&EPA
            United States
            Environmental Protection
            Agency
             Office Of The
             Administrator
             (1102)
                                      December 1992
Senior Policy Council
Pollution Prevention
1992 Annual Report

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SENIOR POLICY COUNCIL
1992 POLLUTION PREVENTION ANNUAL REPORT
    "EPA should emphasize pollution prevention as the preferred option
for reducing risk. By encouraging actions that prevent pollution from
being generated in the first place, EPA will help reduce the costs,
intermedia transfers of pollution, and residual risks so often associated
with end-of-pipe controls..."

    "Preventing pollution at the source — through the redesign of pro-
duction processes,  the substitution of less toxic production materials, the
screening of new chemicals and technologies before they are introduced
into commerce, energy and water conservation, the development of less
polluting transportation systems and farming practices, etc. — is usually
afar cheaper, more effective way to reduce environmental risk, espe-
cially over the long term,"
"Reducing Risk"
 Science Advisory Board, 1990

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12

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I 1 !
SENIOR POLICY COUNCIL
1992 POLLUTION PREVENTION ANNUAL REPORT
TABLE OF CONTENTS
Foreword ... . .... 5
SeniorPolicyCouncil 6
Definition of Pollution Prevention 7
Incorporating Prevention Into Regulatory Environmental Programs
1. Rule Developmentt 8
2.Pennits 10
3.Enforcement’Compliance 11
State Partnerships/Prevention Through Media Grant Programs 13
FundingforPrevention 15
Acronyms . 18
Appendix 19
The Definition of Pollution Prevention
Source Reduction Review Project Fact Sheet
EPA State Grant Guidance

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Pollution Prevention...what people are saying...
“I believe that building pollution-prevention flexibility into
media grant programs is the most important single policy action
that EPA can take to provide incentives for states to integrate
pollution prevention into existing programs. ..EPA has taken a
bold step in the right direction through its guidance on pollution
prevention flexibility in media grant progra,ns.”
John R. Wemgart
Assistant Commissioner
New Jersey Department of Environmental Protection and Energy
“The Minnesota Pollution Control Agency (MPCA) views
pollution prevention as a cornerstone of environmental protec-
tion, and we are attempting to integrate pollution prevention
into the entire fabric of environmental regulation at the MPCA.
We applaud efforts of the EPA to foster this integration at the
federal level.”
Charles W. Williams
Commissioner
Minnesota Pollution Control Agency
“Indiana is extremely supportive of your efforts to inject
sufficient flexibility into program grants for the purpose of
encouraging and facilitating pollution-prevention activities.
The draft “FY94 State Grants Guidance: Integration of Pollu-
tion Prevention” is a case in point; we fully support the concep-
tual approaches framed by this grants guidance...”
Kathy Prosser
Commissioner
Indiana Department of Environmental Management
“EPA ‘s Source Reduction Review Project goes to the heart
of the pollution prevention matter like no other effort in the
country. SRRP creates,for the first time, the possibility of
treating each business like a group of people performing a
productive activity. . for whom pollution is incidental, and to a
large extent, preventable.”
Dr. Nikki Roy
Environmental Defense Fund
I i

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FOREWORD
Pollution prevention is based upon the old principle of”a stitch-in-time saves nine.” Rather than
cleaning up waste after is has been created, pollution prevention relies on the concept that it is best
not to produce waste in the first place.
In 1990, with the backing of states, environmental groups, and industry, Congress passed the
Pollution Prevention Act (PPA). This legislation established an innovative national goal for
environmental protection: to reduce or eliminate waste at its source, rather than trying to control
it after it has been produced. Since the PPA became law, much progress has been made at
implementing strategies to encourage industry to solve its environmental contamination problems
before they begin.
l’his document is an annual report of the Senior Policy Council (SPC) on some of the U.S.
Environmental Protection Agency’s efforts to advance a national pollution-prevention policy.
New regulatory guidelines are outlined as ways to set objectives, evaluate progress, and identify
steps to be taken in the future.
The Pollution Prevention Annual Report was prepared for the SPC by the Pollution Prevention
Policy Staff in the Office of the Administrator. The SPC is comprised of EPA ‘stop managers and
meets on a quarterly basis to review and approve new pollution-prevention initiatives, and to
evaluate their implementation.
While this report focuses primarily on Agency-wide efforts to build prevention into traditional
programs, EPA’s commitment to source reduction incorporates many other activities not covered
in this document, including:
j Collaborative efforts, such as the Design for the Environment and the Green Lights
programs;
L Research and technical assistance, which includes cooperative efforts with other
federal agencies;
r Development of public data to measure success in reducing waste at the source,
including new Pollution Prevention Act reporting requirements; and
i Building state capacity through such programs as the Pollution Prevention Incen-
tive Grants.
If you have questions aboutthis report, please contactEric Schaeffer, Directorof the Pollution
Prevention Policy Staff, at 202-260-8636. For general information about other important
activities not covered in this document, call Dave Kling, Acting Director of the Pollution
Prevention Division, at 202-260-3557.
For information on specific successful EPA pollution-prevention programs, please
feel free to contact the following individuals:
Design for the Environment: Libby Parker 202-260-0686
Life-Cycle Analysis: Tim seam 919-541-0491
Green Lights: Bob Kwartin 202-260-9313
33/50: Dave Sarokin 202-260-6396
Pollution-Prevention
Reporting Requirements: Susan Hazen 202-260-1761
Research Programs: Paul Shapiro 202-260-5747
RCRA Waste Minimization: Donna Pe a 703-308-8438
Prevention and Water Programs: Jim Lund 202-260-7811
5

