
(913) 296-9360 Ext. 276
Mr. Dean Garwood, Director
Entymology Division
Plant Regulatory Office
Kansas State Board of Agriculture
901 Kansas Avenue
Topeka, Kansas 66612
(913) 296-3016
Mr. John Kemp, Secretary
Department of Transportation
State Office Building
Topeka, Kansas 66612
(913) 296-3461
Division of Z:;-ir
Pose Off-is 3~':
Tcpeka, I-C=r.si5
(913) 233-9253 Z
"-incy Pr
C-3GO
56501
t. 301
epareness
Mr. William Bryson
Spill Response Coordinator
Bureau of Oil Fields i Environmental Geclog;/
Department of Health S Environment
Forbes Field - Building 740
Tooeka, Kansas 66620
(913) 296-9360 E:ct. 22G
Mr. Rush W. Dosier
Attorney for the Governor
Office of the Governor
State Capitol
Frankfort,
(502) 554-2611
Xentuckv 40601
Ms. Carolyn Patrick Haight, Manager
Compliance Branch
Division of Hazardous Materials & Waste
Management
Department for Natural Resources &
Environmental Protection
Pine Kill Plaza
Frankfort, Kentucky 40601
(502) 564-6717
Mr. David Quarles
Emergency Response Coordinator
Division of Water Quality
Department for Natural Resources &
Environmental Protection
Pine Hill Plaza
Frankfort, Kenutcky 40601
(502) 564-3410
Mr. Bill Clements, Supervisor
Field Operations Branch
Division of Air Pollution Control
Department of Natural Resources &
Environmental Protection
West Frankfort Office Complex
1050 U.S. 125 South
Frankfort, Kentucky 40601
(502) 564-3560
-293-
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Mr. Thurson Measle, Coordinator
Structural Pest Control
Division cf Pesticides
Departaent of Agriculture
Pine Hill Plaza
Trankfort, Kentucky 40601
(502) 564-'274
Mr. Mike Ragland, Director
Occupational Health & Safety Program
Kentucky Department of Labor
U.S. 127 Building
Frankfort, Kentucky 40601
(502) 564-7360
Mr. Jin S. Runke, Commissioner
Bureau of Vehicle Registration
Department of Transportation
State Office Building
Frankfort, Kentucky 40601
(502) 564-4890
Mr. Charles Collier
Emergency Response Coordinator
Office of the Secretary
Departaent for Natural Resources &
Environmental Protection
Pine Hill Plaza
Frankfort, Kentucky 40601
(502) 564-3350
LOUISIANA
Mr. Billy Nungesser, Executive
Secretary & Chief Executive Assistant
Governor's Office
State Capitol
Bacon Rouge, Louisiana 70804
(504) 342-7015
Mr. Jim Porter, Secretary
Environmental Control Commission
Post Office Box 44066
Baton Rouge, Louisiana 70804
(504) 342-1266
Mr. George Fisher, Secretary.
Department of Health & Human Resources
Post Office Box 3776
Baton Rouge, Louisiana 70821
(504) 342-6711
Ms. Donna Irvin, Director
State Planning Office
Governor's Office
Post Office Box 44004
Baton Rouge, Louisiana 7CS04
(504) 925-4585
Mr. Gerald D. Healy, Jr., Administrator
Hazardous Waste Management Division
Office of Environmental Affairs
Department of Natural Resources
Post Office Box 44066
Baton Rouge, Louisiana 70804
(504) 342-1227
MAINE
Mr. David I. Flannagan
Legal Counsel
Office of the Governor
Augusta, Maine 04333
(207) 289-2811
Mr. Henry E. Warren, Commissioner
Department of Environmental Protection
State House
Augusta, Maine 04333
C207) 289-2811
Mr. John Brochu, Director
Bureau of Oil & Hazardous Materials Control
Department of Environmental Protection
State House
Augusta, Maine 04333
(207) 289-2251
Mr. Stuart Smith, Commissioner
Department of Agriculture
State House
Augusta, Maine 04333
(207) 289-3871
Mr. Donald Mairs, Director
Board of Pesticides Control
Department of Agriculture
Augusta, Maine 04333
(207) 289-2731
Mr. Donald Bissett
Fire Marshall's Office
Department of Public Safety
Augusta, Maine 04333
(207) 289-2481
-294-
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MARYLAND
Mr. Tchn Griffin
Executive Aide
State House
Annapolis, 'Maryland 21404
(301) 259-2804
Mr. William M. Eichbaum, Assistant
