- -
A Tribute to Rachel Carson
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PEANUTS
RACHEL CARSON
5 THAT WHEN
OUR MOON WA5 BORN,
THERE WERE NO
iCEANS ON EARTH
TALKIN6
ABOUT RACHEL CAf?50N!
RACHEL CARSON! RACHEL
CARSON.' RACHEL CARSON!
CUE Slf?L5 NEED
OUR HEROINES!
Women,
Consumers
and the
Environment
If I were asked ... to what
the singular prosperity and
growing strength of that people
(the Americans) ought mainly
to be attributed, I should reply:
To the superiority of their
women.
Alexis de Tocqueville,
"Democracy in America, 1840
In this issue, EPA Journal
examines the many and varied
contributions made by women
to the environmental move-
ment.
Administrator Douglas M.
Costle comments on the
inspiration, dedication, and
hard work provided by women
on an Agency-wide, national
and global scale.
Frank Graham, author of
Since Silent Spring, gives us a
thoughtful evaluation of Rachel
Carson, the very private person
who is credited with providing
major impetus to the environ-
mental movement. This year
marks the 1 5th anniversary
since, as Graham points out, a
Presidentially-appointed
Science Advisory Committee
substantially supported her
position that pesticides were
being misused in this country.
Administrator Costle, the
chairman of the Regulatory
Council recently established
by President Carter to improve
regulatory management in the
Federal Government, discusses
the goals of this new organiza-
tion. Deputy Administrator
Barbara Blum discusses regula-
tory reform advances within
EPA.
The magazine also has
articles from the heads of the
four Federal agencies which
are members of the Interagency
Regulatory Liaison Group,
established in a regulatory
reform-related move to improve
coordination within the Federal
establishment. These agencies
are: EPA, the Food and Drug
Administration, the Consumer
Product Safety Commission,
and the Occupational Safety
and Health Administration.
Other subjects include:
An article by Assistant
Secretary of Agriculture Carol
Foreman emphasizes the con-
tinuing importance of protect-
ing food from environmental
and other contaminants.
An article by Joan Martin
Nicholson, Director of EPA's
Office of Public Awareness,
reviews the effects consumer
buying habits can have on the
environment.
A report from EPA's Region
10 Office headquartered in
Seattle, the last in a year-long
series from the Agency's
Regional Offices. D
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United States
Environmental Protection
Agency
Office of
Public Awareness (A-1 07)
Washington, D.C. 20460
Volume 4
Number 10
Nov./Dec. 1978
S-EPA JOURNAL
Douglas M. Costle, Administrator
Joan Martin Nicholson, Director, Office of Public Awareness
Charles D. Pierce, Editor
Truman Temple, Associate Editor
John Heritage, Chris Perham, Assistant Editors
L'Tanya White, Staff Support
Articles
EPA is charged by Congress to
protect the Nation's land, air and
water systems. Under a mandate
of national environmental laws
focussed on air and water quali-
ty, solid waste management and
the control of toxic substances,
pesticides, noise and radiation,
the Agency strives to formulate
and implement actions which
lead to a compatible balance be-
tween human activities and the
ability of natural systems to sup-
port and nurture life.
Women and the
Environment 2
Administrator Douglas M.
Costle reviews the contribu-
tions women have made to the
environmental movement.
Rachel Carson 5
A tribute by Frank Graham to
the service provided by a
remarkable woman.
Better Governrnent
Service 8
Deputy Administrator Barbara
Blum reports on measures taken
to expedite EPA services.
The Caretaking
Consumer 10
A look by Joan Martin
Nicholson at the opportunities
women have to influence major
societal decisions with their
market place vote.
Nursing Mothers
and Environmental
Contaminants 12
A review by Molly B. Peter of
the problem of chemicals in
mother's milk.
Volunteerism and the
Environment 14
A review by Mary DeCarlo of
the grass-roots efforts by
women to protect their com-
munities from environmental
degradation.
Food Safety
and the Consumer 16
A report by Agriculture Assist-
ant Secretary Carol Tucker
Foreman.
Regulatory
Council Goals
18
Administrator Costle, the
chairman of this new council,
outlines the goals of this
interagency group.
A New Direction
in Interagency
Cooperation 19
A report on the Interagency
Regulatory Liaison Group.
OSHA and the
American
Working Man and
Woman 21
A review by Eula Bingham,
OSHA Administrator, on how
her agency is protecting the
public.
Consumer Safety
and Regulation 23
Susan King, the new chair-
person of the CPSC, reports
on functionings of this
commission.
Regulatory Reform
and FDA 24
FDA Commissioner Donald
Kennedy reports on steps taken
by his agency to improve
coordination with other
government agencies.
Jobs and the
Environment 28
A report by Truman Temple on
efforts being made to protect
both in the Mahoning Valley.