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“Despite its complexity, for pollution control purposes the environ-
ment must be perceived as a single interrelated system. Present assign-
ments of departmental responsibilities do not reflect this interrelated-
ness. Many agency missions,for example, are designed primarily along
media lines — air, water, and land. Yet the sources of air, water and
land pollution are interrelated and interchangeable.”
President Richard Nixon, 1970
SENIOR POLICY COUNCIL
1992 POLLUTION-PREVENTION H IGH LIGHTS
In 1991, the SeniorPolicy Council (SPC) was established to set Agency policy forEPA’s pollution-
prevention initiatives. One purpose of the SPC is to ensure that source reduction is promoted as
the first step m environmental management throughout all EPA activities.
The primaiy accomplishments of the SPC are given here as an introduction to the main course of
EPA pollution-prevention actions listed throughout this document.
Rules: Launched Source Reduction Review Project (SRRP) in March to promote
pollution prevention through multimedia coordination of new rules for 17 key
industhes.
Definition: Developed and distributed Agency-wide defmition of pollution prevention in
May for use by all EPA programs.
Permits: Entered into Memorandum of Understanding with New Jersey in May to test
new, multimedia approaches to permitting. Established “Printing Cluster” to
evaluate pennitting and reporting issues for small print shops.
Enforcement: Recommended new policy in July to incorporate pollution prevention into
enforcement settlements.
Labeling: Cooperated with Federal Trade Commission (July) in developing guidelines for
use of specific environmental tenns in advertising.
Budget: Published criteria for “2%” programs in July leading to identification of $12
million in FY93 program investments in pollution prevention projects.
Grants: Announced guidance in November providing flexibility (within statutory limits)
in federal environmental grant programs for state pollution-prevention invest-
ments.
Voluntary: Published Environmental Leadership proposal in December seeking comment
on new initiative to recognize and reward companies making comprehensive,
long-term commitments to pollution prevention and sustainable development.
6 F

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DEFINITION OF POLLUTION PREVENTION*
[ OBJECTIVE lit
r To establish a clear and consistent definition of pollution prevention to guide EPA
programs (as required by the Pollution Prevention Act of 1990).
ACTIONS TAKEN
EPA published a proposed definition of pollution prevention in January of 1989,
asking for public comment regarding whether “environmentally sound” recycling
should he included in definition along with source reduction.
L Science Advisory Board released “Reducing Risk” report in September of 1990.
That report defines prevention as: “changes in raw materials, products or technolo-
gies of production which reduce the use of hazardous materials, energy, water or
other resources without creating new risks of concern.” Discussion in report
emphasizes toxic use reduction and energy conservation.
Pollution Prevention Act signed into law in November of 1990. The Act defines
source reduction in the industrial context and also establishes source reduction as
the first priority in ahierarchy of choices that also includes recycling, treatment, and
disposal.
EPA’s Pollution Prevention Strategy in January of 1991 defines prevention as
including source reduction and in-process recycling, as well as conservation of
natural resources in industrial, agricultural, energy, and transportation sectors. The
strategy was reviewed and approved by 0MB and published in the Federal
Register.
c Deputy Administrator issued memorandum to all staff in May of 1992 reiterating
that pollution prevention encompasses source reduction and in-process recycling,
and efficient use of natural resources in both industrial and nor -industrial sectors.
ACTIONS NEEDED
Programs should be encouraged to look for further opportunities to illustrate
defmition in specific applications.
Coordination with Council on Environmental Quality (CEQ) to ensure consis-
tent use of definition by all federal agencies.
* See appendix for additional information.
PPPS CONTACT: Kate Perry 202-260-5430
OPPT CONTACT: John Cross 202-260-3559
I