Secretary for Environmental Frograms
Department of Health & Mental Hygiene
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-7328
Or. Max Eisenberg, Special Assistant
for Environmental Health & Science
Office of Environmental Programs
Department of Health & Mental Hygiene
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-2740
Hr. Ronald Nelson, Acting Administrator
Waste Management Program
Office of Environmental Programs
Department of Health & Mental Hygiene
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-3123
MASSACHUSETTS
Mr. John Bewick, Secretary
Executive Office of Environmental
Affairs
100 Cambridge Street
Boston, Massachusetts 02202
(617) 727-9800
Mr. William Cass, Acting Director
Division of Hazardous Waste
Department of Environmental Quality
Engineering
Executive Office of Environmental
Affairs
Boston, Massachusetts 02202
(617) 727-0774
=Mr.- John Shcrtsleeves, Diractrr
Bureau of Industrial I-7ast.i
Deparz^ent of Environmental I^aagement
Executive Office of Environmental Affairs
Boston, Massachusetts 02292
(617) 727-4293
Mr. Anthony Correse, Commissioner
Department of Environmental Quality
Engineering
Executive Office of Environmental Affairs
Boston, Massachusetts 02202
(617) 727-2690
MICHIGAN
Mr. Don Unman, Special Assistant
to the Governor
State Capitol - Room 1
Lansing, Michigan 48909
C517) 373-3427
Mr. Andy Hogarth, Chief
Michigan Department of Natural Resources
Groundwater Compliance & Special Studies
Section
Post Office Box 30028
Lansing, Michigan 48909
(517) 373-8147
Mr. Rich Powers
Michigan Department of Natural Resources
Office of Toxic Materials Control
Post Office Box 30028
Lansing, Michigan 48909
(517) 374-9640
MINNESOTA
Mr. Kermit McCray
Office of the Governor
State Cap'itol
St. Paul, Minnesota 55155
(612) 296-2287
Mr. Dale Wikre, Director
Solid Waste Division
Minnesota Pollution Control Agency
1935 West County Road, B-2
Roseville, Minnesota 55113
(612) 297-2735
-295-
-------
Mr. :^rvis Hc.ra
Uaiar "'jaliv' Division
Icxic iuastaniis i Priaary Monitoring
Jaic
Xisnesata Pollution Control Agency
1935 West County Road, B-2
Roseville, Minnesota 55113
(612) 296-7396
MISSISSIPPI
Mr. Charles Deaton
Administrative Assistant
Governor's Office
Post Office Box 139
Jackson, Mississippi 39205
(601) 354-7575
Mr. Jack McMillan, Director
Solid Waste Management Division
Bureau of Environmental Health.
State Board of Health
Post Office Box 1700
Jackson, Mississippi 39205
(601) 982-6317
Mr. Joe Brown, P.E., Chief
Bureau of Environmental Health
State Board of Health
Post Office Box 1700
Jackson, Mississippi 39205
(601) 354-6616
Mr. Jack Coley
State Entomologist
Division of Plant Industry
Department of Agriculture & Commerce
Post Office Box 5027
Mississippi State University
Starfcville, Mississippi 39762
(601) 325-3390
Col. Charles Blalock
Executive Director
Department of Hatural Resources
Post Office Box 20305
Jackson, Mississippi 39209
(601) 961-5000
Mr. Janes E. Maher, Director
Emergency Jfanagesetii
Mississippi Emergency Management Agency
Post Office Box 45C1 - Fondren Station
Jackson. Mississippi 39256
C601) 354-7201
Mr. Michael Hughes, Coordinator
UMC Poison Services
2500 North State Street
Jackson, Mississippi 39216
C601) 354-7660/987-3500
MISSOURI*
Ms. Carolyn Ashford
Office of the Governor
State Capitol
Jefferson City, Missouri 65101
(314) 751-3222
Mr. Robert Robinson, Director
Solid Waste Management Program
Post Office Box 1368
Jefferson City, Missouri 65102
C314) 751-3241
Dr. Denny DonnellT~Director
Disease Prevention Section
Division of Health
Department of Social Services
Broadway State Office Building
Post Office Box 570
Jefferson City, Missouri 65102
C314) 751-2713 Ext. 286
*Todate, contacts have not been confirmed by the Governor's office.