Senior
Environmental Aides
Honored 34
Leaders in a new program
which enlists the elderly to
help curb environmental ills.
A New Coalition:
Women for Environ-
mental Health 38
Region 10 Report 40
Cover: Rachel Carson photo in a
woodland setting by Erich Hart-
mann, used by permission of the
Rachel Carson Trust. Fall leaves
background photo by Anne
Labastille'.
Inside Front: Cartoon strip by
Charles M. Schultz. Copyright
United Feature Syndicate.
Photo credits: The Brooklyn
Museum/Carll H. De Silver Fund,
Republic Steel Corp., United Feature
Syndicate, Inc., The Rachel Carson
Trust, Dick Rowan', John White',
John Messina', Nick Karanikas,
Ernest Bucci, Yoichi Okamoto".
' Documerica
Departments
Almanac 17
People 26
Letters to the
Editor 31
Update 32
News Briefs
Nation 36
35
i he EPA Journal is published
monthly, with combined issues
July-August and November-Decem-
ber, by the U.S. Environmental
Protection Agency. Use of funds for
printing this periodical has been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect EPA policy. Con-
tributions and inquiries should be
addressed to the Editor (A-107),
Waterside Mall, 401 M St., S.W.,
Washington, D.C. 20460. No per-
mission necessary to reproduce
contents except copyrighted photos
and other materials. Subscription:
SI 0.00 a year, 31.00 for single
copy, domestic; S12.50 if mailed to
a foreign address. No charge to
employees. Send check or money
order to Superintendent of Docu-
ments, U.S. Government Printing
Office, Washington, D.C. 20402.
Text printed on recycled paper.
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Environmentally
Speaking
Women
and the Environment
By Douglas M. Costle
EPA Administrator
Ling before the first Earth Day in 1970,
women were playing a major role in
the effort to protect the environment.
They showed up at board meetings to
point out that industrial expansion would
threaten a trout stream or salt marsh. At
city council sessions when the planners
talked about the economic benefits forth-
coming from the new expressway/high-
rise/industrial park, women often asked
about the neighborhood park. Their interest
in trees, birds, flowers, and insects was
legendary. Construction engineers were
said to cringe from the specter of these
women who campaigned to protect the air,
land, and water.
In the 1940's Dr. Florence Sabin, then in
her seventies, campaigned to clean up
Colorado by combatting diseases spread
by contaminated food and water and sew-
age disposal.
I think that these women symbolized the
life-giving and conserving aspect of human
nature. What was sometimes portrayed as
blind opposition to progress was actually
a zeal to protect human health and the
quality of life.
One of the most outstanding of these
women, Rachel Carson, sounded
the alarm about environmental dangers.
As a scientist Miss Carson knew the value
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of careful, detached research, but it was
her unique, empathetic presentation of the
workings of nature in Under the Sea-Wind.
The Sea Around Us, The Edge of the Sea.
and finally Silent Spring, that gave impetus
to the growing environmental awareness in
this country and around the world.
In the following years women played a
role in the growing international realization
that pollution and environmental damage
are problems on a world scale. Diplomat
Inga Thorsson of Sweden suggested to the
United Nations in 1968 that a conference
be held to consider problems of the environ-
ment at the intergovernmental level. Secre-
tary General U Thant supported her idea
and called for the UN conference on the
Human Environment that was held in
Stockholm in 1972. Inga Thorsson later
headed the Swedish delegation to the Gov-
erning Council of the UN Environmental
Program, a product of the Stockholm
Conference.
Helena Benitez, President of the Philip-
pine Women's University in Manila, chaired
a committee at the Stockholm conference,
and in 1975 was named President of the
Third Governing Council of the UN
Environmental Program.
The UN commissioned an unofficial
report on the human environment to serve
as a factual and conceptual background for
the conference at Stockholm. Co-author of
the report with Rene Dubos was Barbara
Ward, the British economist. Their com-
prehensive and balanced report, Only One
Earth, outlined the social, political, and
economic dimensions of the pollution
problem world-wide.
In this country the late Margaret Mead'
was a shining example of the role women
can play in leading public opinion to support
the environmental cause. She was a strong
supporter of Earth Day and was president of
the North American Nongovernmental
Organizations Concerned with the
Environment.
Throughout my career in environmental
work, I have met women who serve the
environment not just as organizers and
promoters but as scientists and specialists.
Limnologist Dr. Ruth Patrick invented the
diatometer, an instrument that plots the
growth of microscopic algae, which is
used to study pollution in bodies of water.
Her theories of fresh-water aquatic life
are applied to Environmental Impact State-
ments throughout the world. In 1975, Dr.
Patrick won the Tyler Ecology Prize from
Pepperdine University for her work.