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“Turning environmental concern into competitive advantage de-
mands that we establish the right kind of regulations. They must stress
pollution prevention, rather than merely abatement or cleanup. They
must not constrain the technology used to achieve them.”
Michael Porter
Harvard Business School
INCORPORATING PREVENTION INTO REGULATORY
ENVIRONMENTAL PROGRAMS
1. RULE DEVELOPMENT
Agency Project: Source Reduction Review Project*
To meet Pollution Prevention Act requirement to consider how proposed rules will
affect opportunities for source reduction.
To create models, based on key industries, for regulatory development which can
be applied to other rules.
To develop a systematic, cost-effective approach to controlling risks from use of
hazardous solvents through: 1) identifying and publicizing infonnation about safe
substitutes; and 2) eliminating regulatory biases against use of safe substitutes for
compliance.
ACTIONS TAKEN
u Established the Source Reduction Review Project (SRRP) and identified 17
industrial categories for which multimedia source reduction opportunities will be
intensely evaluated during rule development. Categories include pulp and paper,
printing, metal products and machinery, and phannaceuticals.
Identified principles for analyzing, developing, and implementing rules that
emphasize industry source reduction and multimedia management.
Established an Agency work group to evaluate the potential cross-media and
human-health impacts of aqueous and semi-aqueous substitutes for hazardous
solvents. Group will develop a consistent life cycle methodology to determine the
“acceptability” of substitutes for regulated substances.
Received an FY93 Agency commitment of over $1 million to support SRRP.
u Established an agreement with the Department of Defense (DOD) to share
information on the development of new technologies relevant to SRRP industries.
* See appendix for additional information.

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Statement of objectives from each of the work group chairs of the ‘93 and ‘94 SRRP
industry clusters regarding goals for promoting source reduction as a means of
compliance with forthcoming rules.
MULTI-PROGRAM!
MULTI-MEDIA
RELATIONSHIPS
9 i
INDUSTRIAL/PROCESS CATEGORY
Date of Proposed Regulation
AIR’
WATER 2
AZARDOUS
WASTE 3
CTG
MACT
Pulp and Paper Production
19925
1993
1993
1994?(A) 4
Pesticide Formulating
19925
1993
1993(C)
Pharmaceuticals Production
19925
1996
1994
Printing/Publishing (Coating)
19926
1993
1994(B)
Degreasing Operations
1992
1993
1994(B)
Metal Products and Machinery
1994
1994(B)
Styrene Butadiene Rubber and Latex Prod.
1993
1994(B)
Polystyrene Production
1993
1994(B)
Wood Furniture
19928
1996
1996(D)
Paints, Coatings, and Adhesives MIg.
1996
1996(D)
Paint Stripper Users
1996
1994(B)
Rubber Chemicals Production
1996
1994(B)
Paper and Other Webs (Coating)
1996
1994(B)
Acrylic/Modacrylic Fibers Production
1996
1994(B)
Reinforced Plastic Composite Production
1996
Integrated Iron and Steel MIg.
1996
Plywood/Parucleboard Mfg.
1999
PPPS CONTACT: Lynn Vendineflo 202-260-8612
OPPT CONTACT: Julie Shannon 202-260-2736
1. Air rules refer to MACT standards under the Clean Air Act. Dates proposed in the Federal Register (February 1992).
2. Water rules refer to effluent limitations guidelines.
3. Hazardous Waste refers to RCRA listings of specific wastes. A) t)ioxin B) Solvents Ill/H; C’) (‘arbamates: I)) Paint Waste.
The solvent listing determination may indirectly affect many uses of the solvents.
4. May or may not occur, depending on outcome of Office of Water regulations.
5. Industrial wastewater Control Technique Guideline (CTG).
6. Offset lithography pronting operations only.
7. Cleaning solvents CFG.
8. Both (TO and MACT in negotiated rulemaking for integrated standard.