-296-
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80NTANA
ir^:i Mueller,
ifritive Assistant
Cffici of the Governor
icace Capitol
Helena, Montana 59601
(406) 449-3111
Xr. Don Willems, Administrator
Environmental Sciences Division
Department of Health & Environmental
Sciences
Cogswell Building
Selena, Montana 59601
(406) 449-3946
Sr. Roger Taovbilson
Solid Waste Management Bureau
Department of Health & Environmental
Sciences
Cogswell Building
Helena, Montana 59601
(406) 449-3671
Mr. Steve Pilcher, Chief
fater Quality Bureau
Environmental Sciences Division
Department of Health & Environmental
Sciences
Cogswell Building - Room A206
Helena, Montana 59601
(406) 449-2407
Mr. Larry LL&yd, Chief
Occupational Health Bureau
Department of Health & Environmental
Sciences
Cogswell Building
Helena, Montana 59601
X406) 449-3671
Dr. Martin Sk: :»er, Chief
Preventive Health Services Bureau
Department of Health & Environmental
Sciences
Cogswell Building
Helena, Montana 59601
(406) 449-2645
ilr.. Dave Bur che tt, Chief
Enforcement Bureau
Transportation Div_;ion
Public Service Comiosion
1227 llth Avenue
Helena, Montana 59601
(406) 449-3009
Mr. Robert LaRue
Field Services Bureau Chief
Environmental Management Divisic:
Department of Agriculture
Agriculture Livestock Building
Capitol Cooplex
Helena, Montana 59601
(406) 449-2944
NEBRASKA
Ms. Karen Langland
Natural Resources & Agriculture Coordinator
State Policy Research Office
Post Office Box 94501
Lincoln, Nebraska 68509
C402) 471-2414
Mr. Bob Wall, Chief
Water & Waste Management Division
Department of Environmental Control
301 Centennial Mall South
Lincoln, Nebraska 63509
NEVADA
Mr. Bill Philips
Executive Assistant
Office of the Governor
Carson City, Nevada 39710
(.702) 885-5670
Mr. Verne Rosse
Waste Management Project Director
Division of Environmental Protection
Department of Conservation & Natural
Resources
Carson City, Nevada 89710
(702) 885-4670
-297-
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>:r. James Hannah, Executive Secretary
I^-.-.racnenral Conmissioa
Serarrsent of Conservation & Natural
Resources
Carson City, Sevada 89710
(702) 385-5355
HAMPSHIRE
Mr. Michael Dotxahue, Director
Municipal Services
(hazardrus waste coordinator)
Waste Supply & Pollution Control Commission
Post Office Box 95
Concord, New Hampshire 03301
C603) 271-3289
Mr. Stephen Leavenworth, Chief
Division of Water Supply
Water Supply & Pollution Control Commission
Post Office Box 95
Concord, New Hampshire 03301
(603) 271-3139
Mr. Russel Nylander, Assistant
Chief Engineer/Administrator
Water Supply & Pollution Control Commission
Hazen Drive
Concord, New Hampshire 03301
(603) 271-3440
lir. Ron'Poltak, Executive Director
(advisor to the Governor on hazardous
waste)
Office of State Planning
2% Beacon Street
Concord, New Hampshire 03301
(603) 271-2155
Mr. Earl Sweeney, Deputy
Ccmsissioner of Safety
Department of Safety
Concord, New Hampshire 03301
(603) 271-2559
Mr. Dennis Lunderville, Director
Air Resources Agency
Hazen Drive
Concord, New Hampshire 03301
(603) 271-4580
Mr. Murray L. McKay
Pesticide Control Supervisor
Pesticide Control Division
Departaent of Agriculture
85 Manchester Street
Concord, New Hampshire 03301
(603) 271-3550
Dr. Maynard H. Mires, M.D., Director
Division of Public Health Services
Departaent of Health & Welfare
Hazen Drive
Concord, New Hampshire 03301
(603) 271-4500
Mr. Thomas Sweeney, Chief
Bureau of Solid Waste Management
Division of Public Health Services
Department of Health & Welfare
Hazen Drive
Concord, New Hampshire 03301
(603) 271-4609
*Todate, contacts have not been confirmed by the Governor*s office.