The appointment of my colleague Bar-
bara Blum as Deputy Administrator of this
Agency is an indication of the seriousness
of our commitment to let women take their
•Sse Editor's Note, Page 38 .
rightful place as respected professionals
within this Agency. Barbara's long history
of involvement in environmental activities
in her home State testifies to her keen
interest in our mission. In addition to work-
ing to protect the Chattahoochee River, she
served on county planning commissions,
advisory boards, councils, and committees
relating to the environment. As a chair-
person of the Georgia Heritage Trust Com-
mission, a trustee of the Georgia Conserv-
ancy, and a member of Save America's
Vital Environment, her activities earned a
Feinstone Environmental Award in 1977,
one of five given nationwide.
Dr. Kay Camin, EPA's Regional Admin-
istrator in Kansas City, has a background
in economics. Her work before joining the
Agency included studies of strip-mine
reclamation, workshops on citizen par-
ticipation in water quality control and the
first national study on water pollution gen-
erated by the meat-packing industry.
Regional Administrator Adlene Harrison
in Dallas was a member of the National
League of Cities Steering Committee for
Environmental Quality. Her work on the
Dallas city council included support for
a stringent air pollution ordinance and co-
sponsorship of an ordinance to establish a
city environmental committee.
In Boston, Rebecca Hanmer is EPA's
Deputy Regional Administrator. She has
been with the Agency since its inception,
and is a former Director of the Office of
Federal Activities at EPA headquarters.
The EPA Deputy Regional Administrator in
San Francisco is Sheila Prindiville, who
has served in numerous capacities during
her seven years with the Agency.
Here in Washington, I have opportunities
to see and appreciate daily the dedication
and skill of the women on our staff. EPA's
General Counsel, Joan Bernstein, has 25
years of experience as an attorney in gov-
ernment and private practice and served in
various capacities with the Bureau of Con-
sumer Protection of the Federal Trade
Commission.
Alice Brandeis Popkin, who heads up
our Office of International Affairs, came to
the Agency from the Antioch School of
Law where she served as a professor. She
was a member of the original staff that set
up the Peace Corps.
Joan Martin Nicholson, Director of the
Office of Public Awareness, served on
several boards of environmental organiza-
tions and founded the Bolton Institute, a
non-profit organization dedicated to help-
ing people find practical solutions to
environmental problems.
The Director of EPA's Office of Civil
Rights, Doris Thompson, has 26 years of
government experience with the Depart-
ment of the Army and the National Security
Agency.
In addition to the women who act as
administrators and managers, EPA has an
increasing number of women technical
specialists. Dr. Marilyn Bracken is a Deputy
Assistant Administrator in the Toxic Sub-
stances Program who is responsible for
integrating the Agency's toxic substances
activities, coordinating interagency toxics
strategies, and for establishing and operat-
ing information policies and programs. Dr.
Elizabeth Anderson is the Director of the
Agency's Carcinogen Assessment Group,
the advisory body that assesses the pos-
sible health risk of suspected cancer-caus-
ing substances that fall under EPA's regula-
tory authority. In Chicago, the Director of
EPA's Great Lakes National Program is
Dr. Edith Tebo, a specialist in laser
technology.
I am proud of the talent, intelligence, and
experience that these women represent.
They are all seasoned professionals. Yet
they are only a sampling of the more than
3,500 women employed by EPA, 35 per-
cent of the Agency's staff. At the same time
I am aware of the concentration of women
at the lower levels of the civil service
grade hierarchy in EPA, an unfortunate
legacy of discrimination afflicting many
Federal agencies. The average grade of
male employees at EPA is 11.67. The aver-
age grade of the female EPA employee is
7.04. The Agenqy has undertaken to
remedy that situation and with it the tre-
mendous waste that results from under-
utilization of the abilities and contributions
of women.
Finally, women traditionally have been
responsible for the care and welfare of
families, which makes them especially
sensitive to the importance of clean air and
safe water. As mothers they know that their
bodies provide the first environment for a
child, and that they will be primarily re-
sponsible for the nourishment, safety and
well-being of their children.
Homemakers were the foot-soldiers of
the environmental movement—the volun-
teers who gave freely of their time and
energy in support of environmental causes.
Many important environmental decisions
have been based on the concern of local
activists, who many times were home-
makers. This is not strictly an American
phenomenon but occurs anywhere that
pollution poses a threat to people; the
women of Minamata, Japan, were in the
forefront of the battle against mercury
poisoning in their fishing village.
The work many women initiated con-
tinues wherever people care about their
world. D
EPA JOURNAL
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Dacfe
X" "N By Frank Graham, Jr.
Caioi
Robert Frost liked to make a point with
an anecdote as well as with a poem.
