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:
                                     -1-

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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.
                                      -2-

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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);
                                     -3-

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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;
                                    -5-

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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.
                                  -6-

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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:
                                           -7-

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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.
                                      -8-

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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;
                                      -9-

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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
                                          -10-

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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 in•enforcement 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
                                         -11-

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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
                                       -12-

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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.
                                       -13-

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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.
                                       -14-

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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
                                       -15-

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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.
                                     -16-

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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.
                                     -17-

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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;
                                      -18-

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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


                                     -19-

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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.
                                     -20-

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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.

                                    -21-

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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,
                                     -22-

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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.






                                     -23-

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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.
                                    -24-

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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.


                                    -25-

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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
                                    -26-

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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.
                                    -27-

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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.
                                    -28-

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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;
                                    -29-

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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
                                    -30-

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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
                                    -31-

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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.
                                     -32-

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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
                                    -33-

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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.
                                     -34-

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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,
                                       -35-

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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.
                                       -36-

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       INFORMATION PROCESSING SYSTEMS^
               Environmental Safety
             ENT FUNCTIONS
                       ^

                   °*    '
                  PLANNING
                                                              ° Stud •
                                                                   ^
                                                              --->...---  Resccr.se Tssr:-
                             GATHEMSG
 CffW    •
OATIO.
oduction
   -GOVERNOR'S OFFICE LEADERSHIP
Investigation  •

      WHAT'S  INVOLVED  IN

  V^'     INTEGRATH)
      'TOXICS MANA6EP1ENT
                Environmental Epidemiology
                                                               **
       PRODUCTS
                    Chlorine
                                                              6>
,«siiies


                                          REPROCESSING
J5IVT??
            Defoliants
                                              -37-


                                                                          *

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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.
                                    -38-

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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
                                     -39-

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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
                                    -40-

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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
                                     -41-

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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
                                      -42-

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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.


                                     -44-

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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.
                                -46-

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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,
                                      -48-

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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
                                     -49-

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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.





                                      -51-

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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
                                     -52-

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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.
                                      -53-

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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
                                      -55-

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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-

-------
   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) .
                                       -59-

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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.
                                      -60-

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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
                                      -62-

-------
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-

-------
         • 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.
                                     -64-

-------
      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,
                                     -67-

-------
            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
                                     -68-

-------
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
                                     -69-

-------
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
                                     -70-

-------
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
                                      -71-

-------
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
                                     -72-

-------
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
                                     -73-

-------
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
                                     -74-

-------
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
                                    -75-

-------
 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; %
                                     -76-

-------
     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
                                    -77-

-------
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.
                                    -78-

-------
     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.
                                      -79-

-------
     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;
                                    -80-

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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.
                                    -81-

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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
                                     -82-

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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
                                    -83-

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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;
                                     -84-

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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)
                                    -85-

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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
                                    -86-

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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.
                                    -87-

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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:
                                    -88-

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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);
                            -89-

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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);
                              -90-

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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
                                   -91-

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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.
                                    -92-

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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
                                   -93-

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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;
                                    -94-

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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.
                                   -95-

-------
     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
                                   -96-

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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,
                                   -97-

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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
                                    -98-

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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
                                    -99-

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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.
                                   -100-

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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.
                                   -101-

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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;
                                   -102-

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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
                                   -103-

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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
                                   -104-

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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
                                   -105-

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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
                                    -106-

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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.
                                   -107-

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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
                                   -108-

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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,
                                   -109-

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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;
                                   -110-

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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;
                                     -111-

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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
                                   -112-

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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.
                                   -113-

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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);
                                   -114-

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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;
                                   -115-

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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;
                                   -116-

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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:
                                   -117-

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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;
                                   -118-

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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
                                   -119-

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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
                                   -120-

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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
                                   -121-

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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
                                   -122-

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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.
                                    -123-

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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
                                   -125-

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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.
                                   -126-

-------
     "-• '-:.: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
                                   -127-

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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.
                                   -128-

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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,
                                   -129-

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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.
                                   -130-

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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.
                                   -131-

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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;
                                   -132-

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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;
                                   -133-

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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
                                     -134-

-------
 --_:-': 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.,
                                    -135-

-------
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, long—range 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
                                    -136-

-------
 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.
                                    -137-

-------
     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
                                   -138-