HEW JERSEY*
1-Ir. Jeffrey Light, Assistant
Counsel to the Governor
Governor's Counsel's Office
State House
West State Street
Trenton, New Jersey. 08625
C609) 292-7400
Mr. Paul Giardino, Director
Hazards Management Program
Deparoaent of Environmental Protection
John Fitch Plaza
Labor & Industry Building - Room 805
Trenton, New Jersey 08625
C609) 292-6028
Ms. Judy Louis, Research Scientist
Office of Cancer & Toxic Substances Research
Department of Environmental Protection
190 West State Street
Trenton, New Jersey 08625
(609) 984-6070
-298-
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SEW :EXICO
Dr. George S. Goliscein, Secretary
Department of Health & Environment
Post Office Boat 968
Santa Fe, New Mexico 87501
(505) 827-5671
Mr. Thomas E. 3aca, Director
Environmental Improvement Division
Department of Health & Environment
Post Office Box 968
Santa Fe, New Mexico 87501
(505) 827-5271
Mr. Raymond Krehoff, Program Manage
Physical Environmental Manageaent
Section
Environmental Improvement Division
Department of Health & Environment
Post Office Sox 968
Santa Fe, New Mexico 87501
(505) 827-5271
Ms. Lee Lockey, Chief
Air Quality Bureau
Environmental Improvement Division
Department of Health & Environment
Post Office Box 968
Santa Fe, New Mexico 87501
(505) 827-5271 Ext. 370
Hr. Joseph Pierce, Chief
Water Pollution Control Bureau
Environment Improvement Division
Department of Health & Environment
Post Office Box 968
Santa Fe, New Mexico 87501
(505) 827-5271 Ext. 232
Mr. Michael Curtis, Chief
Occupational Health & Safety Bureau
Department of Health & Environment
Post Office Box 968
Santa Fe, New Mexico 87501
(505) 827-5271 Ext. 250
Mr. Lonni Mathews, Assistant Chief
Division of Pesticide Management
Department of Agriculture
Post Office Box 3AQ
Las Cruces, New Mexico 88003
(505) 646-2133
.\-. Vincient Gutierrez
Motrr Transportation Division
Department of Transportation
Post Office Box 1028
Santa Fe, New Mexico 37503
(505) 827-2063
Mr. Don Naylor
State Fire Marshall's Office
Post Office Drawer 1269
Santa Fe, New Mexico 87501
(505) 827-2357
NEW YORK*
Mr. Frank Murray, Program Associate
State Capitol - Room 227
Albany, New York 12224
(518) 474-1288
Mr. Bob Collin, Chief
Toxic Substances Control Unit
Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
(518) 457-2462
Mr. Paul Sausville, Chief
Northeast Planning Section
Department of Environmental Conservation
50 Wolf Road - Room 416
Albany, New York 12233
(518) 457-2672
NORTH CAROLINA
Dr. Quentin Lindsey
Science & Policy Advisor
Office of the Governor
116 West Jones Street
Raleigh, North Carolina 27611
(919) 733-6500
Dr. Donald Huisingh
Toxic Substances Project Leader
16 West Martin Street - Suite 810
Raleigh, North Carolina
(9191 733-2770
*7odate, contacts have not been confirmed by the Governor's office.