"A boy came to my homethe other day,"
Frost recalled, "and he said to me, 'I'm a
poet.' I said, That's a praise word. I'd wait
unti! somebody else called me that.' '
Rachel Carson did not have to pin any
labels on herself. There were many other
people all over the world who were eager
to use praise words to describe her and
her work.
-------
Poet was one of them, for she wrote
prose with a poet's passion. Scientist was
another. As a marine biologist who worked
for the old U.S. Bureau of Fisheries and
later for the Fish and Wildlife Service, she
gathered the background to write those
distinguished books on the sea that were
read by millions here and abroad.
Conservationist was still another. No one
in our country's history believed more pro-
foundly in the aim of conservation—as an
attempt to understand and preserve the
capacity of land, water and wildlife for
self-renewal, in all their diversity and com-
plexity. Nor was anyone in our history able
to create among the public an "ecological
conscience" as ably as Rachel Carson did.
Yet this intensely private person, whom
her superiors at the Fish and Wildlife Serv-
ice remembered as being so shy originaliy
that she could hardly get out the words to
discuss a new project, became the center
of one of the most bitter public controver-
sies in the post-war era. As she lay dying
of cancer at the age of 56 in'1964, other
labels still swirled about her. "A nun of
nature, a votary of all outdoors," some
over-enthusiastic admirers gushed, while
from much less friendly quarters came
epithets like "mystic," "food faddist,"
"health quack" and "bird-lover." A dis-
passionate look at both her personality and
achievements suggests that of these char-
acterizations, coined in the heat of battle
by both friend and foe, only the last was
accurate.
Rachel Carson was an unlikely crusader.
Born in Springdale, Pa., far from the sea
with which she was later so closely
identified, she spent her childhood ab-
sorbed in books and in the wild things
around her home, to which her mother had
lovingly introduced her. Her first inclina-
tion was toward poetry. She apparently
produced a smattering of the poetic effu-
sions common to many sensitive young
people, but all that survived at her death
was a sheaf of rejection slips from the
magazines to which she sent her poems. At
that stage she was a poet in search of a
subject.
A subject revealed itself part way
through her undergraduate course at the
Pennsylvania College for Women, when
her romantic attraction to the sea coincided
with a growing fascination for biology. She
went on to study biology and genetics at
Johns Hopkins University, where she
earned her master's degree in 1932. (Her
doctorates were honorary.) For a time she
taught zoology at the University of Mary-
land and spent her summers working at the
Marine Biological Laboratory in Woods
Hole, Massachusetts. She became a Fed-
eral aquatic biologist in 1936.
It was during those Depression years
that Carson, intent on making a living, un-
wittingly was preparing herself for the
drama ahead. Though taken up with her
detailed studies of small aquatic life (her
master's thesis was entitled "The Develop-
ment of the Pronephros During the Embry-
onic and Early Larval Life of the Catfish
Ictalurus punctatus)," she never lost her
early vision of the complexity and majesty
of the sea, or indeed, of nature itself. To
the end of her life she kept close to her the
books by writers she thought captured
those qualities—Melville, Thoreau, Con-
rad, Richard Jeffries, Henry Beston, H. M.
Tomlinson—and letters to her closest
friends were filled with references to them.
Immersed in her science, her imagina-
tion resonant with phrases from favorite
books read and read again, Carson began
composing short articles about what she
knew best, the natural world. She became
a contributor to a Baltimore newspaper
while sharpening her skills writing official
government publications. In later years she
was given the title Biologist and Chief
Editor in the Fish and Wildlife Service.
An article of hers in the A tlantic at-
tracted the attention of several writers and
editors who suggested that she write a
book, and this suggestion changed the
course of her life. Not immediately, it must
be said, for though her articles had already
attracted many admirers, her personality
and the circumstances of her life prevented
her from moving with dramatic sudden-
ness.
"I am a slow writer," she once said, "en-
joying the stimulating pursuit of research
far more than the drudgery of turning out
manuscript."
Moreover, Rachel Carson, for all her
craving for privacy, was never free to act
utterly independently. Even in the hours
away from her demanding job at the Fish
and Wildlife Service, she had a home to
run. Though she did not marry, she cared
for her mother through most of her own
mature years and later adopted an or-
phaned grand-nephew. The first of her
books, Under the Sea-Wind, was published
late in 1941, but aside from some welcome
critical acclaim it went almost unnoticed
in the uproar that followed Pearl Harbor.
It was not until 1951 that the general
public came to share the admiration of
critics and scientists for Carson's many
skills. She had chosen as her subject noth-
ing less than the sea itself, and when her
book. The Sea Around Us, appeared, the
response stunned even this artist-scientist.
The book remained on the best-seller list
for 86 weeks, was picked up by book clubs
and magazines, and was translated into 33
foreign languages.