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2. PERMITS
OBJECTIVES
L To evaluate the feasibility of promoting pollution prevention through integrated,
multimedia permitting and reporting.
f To develop and implement an Agency pollution-prevention permitting strategy
that uses both regulatory and non-regulatory tools to promote cost-effective risk-
reduction actions.
U To reduce transaction costs of permitting and reporting systems, especially for
small businesses.
Established a Printing Industry Cluster (OPPT as lead) to coordinate projects
affecting small printers. Cluster projects include: 1) promoting industry use of safe
chemicals and pollution-prevention practices; 2) coordinating development of new
rules to promote pollution prevention and reduce production cost; and 3) develop-
ing pilot projects to test use of pollution-prevention methodologies to reduce cost
of reporting requirements.
U Coordination of state pilot projects by the Office of Pollution Prevention and
Toxics (OPPT) to explore multimedia permitting.
U In June 1992, EPA announced a Memorandum of Understanding with New Jersey
to demonstrate multimedia permitting with three industrial facilities.
U Completed Amoco/Yorktown project documenting value of comprehensive emis-
sions inventory.
ACTIONS NEEDED F
U OPPT needs to clarify responsibilities of various programs under Printing
Industry Cluster, and to get clear definition of, and budget commitment for,
expected work products.
U Agency must deyelop coherent strategy for permitting issues and complete memo-
randa of understanding with two to three additional states for demonstrations of the
multimedia permitting concept. Should also evaluate existing state/EPA multime-
dia permitting demonstrations to transfer experience to other states nationwide.
PPPS CONTACT: Kate Perry 202-260-5430
OPPT CONTACT: Kathy Ramus 202-260-1707
OPPE CONTACT: Pam Herman 202-260-4336
10

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3. ENFORCEMENT/COMPLIANCE
Agency Projects: Blackstone Multimedia Inspections
Supplemental Environmental Projects
OBJECTIVES
To integrate pollution prevention into enforcement settlements where appropriate
under the law.
To examine the feasibility of multi-media inspections and the proper role for
pollution prevention in these inspections.
. .. I°
The SPC appointed a work group to develop recommendations on how to imple-
ment SEP in enforcement settlements. Remainder of the recommendations to be
completed under the Office of Enforcement (OE) Innovative Settlements Work
Group.
EPA evaluating Blackstone project to determine how multimedia inspection can
lead violators to use source reduction as a principle means of compliance.
j ACTIONS NEEDED
OE Innovative Settlements Work Group needs to complete implementation of
the recommendations for incentives for additional pollution prevention settle-
ments.
J OE must collect, synthesize and distribute year-end data from Regions on
pollution- prevention SEPS.
OE should ensure that data on SEP settlements are included in the annual report on
enforcement cases.
PPPS/OE must work with Region I to complete a formal evaluation of the
objectives of the Blackstone Project in promoting pollution prevention and
meeting statutory objectives.
PPPS Contact: Contact: Linda G’ass (202) 260-8616
OE Contact: Peter Rosenberg (202) 260-8869
Iii I

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19%
POLLUTION PREVENTION SEPS BY ACTIVITY
(REPRESENTED IN PERCENT)
Close-Loop Recycle
25%
New Equipment
21%
Process
Change
Total # = 69 in FY92
(Preliminary Findings)
Chem Substitution
35%
Hi

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“fP]ro grams can be designed to allow for significant flexibility at the
state or local level. The federal government can define the mission and
the outcomes it wants, but free lower governments to achieve these
outcomes as they see fit. What we really need is a new model of grant
program, built around the principles of entrepreneurial government.”
Reinventing Government
David Osborne and Ted Gaebler
STATE PARTNERSHIPS/PREVENTION THROUGH MEDIA
GRANT PROGRAMS
Agency Projects: Guidance for EPA Media Grants*
Multimedia Models (e.g. Blackstone)
I OBJECTIVES ti
i To encourage states to use EPA media grants (Resource Conservation Recovery
Act, Clean Air Act, Clean Water Act) to support state prevention initiatives and
build core pollution-prevention programs.
To establish clear national prevention guidelines to guide investment of federal
grants to states.
ACTIONS TAKEN
Developed FY93 guidance as a preliminary step encouraging the use of media
grant programs for innovative state prevention projects.
Issued Agency-wide guidance effective FY94 promoting pollution prevention
and flexibility in grant work plans developed by EPA and states. The guidance
outlines national principles to encourage innovation and build-up of state pollution
prevention capacity.
Orchestrated Regional office workshops on implementation of guidance sched-
uled for January/February of 1993.
ACTIONS NEEDED II
Programs should develop materials to incorporate Agency-wide guidance into
FY94 media grants.
State Grant Work Group should collect and distribute examples of innovative
state prevention projects supported through federal grant dollars, and to help
provide models for implementing guidance.
* See appendix for additional information.
j13 1 :

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c i Deputy Administrator and Regional Offices need to assess effectiveness of
guidance, share information on successes, and identify barriers based on annual
reports provided by EPA Regional Offices.
PPPS CONTACT: Kate Perry 202-260-5430
OPPT CONTACT: Deborah Hanbn 202-260-2726
REGIONAL OFFICE CONTACT: Mike Gearheard (Region 10) 206-553-2782