-299-
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Dr. Neil Grigg, Assistant
Secretary for Natural Resources
Department of Natural Resources i
Coonunity Development
Post Office Box 27687
Raleigh, North Carolina 27611
(919) 733r4006
Dr. Hugh Tilson, Director
Division of Health Services
Department of Human Resources
Cooper Health Building
225 North McDowell Street
Raleigh, North Carolina 27602
(919) 733-3*46
Mr. 0. W. Strickland, Head
Solid & Hazardous Waste Management
Branch
Environmental Health Section,
Division of Health Services
Department of Human Resources
306 North Wilmington Street
Post Office Box 2091
Raleigh, North Carolina 27602
(919) 733-2178
Ms. Lucy Bode, Chief Assistant
to the Secretary
Department of H*WOT Resources
325 North Salisbury Street
Raleigh, North Carolina 27611
(919) 733-4534
Dr. Bernard Greenberg, Chairman
School of Public Health
Rosenau Hall, Room 201H
University of North Carolina
Chapel Hill, North Carolina 27514
(919) 966-4152
Mr. Arnold Zogry, Assistant Secretary
for Policy & Management
Division of Administration
116 West Jones Street
Raleigh, North Carolina 27611
(919) 733-4131
"r. David Kelly, Assistant Secretary
for Public Safety
Department of Crine Control i Public Safery
Post Office Box 27637
Raleigh, North Carolina 27611
C919) 733-2126
Mr. 5. Ray Forrest, Director
Office of Resources Planning & Development
Department of Agriculture
Post Office Box 27647
Raleigh, North Carolina 27611
(919) 733-6248
Mr. James B, Howard, Assistant Director
Occupational Safety & Health Administration
Department of Labor
4 West Edenton Street
Raleigh, North Carolina 27610
C919) 733-4880
Mr. M.C. "Bob" Adaas, Manager
Maintenance & Equipment Branch
Department of Transportation
Highway Building
Raleigh, North Carolina 27611
C919) 733-2330
NORTH DAKOTA
(List of contacts not available as yet)
NORTHERN MARIANA ISLANDS
(List of contacts not available as yet)
OHIO
Mr. Edward Glod
Hazardous Waste Coordinator
Ohio Environmental Protection Agency
361 East Broad Street
Columbus, Ohio 43216
(614) 466-8934
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C.
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*ir. -lirliton Maine, Assistant Director
of Er.'Tircnnetital Mscagesent
Depar~=er.: of Environmental Management
Cannon Health Building - Room 209
Davis Street
Providence, Bhode Island 02908
(401) 277-2234
Mr. Thomas Wright, Chief
Air & Hazardous Materials Division
Department of Environmental Management
Cannon Health Building - Room 204
Davis Street
Providence, Rhode Island 02908
(401) 277-2808
Mr. David Hartley
Senior Plant Pathologist
Division of Agriculture
Department of Environmental Management
83 Park Street
Providence, Bhode Island 02903
(401) 277-2781
Mr. James Hickey, Chief
Division of Occupational Health
i Radiation Control
Department of Health
Cannon Health Building Room 206
Providence, Rhode Island 02908
(401) 277-2438
Mr. John Hagopian, Chief
Division of Water Supply
Department of Health
Davis Street
Providence, Bhode Island 02908
(401) 277-6867
Mr. Wendall Flanders, Director
Department of Transportation
210 State Office Building
Providence, Rhode Island 02903
(401) 277-2481
PUE5SO P.ICO
Mr. Frederick E. Sushford
Federal Programs Officer
Office of the Governor
La Fortaleza
San Juan, Puerto Rico 00901
(809) 724-7900
Mr. Eugenio H. Fontanes, President
Puerto Rico Industrial Development Co.
Post Office Box 2350
San Juan, Puerto Rico 00936
(809) 767-4747
Mr. Heriberto J. Martinez Torres
Secretary of Agriculture
Department of Agriculture
Post Office Box 10163
Santurce, Puerto Rico 00908
C809) 722-0871/722-0291
Mr. Pedro A. Gelabert, President
Environmental Quality Board
Post Office Box 11488
Santurce, Puerto Rico 00910
(809) 725-8898
Mr. Santos Rohena, Jr., Associate Director
Environmental Quality Board
Post Office Box 11488
Santurce, Puerto Rico 00910
(809) 725-2062
Ms. Luisa Cerar
Puerto Rico Federal Affairs Administration
Washington Office
724 15th Street, N,W.
Washington, D.C. 20005
(202) 383-1300
SOUTH CAROLINA
Ms. Patricia Jerman
Coastal Energy Impact Program Coordinator
Governor's Office
Division of "Natural Resources
1205 Pendleton Street - Room 304
Columbia, South Carolina 29201
(803) 758-8808
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Mr. Eartsiil Truesdale, Director
Solid i Hazardous Waste Managesent
Division
Department of Environmental Control
Department of Health & Environmental
Control
:500 Buss Street
Columbia, South Carolina 29201
C303) 758-5681
SOUTH DAKOTA.