"Great poets from Homer down to Mase-
field have tried to evoke the deep mystery
and endless fascination of the ocean," the
New York Times said of her book. "But the
slender, gentle Miss Carson seems to have
the best of it. Once or twice in a generation
does the world get a physical scientist with
literary genius. Miss Carson has written a
classic in The Sea Around Us."
Though celebrity terrified her at first,
she learned to deal with it. She was one of
those writers who inspire affection as well
EPA JOURNAL
-------
as respect among her readers, and certainly
a reason for the painfully slow pace at
which she wrote her later books was the
bulky correspondence she insisted on re-
sponding to with courtesy and thorough-
ness. Moreover, she had the unique ability
to transform, through the alchemy of her
prose, cold scientific facts into the stuff of
wonder and delight.
"The pleasures, the values of contact
with the natural world are not reserved for
the scientist," she wrote. "They are avail-
able to anyone who will place himself un-
der the influence of a lonely mountain top
—or the sea—or the stillness of a forest;
or who will stop to think about so small a
thing as the mystery of a growing seed."
Carson's stature grew in succeeding
years with the re-publication of Under the
Sea-Wind and the writing of a new book,
The Edge of the Sea. A future full of honors
and tranquility seemed assured to her. But
late in the 1950's something began to gnaw
at her, a sense that events in the world had
taken an ominous turn, that mankind in its
ingenuity and arrogance had suddenly got-
ten hold of the power "to change dras-
tically—or even destroy—the physical
world."
Her own wide reading and her conversa-
tions with other scientists led her to focus
on the misuse of chemical pesticides as the
symbol of what had gone wrong. Only a
few years earlier those new chemicals,
especially DDT, had been hailed as human-
ity's savior, weapons that would finally
solve the age-old problems posed by
noxious insects and other pest organisms.
Massive doses of the new chemicals, often
spread by planes, became the prescription
for all pest problems. It became apparent
after a while that many kinds of animals
besides insects were affected by the chem-
icals, and, as Carson realized, no one had
any idea of their ultimate effect on the
foundations of life itself.
"I may not like what I see," she wrote,
"but it does no good to ignore it, and it's
worse than useless to go on repeating the
old 'eternal verities' that are no more
eternal than the hills of the poets. So it
seems time someone wrote of life in the
light of the truth as it now appears to us."
At first she had no intention of writing a
book about pesticides. She suggested the
idea to others, but got little response.
Eventually it became clear that she was the
leading candidate to tackle the subject,
for no one else had such excellent creden-
tials—her scientific background, her love
for the natural world, her writing skill and
her stature in American letters.
The "brief book'' on the subject that she
had envisioned grew as she began to dig
Rachel Carson Trust
Soon after Rachel Carson's death,
friends and colleagues with whom
she had discussed the possibility
formed the Rachel Carson Trust for
the Living Environment in 1965. Pur-
pose of the organization is to advance
her causes and philosophy by pro-
moting public interest in and knowl-
edge of our environment; encour-
aging enlightened conservation
measures; and serving as a clear-
inghouse of information for scien-
tists and the general public. The
trust's focus is chemical contami-
nation, especially from pesticides.
The trust is an independent, non-
profit scientific organization. Further
information can be obtained by writ-
ing to the Rachel Carson Trust for
the Living Environment, Inc., 8940
Jones Mill Road, Washington, D.C.
20015.
into the evidence that mankind had badly
misused these toxic substances. Despite
the fact that she was already suffering from
the illness that would kill her, she pushed
on for four years—reading, asking ques-
tions, writing and re-writing..When her
book. Silent Spring, was published in
1962, the uproar it caused and the influ-
ence it exerted was compared to that of an
earlier classic, Harriet Beecher Stowe's
Uncle Tom's Cabin.
Why was a writer who spoke out against
the contamination of the environment so
savagely attacked from many quarters? In
part it was because of the nature of her
subject. Chemical pesticides, used in the
right way, have been a valuable tool, in-
creasing agricultural production and pro-
tecting human lives. A number of men and
women of good will saw in Silent Spring
an attempt to turn back the clock, depriving
humanity of a weapon against pests at a
critical moment in history.
But Carson did not call for the abandon-
ment of all chemical pesticides. She asked
for a ban on the more insidious, long-
lasting chemicals like DDT, against which
there was increasing evidence of harmful
effects to many living things. She asked
also that the other chemicals be used more
judiciously and that the regulations for
their manufacture and sale be considerably
tightened. Finally, she asked that scien-
tists redouble their efforts to find alterna-
tive methods of fighting pests, such as bio-
logical controls, so that the flow of deadly
poisons into the environment might be
restricted.
Despite the initial flood of hostile criti-
cism, Carson's argument has stood the test
of time. As early as 1963, President
Kennedy's Science Advisory Committee
substantially supported her position that
pesticides were being misused in this
country. Laws and regulations have been
tightened, and most of the chemicals
whose use she criticized have been banned.
continued on page 38
Frank Graham, Jr. is author of Since Silent
Spring, an account of the impact of Rachel
Carson's book. He also is author of a book
on water pollution, Disaster by Default.