-------
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
                                   -139-

-------
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
                                   -140-

-------
     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
                                   -141

-------
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.
                                   -142-

-------
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
                                    -143-

-------
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.
                                    -144-

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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.
                                   -145-

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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
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I
X

X
D




X
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X
1)
Assessment of Economic Impact
D

X
—

D

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—
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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
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X
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Resource Sharing
P
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TION
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X
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Consolidated Permit Process
P

I
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—

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
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X
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X
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X
Chemical Data Registry /Resource Center |
P
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Agency/Cons&ittee Annual Reporting Requirement ]








X

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| Agency Management Inventory/ Directory


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X
OTHER TOXIC}} STATE ACTJVJTI1S
Health Effects Studies/Monitoring


X
X
X
X
X
X
X
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| Development of Scientific Testing Procedures |


D


X
X

X
D
| Development of Chemical Use Standards |

—
X



P
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X
X
X

X

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X
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X
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X
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( Public I •_£ or=ation/?2rticipatios i

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X
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-------
         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.
                                   -147-

-------
     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.
                                   -148-

-------
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
                                   -149-

-------
 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
                                   -150-

-------
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
                                   -151-

-------
     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
                                   -152-

-------
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.
                                    -153-

-------
     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.
                                    -155-

-------
     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;
                                   -156-

-------
     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)
                                   -157-

-------
                                   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.
                                   -158-

-------
     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;
                                    -159-

-------
      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.
                                   -160-

-------
     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.
                                    -161-

-------
     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
                                   -162-

-------
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
                                   -163-

-------
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 '
                                   -164-

-------
                                   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.
                                    -165-

-------
     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.
                                   -166-

-------
     ":e chrust :f che program is 
-------
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
                                   -168-

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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
                                   -169-

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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
                                   -170-

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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
                                   -171-

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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
                                   -172-

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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.
                                   -173-

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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
                                   -174-

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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
                                   -175-

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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 .
                                    -176-

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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
                                   -177-

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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:
                                   -178-

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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.
                                    -180-

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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
                                      -181-

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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
                                    -182-

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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
                                    -183-

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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.
                                    -184-

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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
                                     -185-

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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, low—level 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.
                                    -186-

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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:
                                    -187-

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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
                                    -188-

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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
                                    -189-

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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
                                     -190-

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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;
                                    -191-

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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
                                    -192-

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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.
                                    -193-

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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:
                                    -194-

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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 .
                                    -195-

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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
                                   -196-

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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.
                                   -197-

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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
                                    -198-

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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
                                    -199-

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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:
                                   -200-

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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.
                                   -201-

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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
                                   -202-

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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;
                                   -203-

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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;


                                   -204-

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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
                                   -205-

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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.
                                   -206-

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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
                                   -207-

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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
                                   -208-

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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;
                                     -209-

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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
                                   -210-

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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
                                    -211-

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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;
                                   -212-

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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."
                                    -213-

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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
                                   -214-

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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
                                   -215-

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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
                                   -216-

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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
                                   -217-

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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
                                   -218-

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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;
                                    -219-

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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,
                                    -220-

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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.
                                    -221-

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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
                                   -222-

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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
                                   -223-

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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
                                   -224-

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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;
                                   -225-

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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 on—site 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.
                               -226-

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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
                                   -227-

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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.
                                   -228-

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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
                                   -229-

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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.
                                   -230-

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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
                                    -231-

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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.
                                   -232-

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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
                                    -267-

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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
                                   -268-

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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.
                                   -269-

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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
                                    -270-

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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.
                                    -271-

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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.
                                   -272-

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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.
                                   -273-

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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
                                   -274-

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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.
                                    -275-

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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
                                    -276-

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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 ,
                                    -277-

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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.
                                   -278-

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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,
                                    -279-

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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
                                    -280-

-------
.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
                                    -281-

-------
-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.
                                   -282-

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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)
                                     -283-

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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;
                                   -284-

-------
     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
                                    -285-

-------
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)
                                    -286-

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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
                                        -287-

-------
: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.
                                         -288-

-------
 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-

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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-

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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-

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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-

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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 201—H
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
                                        -300-

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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
                                       -302-

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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
                                        -303-

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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
                                        -304-

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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.
                                        -305-

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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
                                          -306-

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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.
                                      -307-

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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
                                         -308-

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