(List of contacts not available as
yet)
TENNESSEE
Mr. Keel Hunt, Special Assistant
to the Governor
Governor's Office
State Capitol
Nashville, Tennessee 37219
(615) 741-3621
Mr. Robert Wolle, Deputy
Commission for the Environment
Department of Public Health
"Bureau of Environmental Health
Administration
349 CordeU Hall Building
Nashville, Tennessee 37219
(615) 741-3657
Jfr. Christopher Boven
Export Marketing Consultant
Office of Export Trade Promotion
Economic & Community Development
Adminis tration
1018 Andrew Jackson Building
Nashville, Tennessee 37217
(615) 741-2974
Mr. Andrew Rymer, Director
Transportation Rate Division
Tennessee Public Service Commission
349 Cordell Hall Building
Nashville, Tennessee 37219
(615) 741-2974
Col..W,S. Wallick, Deputy Director
for Resources
Ilvision of Civil Defense & Energency
Preparedness
Eaergency Operations Center
Department of Military Affairs
National Guard Armory
Sidca Drive
Nashville, Tennessee 37204
(615) 741-5181
TEXAS
Mr. Mit Spears, Special Assistant
Governor's Budget & Planning Office
Sam Houston Building - Suite 700
Post Office Box 12428 - Capital Station
Austin, Texas 78711
(512) 475-2427
Mr. Robert Fleming, Executive Assistant
Department of Water Resources
Post Office Sox 13087 - Capital Station
Austin, Texas 78711
(512) 475-3137
Mr. Charles Mueller, General Counsel
Texas Energy & Natural Resources Council
200 East 18th Street - Suite 502
Austin, Texas 78711
(512) 475-0314
Mr. Jack Carmichael, Director
Division of Solid Waste Management
Texas Department of Health
1100 West 49th Street
Austin, Texas 78756
(512) 458-7111
Mr. Dick Whittington, Deputy Director
Department of Water Resources
Post Office Box 13087 - Capital Station
Austin, Texas 78711
(512) 475-3761
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UTAH
Dr. Janes tf. Bunger
Scats Science Advisor
Cffica of State Planning
Coordinator
State Capitol Building
Boom 104
Salt Lake City, Utah 84114
(801) 533-4987
Dr. Dale D. Parker, Director
Bureau of Solid Waste Management
Division of Environmental Health
150 West North Tenple
Post Office Box 2500
Salt Lake City, Utah 84110
(801) 533-4145
Mr. Kent P. Gray, Section Chief
Hazardous Waste Management
Division of Environmental Health
Utah Department of Health
Post Office Box 2500
Salt Lake City, Utah 84110
(801) 533-4145
Mr. Larry F. Anderson, Director
Bureau of Radiation & Occupational
Health
Utah Department of Health
Post Office Box 2500
Salt Lake City, Utah 84110
(801) 533-6734
Mr. Ray J. Downs, Director
Division of Plant Industry
Utah Department of Agriculture
147 North 200 West
Salt Lake City, Utah 84103
(801) 533-4107
Mr. LeGrand 0. Jones
Safety Regulations Administrator
Division of Safety
Utah Department of Transportation
748 West 300 South
Salt Lake City, Utah 84104
(801) 533-5201
Ms. Lorayne Tecpest, Director
Division of Cosorehensive Emergency Servic
Department of Public Safety
1543 Sunnside Avenue
Salt Lake City, Utah 84108
C801) 533-5933
VEEMOHT
Ms. Nancy Knox, Special Assistant
to the Governor
Office of the Governor
Montpelier, Vermont 05602
(802) 828-3333
Mr. John Halter, Chief
Hazardous Materials Management Section
Department of tfater Resources & Environ-
mental Engineering
Agency of Environmental Conservation
Montpelier, Vermont 05602
(802) 828-3395
Mr. Harold Garabedian
Chief Air Pollution Control Engineer
Air & Solid Waste Program
Agency of Environmental Conservation
State Office Building
Montpelier, Vermont 05602
(802) 828-3395
Mr. David Clugh, Director
Water Quality Division
Department of Water Resources & Environ-
mental Engineering
Agency of Environmental Conservation
State Office Building