NOVEMBER/DECEMBER 1978
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Better
Government
Service
By Barbara Blum
EPA Deputy Administrator
One of the biggest problems we have at
the Environmental Protection Agency
is the suspicion—sometimes well-founded
—that the way we have to set up our regu-
lations, rules, procedures and paperwork
costs business, industry and local and
State governments more than it needs to in
time and money. We can do a better job of
cleaning up the environment, and get more
cooperation, or at least less opposition, if
we clean up our own regulatory act, too.
That is why regulatory reform is a very
important part of our job at EPA, and why
the friendly attention we got for one set of
those reform initiatives announced in
September is worth the notice of all of us
who are committed to a cleaner environ-
ment. We announced a streamlining of
pollution control permit procedures that
will save time and money for industries
that must undergo environmental reviews,
by making it clearer, sooner, just what has
to be done to get all the necessary permits.
What may be more important than the
details of what we did was the way we got
there. These changes did not start with a
blinding flash of inspiration here at head-
quarters. They began when an industrialist,
W. W. Dodge of Caterpillar Tractor, wrote
me last year to complain of the uncertain-
ties and costs involved in obtaining multi-
ple permits for building new factories.
What Mr. Dodge said made sense, and
we set up a task force with him and other
industry figures, representatives from en-
vironmental groups, and the officials here
who write and administer the procedures.
When we announced the results, Mr.
Dodge was with me in Washington to help
explain the results of our work and say how
they would reduce the costly uncertainty
industry faced with the previous lengthy
procedures.
These changes should be even more
valuable for smaller firms, less equipped
than big companies like Caterpillar to find
their way through what sometimes seem to
be bureaucratic mazes. First of all, in each
of our Regional Offices, one person will
keep track of all phases of a company's ap-
plication for pollution control permits. Only
thirty days will be allowed for the initial
review of applications, the review needed
to make sure they are complete, and a per-
mit tracking system is being set up to make
sure we act as swiftly as possible.
EPA and the companies involved will
meet early in the process to make sure that
the multiple permit requirements are thor-
oughly understood, and then at EPA we
will coordinate the review of the multiple
applications. Beyond that, we will work
with State and local governments to elimi-
nate unnecessary duplication where dual
requirements for permits exist.
In addition, we are working to develop a
single application form for the various per-
mits needed for the construction of plants
that will be new sources of air pollution,
the discharge of water pollutants, the treat-
ment and disposal of hazardous wastes,
the control of underground injection of
pollutants, and dredge and fill activities.
Because these permits are required under
several different laws, involving different
time requirements, a single construction
permit is not feasible, but we think we are
working toward the next best thing.
In developing these changes, the gov-
ernment listened—and found responsible
industry leaders eager to cooperate with us
once they knew we valued their experience
and insight. Without their help, we could
not have done the job.
This is one concrete example of how
regulatory reform has worked at the Envi-
ronmental Protection Agency—an accom-
plishment noted by the Washington papers,
the Christian Science Monitor, and con-
servative commentator James Jackson
Kilpatrick. We found ways to administer
the laws at less burden to American indus-
try, and at less burden to government—
thus at a saving to the American people in
both cases.
Our agenda for regulatory reform is
long, but another set of changes is well
advanced—a number of initiatives we
EPAJOURNAL
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group under the term "offset strategies."
Taken together, these concepts develop the
idea that not all methods for controlling
pollution are created equal, and that in-
dustry should be encouraged to find the
most efficient ways to do the job.
Taken in its simplest terms, the idea
behind this concept is that the total pollu-
tion in the environment is what matters, not
the sum from any individual machine or
smokestack. Thus, if a company wants to
build a factory with two processes, one of
which we have determined should spew no
more than eight pounds of pollutant per
hour into the air and the other no more than
twelve, we should find a way to allow one
to spew five and the other fifteen, if that is
more economical for the industry.
This, in simple terms, is an approach
whose implementation is getting easier
because the technology of measuring dis-
charges is improving. Allied with it are
several other concepts, such as allowing
an industry to "bank" pollution control
accomplishments beyond the minimum re-
quirements, so that it can be confident
future expansion or extra shifts will be
permitted.
We are looking into ways of trading or
selling those pollution control accomplish-
ments between industries in a given area.
And we have developed a policy where a
firm can build in a non-attainment area—
where air quality does not meet Federal
standards—even though it adds to the pol-
lution, if it can find some way of cleaning up
other pollution sources so that the totai
pollution is reduced, not increased, with
the addition of a new factory or plant.