FY93 EPA OPERATIONS GRANT PROGRAM FUNDING*
Water
39.0%
Total = $526.4 million
Exdudes CWA tftle VI and Superfund
* Based on President’s FY93 request
PREVENTION IN
STATE GRANTS
L i i
RCRA
19.0%
Pesticides & Toxics
7.0%
35.0%
Figures as of November 15, 1992

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FUNDING FOR PREVENTION
FY93 2% PROJECTS
FY94 BUDGET REQUEST
....... ........—...... ........... ii
( To allocate resources for innovative pollution-prevention projects in EPA base
programs.
L] To design and establish effective tracking procedures to ensure that project
objectives are meL
L i To ensure that FY94 budget requests clearly and consistently identify resources
dedicated to prevention as defined by the Deputy Administrator memorandum.
ACTIONS TAKEN fi.
2% PROJECT
RESOURCES
(DOLLAR FUNDING BY
AGENCY PROGRAM)
Guidance and allocations for FY93 projects distributed to programs.
i Approval for regional guidance on pollution prevention 2% set-aside projects.
Identification of over 100 Agency-wide 2% projects dedicated to pollution preven-
tion (project list available upon request).
Review, by the Office of the Administrator, of all 2% projects for FY93.
i Submission of 2% project list to the Senior Policy Council for approval.
Approval by Senior Policy Council of 2% project list (FY93) pending EPA budget
finalization.
OFFICE
FY93 RESOURCES
OA
$196.5
OIA
$259.2
OARM
$51.8 :1
ORD
$5,051.0
$1,187.4
OPPTS
OAR
$2,029.9
OW
$1,602.5
OGC
$3.1
OPPE
$362.6
OSWER
$795.1
OE
$193.1
I
$11,732.3
15

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Agency-wide:
Publication of FY93 2% Pollution-Prevention Projects.
C Semi-annual review of project progress (April ‘93-September ‘93).
Final review of FY94 budget request to ensure that prevention resources are clearly
identified.
PPPS Cont t: Tom McCuIIy 202-260-8617
OPPT Cont t: John Cross 202-260-3559
rid

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Hi

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ACRONYMS

Council on Environmental Quality
Li Department of Defense
Li Federal Trade Commission
Li Office of Air and Radiation
Li Office of Enforcement
Li Office of Management and Budget
Li Office of Policy, Planning and Evaluation
Li Office of Pollution, Prevention and Toxics
Li Office of Research and Development
Li Office of Solid Waste and Emergency
Li Pollution Prevention Policy Staff
Li Resource Conservation Recovery Act
Li Senior Policy Council
Li Source Reduction Review Project
CEQ
DOD
FTC
OAR
OE
0MB
OPPE
Oplyr
ORD
OSWER
PPPs
RCRA
sPC
SRRP
18j

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APPENDIX
The Definiáon of Pollution Prevention
Source Reduction Review Project Fact Sheet
EPA State Grant Guidance
19

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
MAY 281992
OFFICE OF
THE ADMINISTRATOR
MEMORANDUM
SUBJECT: EPA Definition of “Pollution Prevention”
FROM: F. Henry Habicht II
Deputy Administrat
TO: All EPA Personnel
EPA is seeking to integrate pollution prevention as an ethic
throughout its activities, in accordance with the national policy
expressed in the Pollution Prevention Act of 1990. Your
individual efforts to push development of new opportunities,
approaches, and processes to prevent pollution are impressive and
exciting.
While the concept of pollution prevention is broadly
applicable-—a tool to accomplish many environmental tasks-—this
memo attempts to guide more consistent use of the term in our
activities and written materials. Pollution prevention requires
a cultural change——one which encourages more anticipation and
internalizing of real environmental costs by those who may
generate pollution, and which requires EPA to build a new
relationship with all of our constituents to find the most cost-
effective means to achieve those goals.
The following EPA “Statement of Definition” is a formal
embodiment of what has been the Agency’s working definition of
pollution prevention, and is consistent with the Pollution
Prevention Act of 1990 and the Agency’s 1991 Pollution Prevention
Strategy. It makes clear that prevention is our first priority
within an environmental management hierarchy that includes: 1)
prevention, 2) recycling, 3) treatment, and 4) disposal or
release.
While it is subject to further refinement, this definition
should provide a common reference point for all of us. As you
review and apply the definition in your work, please keep the
following points in mind:
• As always, whether the pollution prevention option is
selected in any given situation will depend on the
Printed on Recycled Paper