Montpelier, Vermont 05602
(802) 838-2761
Mr. Mars Longley, Director
Division of Occupational & Radiological
Health
Department of Health
10 Baldwin Street
Montpelier, Vermont 05602
(802) 828-2886
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Mr. Kenneth Scene, Director
60 Main Street
Burlins-cn, Vermont 05401
(302) b2-5701 Ext. 256
Mr. Philip Benedict, Director
Plant Industry Division
Department of Agriculture
State Office Building
Montpelier, Vermont 05602
(302) 823-2431
Mr. George Combes
Transportation Research Specialist
Division of Operations
Agency of Transportation
113 State Street
Montpelier, Vermont 05602
(302) 828- 2828
VIRGIN ISLANDS*
Mr. Donald C. Francois, Acting Director
Natural Resources Management
Department of Conservation & Cultural
Affairs
Post Office Box 4340
St. Thomas, Virgin Islands 00801
(809) 774-6420
VIRGINIA
Ms. Joy Hanson
Executive Assistant
Governor's Office
Richmond, Virginia 23219
(304) 786-2211
Dr. John Hilckfin, Director
Bureau of Toxic Substances
Department of Health
Richmond, Virginia 23219
(804) 786-1763
'!r. 3.H. South all, Director
Division of Prrd^ct & Industry P.eguis tian
Department of .-.gxiculcura i Consumer services
203 North Governor Street
Richmond, Virginia 23219
(804)786-3523
Mr. William R. Moyer, Executive Director
State Air Pollution Control Board
1106 Ninth Street Office Building
Richmond, Virginia 23219
(804) 786-2378
Mr. Danny Brown, Commissioner
Division of Mined Land Reclamation
Post Office Drawer U
Big Stone Gap, Virginia 24219
(703) 523-2925
Mr. Charles W. Ramsey
Hazardous Materials Officer
Office of Emergency & Energy Services
310 Turner Road
Richmond, Virginia 23225
(804) 272-1441
Dr. Robert B. Stroube, M.D.
Assistant Health Commissioner
State Health Department
109 Governor Street
Richmond, Virginia 23219
C804) 786-4265
Mr. Robert Beard, Jr., Commissioner
Department of Labor & Industry
205 North Fourth Street
Richmond, Virginia 23219
C804) 786-2376
Mr. R.V. Davis, Executive Director
State Water Control Board
2111 North Hamilton Street
Richmond, Virginia 23250
(804) 257-6384
~
r?/
*Todate, contacts have not been confirmed by the Governor's office.
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Mr. Dave Stevens
Assistant for Natural Resources
Office of the Governor
Scats Capitol
Olynpia, Washington, 98504
(206) 753-6780
Mr. Tom Cook., Head
Hazardous Waste Section
Department of Ecology
Sc. Martin's Campus
Rowesix; Mail Stop F711
Olynpia, Washington 98504
(206) 753-4276
ilr. Glen Fiedler, Acting
Assistant Director
Office of Water Programs
Department of Ecology
Olynpia, Washington 98504
(206) 753-3893
Mr. Henry Droege, Supervisor
Air Resources Management Division
Department of Ecology
Olympia, Washington 98504
(206) 753- 2822
Mr. Stephen M. Cant
Chief Industrial Hygenist
Division of Industrial Safety
& Health
Department of Labor & Industries
Post Office Box 297
Olympia, Washington 98504
(206) 753-6497
Mr. Terry Strong, Head
Radiation Control Section
Department of Social & Health Servcies
Olympia, Washington 98504
(206) 753-3469
Mr. Art Losey, Assistant Director
Grain & Chemical Division
Department of Agriculture
406 General Administration Building
Olympia, Washington 98504
(206) 753-5062
Mr. Lee Kagley, Assistant Administrator
of Transportation
Transportation Division
Department of Utilities & Transportation
Highway License Building
12th & Franklin Streets
Olympia, Washington 98504
(206) 753-6065
Mr. Kenneth Solt, Division Manager
Administrative Services
Department of Natural Resources
Olympia, Washington 98504
(206) 753-5310
WEST VIRGINIA
Mr. James Maddy, Special Assistant
to the Governor
State Capitol