There are many other elements of our
regulatory reform effort, from trying to
shorten time periods to what Doug Costle
calls "making English the official language
of EPA."
They have intrinsic merit, for there never
has been a good reason for government to
make people's lives more complicated than
necessary. They have a timely political
value, for the distrust of government shown
in various elections across the country in
1 978 needs to be dealt with constructively
or else it will be dealt with destructively,
again and again. And they have a particular
merit for this agency, which has been en-
trusted with a regulatory assignment that
will not be simple or cheap when we do
our best, the duty of administering a series
of laws that have imposed new and often
costly requirements on industry and gov-
ernment in a time of serious inflation.
We are not going to sacrifice the environ-
ment for any quick savings for the econ-
omy, or any small part of it. But a healthy
economy is a concern of environmentalists
just as seriously as it is a concern of indus-
trialists, for without resources, the expen-
sive job of cleaning up the environment
will be left incomplete. So whenever we
can find a way to cooperate with industry
and the others we regulate to save time,
money and jobs without damage to the
environment, we will. D
NOVEMBER/DECEMBER 1978
-------
The
Caretaking
Consumer
By Joan Martin Nicholson
Director, Office of Public
A wareness
Much of American capitalism relies on
two factors that are not given wide
consideration in the development of U.S.
economic policy. The first is the capital
provided by Nature—air, land, and water.
In his book Small Is Beautiful, E. F. Schu-
macher notes that modern economics,
which is so largely market-oriented, often
ignores human dependence on the natural
world.
The second fundamental of our eco-
nomic system is the consumer. In this
country, as in many industrial-urban so-
cieties, women have assumed the role of
chief consumer. As more of the world
moves from agrarian to industrial society,
what are the implications of this role for
women? And what impact will women have
on the natural systems and primary re-
sources that sustain life?
The ultimate well-being of this planet
and the people who inhabit it are intricately
linked to the role of women as consumers
in industrial societies.
In the past when America was largely an
agrarian society, women played a key role
in the production, refinement, and distribu-
tion of the food and other items that were
daily necessities. They worked as an im-
portant part of a family unit in the fields,
home, and marketplace, assuming a share
of the labor, responsibility, and the bene-
fits of the farm-based economy. The pro-
duction aspects of society were a part of
each woman's daily existence.
The "Women's Liberation" movement is
very much a protest against the loss of
these functions in women's lives. Our
technical-industrial society has isolated
women into "kept consumers." Many
women are seeking to balance the child-
centered, consumer-focused lifestyle with
a production-related, adult-oriented world.
Economic power in America particularly
determines the choices available to us,
which ultimately define the quality of our
lives. In highly industrialized societies, the
modern woman makes important economic
statements through exercising consumer
choices. Unfortunately, it has not always
been used effectively, for most women do
not perceive its implications.
What we consume determines which
natural resources are depleted and how
long these limited quantities will last. What
we consume also determines who is em-
ployed, and at what level of pay and skill.
What we consume determines our depend-
ence on imported resources, and our
supply of domestic resources. These re-
sources include the world's supply of fossil
fuels.
The wastes from the products we buy
often last long after we have finished using
them. Consumer habits determine which
wastes are returned to the Earth's natural
systems to be broken down and absorbed.
And the sad fact is that many places on
Earth are showing signs of severe stress.
They are no longer able to absorb and con-
vert these modern industrial wastes.
In our market-place we increasingly see
goods with built-in, planned obsolescence,
10
EPA JOURNAL
-------
requiring expensive repairs and skills.
There are items that cannot be recycled, or
which may and often do pose hazards to
human health. The question that arises
here is: How do women relate to it a 11 ?
Women are, by tradition, the caretakers,
the bearers of wide-ranging skills and
broad-range emotional systems. Somehow,
in the complexity of our frenetic modern
existence many women have lost sight of
their most obvious mandate—that of a
caretaking consumer.
Unfortunately as they become more
mobile in the world, and begin to enter
policy forums, even as a token force,
women tend to emulate the vocabulary of
men, to accept their definitions of the prob-
lems, and to adopt their structures for re-
solving the challenges that confront people.
But there are other ways of looking at
problems and dealing with them. Women
must redefine their role in these new times
and make better use of their consumer
power: the ability to decide when and
where the family will spend its money.
i ne credit card, the checkbook, and the
dollar should be perceived as ballots with
which to vote products in and out of peo-
ple's lives. The cumulative impact of their
choices as consumers determines the des-
tiny of their environment and the final price
that people will pay in determining the
duality of life.
While there is much positive work being
done around the world to meet human
needs, we should make certain that the
negative aspects of the U.S. market are not
exported to developing nations seeking
industrial and technological growth.
America has a moral obligation to share
our good fortune with other countries that
have traditions much longer than our own.
But we must also make them aware of the
potential abuses to land and people from
modern technology.