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2
requirements of applicable law, the level of risk reduction
that can be achieved, and the cost-effectiveness of that
option.
• Accordingly, the hierarchy should be viewed as
establishing a set of preferences, rather than an absolute
judgement that prevention is always the most desirable
option. The hierarchy is applied to many different kinds of
circumstances that will require judgement calls.
• Drawing an absolute line between prevention and recycling
can be difficult. “Prevention” includes what is commonly
called “in—process recycling,” but not “out—of—process
recycling.” Recycling conducted in an environmentally sound
manner shares many of the advantages of prevention, e.g.
energy and resource conservation, and reducing the need for
end—of—pipe treatment or waste containment.
As EPA looks at the “big picture” in setting strategic
directions for the decade ahead, it is clear that prevention is
key to solving the problems that all our media programs face,
including the increasing cost of treatment and cleanup. In the
common—sense words of Benjamin Franklin, “an ounce of prevention
is worth a pound of cure.”
Please use the Statement of Definition of Pollution
Prevention in all of your EPA activities.
POLLUTION PREVENTION: EPA STATEMENT OF DEFINITION
(pursuant to the Pollution Prevention Act of 1990
and the Pollution Prevention Strategy)
Under Section 6602(b) of the Pollution Prevention Act of
1990, Congress established a national policy that:
• pollution should be prevented or reduced at the source
whenever feasible;
• pollution that cannot be prevented should be recycled in an
environmentally safe manner whenever feasible;
• pollution that cannot be prevented or recycled should be
treated in an environmentally safe manner whenever feasible;
and
• disposal or other release into the environment should be
employed only as a last resort and should be conducted in an
environmentally safe manner.
Pollution prevention means “source reduction,” as defined
under the Pollution Prevention Act, and other practices that
reduce or eliminate the creation of pollutants through:

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3
——increased efficiency in the use of raw materials, energy,
water, or other resources, or
——protection of natural resources by conservation.
The Pollution Prevention Act defines “source reduction” to
mean any practice which:
——reduces the amount of any hazardous substance, pollutant,
or contaminant entering any waste stream or otherwise
released into the environment (including fugitive emissions)
prior to recycling, treatment, or disposal; and
——reduces the hazards to public health and the environment
associated with the release of such substances, pollutants,
or contaminants.
The term includes: equipment or technology modifications,
process or procedure modifications, reformulation or redesign of
products, substitution of raw materials, and improvements in
housekeeping, maintenance, training, or inventory control.
Under the Pollution Prevention Act, recycling, energy
recovery, treatment, and disposal are not included within the
definition of pollution prevention. Some practices commonly
described as “in—process recycling” may qualify as pollution
prevention. Recycling that is conducted in an environmentally
sound manner shares many of the advantages of prevention——it can
reduce the need for treatment or disposal, and conserve energy
and resources.
Pollution prevention approaches can be applied to all
pollution-generating activity, including those found in the
energy, agriculture, Federal, consumer, as well as industrial
sectors. The impairment of wetlands, ground water sources, and
other critical resources constitutes pollution, and prevention
practices may be essential for preserving these resources. These
practices may include conservation techniques and changes in
management practices to prevent harm to sensitive ecosystems.
Pollution prevention does not include practices that create new
risks of concern.
In the agricultural sector, pollution prevention approaches
include:
——reducing the use of water and chemical inputs;
——adoption of less environmentally harmful pesticides or
cultivation of crop strains with natural resistance to
pests; and
——protection of sensitive areas.
In the energy sector, pollution prevention can reduce
environmental damages from extraction, processing, transport, and

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4
combustion of fuels. Pollution prevention approaches include:
——increasing efficiency in energy use;
——substituting environmentally benign fuel sources; and
——design changes that reduce the demand for energy.
For more information contact:
th. Pollution Prevention Policy Staff (260-8621), or
—-the Pollution Prevention Division, Office of Pollution
Prevention and Toxics (260-3557)