Charleston, West Virginia 25305
(304) 348-0410
Mr. Harley Mooney
State Police Chief
Department of Public Safety
Charleston, West Virginia 25305
(304) 348-2355
Mr. Dale Parsons, Director
Solid Waste Disposal Planning
Department of Health
1800 Washington Street East
Charleston, West Virginia 25305
(304) 348-2987
Mr. David Robinson, Chief
Water Resources Division
Department of Natural Resources
Charleston, West Virginia 25305
(304) 348-2107
Mr. Bill Aaroe, Director
Industrial Hygiene Division
Department of Health
151 llth Avenue
South Charleston, West Virginia 25303
(304) 348-3526
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Mr. John. Northeiaer
Department of Natural Resources
"."acer Resources Division
1191 Greenfarier Scresc
Charleston, Wast Virginia 25311
(204) 348-5935
WISCONSIN*
lit. Mark Popovich
Office of the Governor
State Capitol
Madison, 'Wisconsin 53702
(608) 266-1212
Mr. Renato Millan
Environmental Engineer
Department of Natural Resources
Post Office Box 7921
Madison, Wisconsin 53707
(608) 266-3084
Mr. Scanton Kleineff, Chief
Pre-Treataenc. & Fees Section
Division of Environmental Standards
Departaent of Natural Resources
Madison, Wisconsin 53707
(608) 266-7721
Mr. Tom Sheffy
Surveillance Chemist
Bureau of Water Quality
Department of Natural Resources
Post Office Box 7921
Madison, Wisconsin 53707
(608) 266-9265
Mr. Don Theiler, Director
Bureau of Air Management
Division of Environmental Standards
Department of Natural Resources
Post Office Box 7921
Madison, Wisconsin 53707
(608) 266-5603
Ms. Kay Dally
Department of Health & Social Services
Division of Health
Bureau of Prevention
Section of Environmental Epidemiology
Post Office Box 309
Madison, Wisconsin 53701
(608) 266-9711
Mr. Med Zuelsdorff
Wisconsin Deparrrsnt of Agriculture
Plant Industry Division
301 "est Badger Road
Madison, Wisconsin 537C8
C603) 256-7135
Mr. Den Sano, Supervisor 11
Regulation Ccspliance Investigation
Inspection Bureau
Wisconsin Departaent of Transportation
Post Office 3ox 7912
Madison, Wisconsin 53707
(608) 266-0274
Mr. Harold Hettrick, Head
Law Enforcement
Division of Saergency Government
Departaent of Local Affairs & Development
4802 Sheboygan Avenue - Roon 99A
Madison, Wisconsin 53707
(608) 266-1369
WYOMING
Mr. C. Richard Skinner
Administrative Assistant
Governor's Office
State Capitol
Cheyenne, Wyoming 82002
C307) 777-7434
Mr. Dave Finley, Engineer
Solid Waste Management Division
Departaent of Environmental Quality
Hathaway Building
Cheyenne, Wyoming 82002
(307) 777-7752
Mr. Leroy Feusner, Response Supervisor
Oil & Hazardous Substances Program
Water Quality Division
Department of Environmental Quality
401 West 19th Street
Cheyenne, Wyoming 32002
C307) 777-7781
*Todate, contacts have not been confirmed by the Governor's office.
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Mr. Randolph Uood, Administrator
Air Quality Division
wepartsent of Environmental Quality
-01 Kest 19th Street
Cheyenne, Uyoming 82002
(307) 777-7391
Mr. Nora French.
Training, Education & Public
Information Officer
Office of Disaster & Civil Defense,:
Post Office Box 1709
5500 Bishop Boulevard
Cheyenne, Wyoming 82002
(307) 777-7566
Mr. Bill Eaton
Pesticides Specialist
Consumer Compliance Division
Hvoning Department of Agriculture
2219 Carey Street
Cheyenne, Wyoming 82002
(307) 777-7231
Mr. Don Owsley, Administrator
Occupational Safety & Health Program
Wyoming Department of Safety & Health
200 East 8th Avenue
Cheyenne, Wyoming 82002
(307) 777-7786
Lt. Brent Taylor
Motor Carrier Office
Highway Patrol
Post Office Box 1708
Cheyenne, Wyoming 82001
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