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EPA Source Reduction Review Project
Who benefits
from SRRP?
How did EPA
choose the
industrial!
process
categories?
What are
the key
industrial
categories?
By having the flexibility to invest in source reduction measures as a means of compliance, industry can
make cost-effective environmental decisions that will help improve efficiency and competitiveness. If
source reduction measures are chosen as the primary means to achieving compliance, then the environ-
ment will benefit in at least two significant ways: 1) the transfer of pollutants from one medium to
another will be prevented; and 2) energy and raw materials use as well as other waste streams may be
reduced.
EPA based its list on those industrial categories facing new air, water, and hazardous waste standards
over the next decade. Sixteen industrial/process categories were chosen based on one or more of the
following:
• Environmental releases to more than one media
• Potential for pollution reduction
• Known opportunity for source reduction
• Forthcoming regulatory requirements under multiple statutes.
Paper and Other Webs Coating
Acrylic Fibers/Modacrylic Fibers
Degreasing Operations
Polystyrene Production
Reinforced Plastic Composites Production
Metal Products and Machinery
Wood Furniture Manufacturing
Where can I
get more
information?
Lynn Vendindllo
U.S. Environmental Protection Agency
Office of the Administrator
Pollution Prevention Policy Staff (1102)
401 M Street, S.W.
Washington, D.C. 20460
(202) 260-8612
Pesticide Formulating
Pulp and Paper Production
Pharmaceuticals Production
Paints, Coatings, and Adhesives
Printing/Publishing
Integrated Iron r
Plywc
1 Manufacturing
Manufacturing
I
I
cturing

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
NOV I 2 1992
OFFICE OF
THE ADMINISTRATOR
SUBJECT: State Grants Guidance: Integration of Pollution
Prevention
FROM: F. Henry Habicht I
Deputy Administrator
TO: Assistant Administrators
Regional Administrators
This memorandum announces the Agency—wide pollution
prevention Guidance, beginning with the FY’94 State grants cycle.
It has four goals:
• Promoting pollution prevention in State programs
supported through Federal grants by establishing
National Principles to guide workplans negotiated
between Regional Offices and States;
• Ensuring that grant requirements as interpreted by
EPA/State workplans are flexible enough to support
innovative State pollution prevention activities;
• Establishing a simple accounting process to share
information on successful State projects, and identify
statutory or other barriers to funding State proposals;
and
• Building sustained State capacity in pollution
prevention to the extent consistent with statutory
grant requirements.
All of these objectives are subject to any statutory and
regulatory limitations that apply in specific circumstances.
The Guidance should help integrate pollution prevention into
the Agency’s activities as required by the Pollution Prevention
Act of 1990 . By emphasizing flexibility, the Guidance
complements other Agency efforts to build a productive
environmental management system in partnership with the States,
and improve coordination with existing State pollution prevention
programs.
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In general, this Guidance applies to all of the Agency’s
media-specific State grant programs, but particularly to the
following: Clean Air Act S1O5 Air Pollution Planning and
Control; Resource Conservation and Recovery Act S3011——Hazardous
Waste; Federal Insecticide. Fungicide, and Rodenticide Act
§23(a)(l)——Pesticides; Toxic Substances Control Act S28-—
Enforcement and Enforcement Activities under S3l3 of the
Emergency Planning and CommunitY Right-to-KnOW Act; and Clean
Water Act S106--Surface Water, S104(b) (3)--Wetlands and Water
Quality Management, and 5319(h)—-Non-Point Source Management.
Building on the Agency’s many successful pollution
prevention efforts, beginning in FY’94 EPA’s grant programs--
working with States—-should explicitly promote pollution
prevention in State workplans (also called agreements). This
memorandum will be incorporated into the annual Agency Operating
Guidance as well as program—specific Guidance developed this
winter with the advice of the State/EPA Operations Committee.
Program Guidance, intended to tailor the Agency-wide commitment
to each grant program, will be applied by Regional Offices and
States in the development of grant-assisted work.
The National Principles stated below should help guide
development of EPA/State workplans. These should be reflected in
program—specific Guidance, weighed in workplan discussions, and
used to qualitatively assess program progress in integrating
pollution prevention. In applying these principles, Regional
Offices should use or expand upon the menu of flexibility options
below to respond to State needs to the extent possible. Annual
accomplishment reports, discussed below, will help assess EPA’S
progress in supporting pollution prevention-oriented State
workplans and initiatives.
National Principles
Guidance for each grant program covered by this document
should make clear that pollution prevention--as defined in the
Agency-wide memorandum of May 28, 1992 (attached)--is EPA’S
preferred approach to environmental management where technically
and economically feasible. Consistent with the Pollution
Prevention Act, the Guidance should further the integration of
pollution prevention into State activities--e.g. inspections and
permits--that are supported by EPA grants. While pollution
prevention is not mandated, the Principles are intended to ensure
that it is considered fairly in EPA/State workplans.
Specific proposals from States that are consistent with
these principles should be considered good candidates for funding
through the grant programs. In addition, Regional Offices should
take the initiative to suggest pollution prevention approaches,
drawing upon program-specific Guidance and implementation
workshops. Regional Offices and States are expected to use their

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discretion in applying these Principles; they are not obligatory
elements of every negotiated workplan, but rather factors for
serious consideration in the negotiation process.
The Principles are:
1) The workplan applies the EPA definition of pollution
prevention (see memorandum of May 28, 1992) consistent with the
Pollution prevention Act of 1990 and the 1991 EPA Pollution
Prevention Strategy.
2) The workplan reflects an explicit preference for pollution
prevention and identifies pollution prevention activities,
products, or approaches.
3) The workplan incorporates pollution prevention as a priority
in environmental management decisions made by the grantee as part
of the grant—assisted activities.
4) The workplan encourages opportunities to modify existing or
to develop new equipment, technology, processes, procedures,
products, or educational or training materials to promote
pollution prevention.
5) The workplari encourages institutional coordination——including
coordination with existing State pollution prevention programs--
and multi-media opportunities for pollution prevention.
6) The workplan complements or builds upon existing EPA
pollution prevention projects (e.g. the work of multi-media
industry clusters such as the Source Reduction Review Project,
and the use of pollution prevention in enforcement settlements).
7) The workplan identifies and applies measures and ways of
documenting pollution prevention progress as part of the grant-
assisted activities (e.g. provides opportunities for measurable
pollution prevention).
8) The workplari includes activities or approaches that may serve
nationally as innovative models for other State or local
programs. Workplans also should encourage innovative approaches
already developed by other State or local programs, and improve
coordination to build on existing successes.
9) The workplan structures grant output information so that EPA
can make pollution prevention data and experience available to
other States and the Pollution Prevention Information
Clearinghouse.
Clearly, both partners must comply with any applicable statutory
or regulatory requirements and take into account other factors
that may be important. Regional Offices and States may identify

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additional Principles to guide workplan requirements.
Flexibility
Many Regional Offices already have made adjustments to
accommodate flexibility needs. The purpose of this Guidance is
to encourage such flexibility. Whenever possible, workp].ans
should accommodate State flexibility needs associated with
incorporating pollution prevention approaches into their grant—
assisted activities. That means working within the parameters of
statutory and regulatory requirements to arrive at an agreement
that is practical and meets the parties’ needs. Options for
flexibility include (but are not limited to):
a) Adjustments in numbers or types of required outputs
including, for example, (1) tradeoffs or disinvestment from
traditional requirements (non—statutory and non—regulatory)
and (2) multiple credit for a single “multi-media”
inspection that emphasizes pollution prevention.
—-An example of (1) is RCRA’s RIP-Flex Guidance, which
allows disinvestment from national priority activities and
re—investment in Regional or State priorities: up to 25% of
enforcement resources in FY’92 and ‘93.
--An example of (2) is being tested in Region One with
Massachusetts’ BlackStOfle project. The key issue is how to
“bean—count” a single multi-media inspection claiming to
satisfy enforcement requirements under multiple statutes and
promote pollution prevention technical assistance.
b) Adjustments in timing of non-statutory and non-
regulatory EPA deadlines.
c) Identification of a percentage of funds for pollution
prevention within each media program, coordinated by a
pollution prevention office.
——For example, Region 10 has agreed to Alaska’s request to
allow the State to identify 3% (5% over the next two years)
of grant program monies—-RCRA, air, and water--for pollution
prevention, to be coordinated by the pollution prevention
office. The monies will be reflected in specific activities
reasonably related to each program’s contribution and
statutory objectives. The annual EPA/State Agreement will
explicitly identify pollution prevention activities and
specific disinvestments in each program.
d) Adjustments in traditional or administrative procedures
or schedules to ease EPA/State interaction.
Annual Accomplishment Report
To allow EPA to evaluate progress in integrating pollution
prevention into State grant programs, each Regional Office should

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provide an annual report summarizing pollution prevention
accomplishments (e.g. activities, products, approaches, etc.), as
reflected. in grants—assisted work. The report may take any form
and may draw upon reports developed to satisfy other
requirements.
While program-specific Guidance may elaborate further, each
report should identify: a) success stories, including innovative
State projects funded under this Guidance; and b) any barriers
(statutory or otherwise) that led a program to reject State
proposals or to decide against including pollution prevention
approaches. In addition, recommendations on regulatory,
administrative, or other changes to improve flexibility would be
helpful. Your contribution of this information is key to making
pollution prevention a reality in EPA ’s on-going bread and butter
work.
Conclusion
Incorporating pollution prevention into EPA’S policies and
programs is a collaborative effort requiring EPA to work in
concert with our State partners. The National Principles and
Annual Reports described above will help us to measure our
progress and build on our successes.

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