Women in the developing countries play
a significant role in landbased economies.
Unfortunately, some of these countries are
faced with the problem of multinational
corporations that create economic depend-
ence on their goods. Even in this country
we are just beginning to understand that
those goods have negative as well as
positive aspects.
The role of women in molding the future
is equally important in the less-developed
countries of the world. Many developing
nations are beginning to move toward our
technical-industrialized way of life. Mil-
lions of people face different choices, for
which they are ill-prepared, en route to
urbanization. The fate of those changing
societies pivots on the size and well-being
of the families who live within their bor-
ders, and the main determinant in those
families will be women.
According to John Gilligan, Administra-
tor of the Agency for international Develop-
ment, 87 percent of the world's population
will live in the less developed countries by
the year 2000. These people face an in-
creasing food deficit. The great majority
are subject to disease and malnutrition.
Some 800 million people are illiterate—
and most of them are women.
Gilligan notes the ties between educa-
tion, population growth, and economic
development. Birth rates decline when
women realize it isn't necessary to have so
many children to ensure help in the fields
and care for their old age. Also as people
increase their education levels, the number
of children per family declines. The change
especially accelerates with the education of
the mother. In Latin America, studies in-
dicate that women who have completed
primary school will average about two
children fewer than those who have not.
The AID administrator points out that the
education of women in developing coun-
tries is an imperative if population growth
rates are to be reduced.
Gilligan adds that the role of women in
Third World food production is directly
related to U.S. prosperity and security. It
is unlikely that the West will be able to
make up the difference in the world food
deficit projected for 1985. That will have
to be done by the millions of subsistence
farmers scattered around the globe—most
of whom are female. In many Third World
countries 40 to 70 percent of agricultural
labor planting, hauling water, tilling, har-
vesting, and marketing is done by women.
As more men are drawn to the cities and
factories by the lure of wealth, more of the
burden of food production will fall on
women. If they a re to cope with the bur-
geoning task of feeding increasing popula-
tions, many barriers must be crossed. Not
the least of these is the tendency of West-
ern development advisors to assume in
their assistance programs that all farmers
are men and to ignore women. Women
must be taught in these emerging lands to
use improved seed and fertilizers, irriga-
tion systems, and agricultural machinery.
They must have roads and transportation,
food processing and storage facilities, and
access to economic structures like credit.
A little education in nutrition and health
can go a long way, as well, in some deeply
impoverished areas where more food and
medical care may not be forthcoming soon.
According to AID, nutrition experts in
Africa found that in most villages women
could find the right food or combinations
of foods for their families if they knew
what to look for and how best to prepare it.
Likewise, an elementary knowledge of
sanitary precautions could prevent many
health problems.
Do American women, who are too often
"kept consumers" chasing a dream of the
land of plenty, have some moral obliga-
tions to these emerging cultures opting for
an industrial/technical society? The
answer is yes.
Technology, economics, employment,
energy, and the welfare of the environment
are part of the same web. The tradeoffs
among them determine the fate of each.
Each individual consumer should be able
to perceive that by foregoing certain levels
of natural resource indulgence, availability
of these resources for future generations
can be assured.
Who is to lead us in this new code of
group morality?
In the past, women have followed the
road to highly urbanized industrialized
living without evaluating for themselves
the implications of development. The con-
sequence is that there are few female
critics monitoring society's evolution from
a female perspective. And it is time women
assumed this role in society.
What are the options? In light of the
direct correlation between Earth's survival
and our own survival as a species, the
immediate need is for the massive educa-
tion of women about their potential as
"caretaking consumers."
How does one become a "caretaking
consumer?" When making a purchase
women might stop for a moment and con-
sider whether their choice of products will
influence these broader goals:
• Avoid or mitigate harmful impact on
the environment;
• Encourage beneficial impact on the
environment;
• Reduce consumption of limited nat-
ural resources;
Conserve limited energy resources;
Encourage the use of natural materials
or ecyclable products;
Avoid planned obsolescence;
Encourage self-sufficiency;
Protect life from toxic and carci-
nogenic substances.
Women are one-half of the population,
controlling more than one-half of the
wealth. But are women half of the eco-
nomic and political power structure? The
quality of human existence in the present
context says not. One woman acting alone
has little effect. But ten, twenty, or a
thousand women making educated choices
can turn consumer policy into social, politi-
cal, and economic statements about our
destiny as a people. Our environmental
future could well be determined by the
"caretaking consumer." D
NOVEMBER/DECEMBER 1978
11
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-------
Nursing Mothers
and
Environmental
Contaminants
By Molly Broughton Peter
The U.S. Environmental Protection
Agency is preparing a follow-up inves-
tigation of 1,500 women tested in 1975 as
part of a major study of pesticide residues
in mothers' milk.
EPA scientists now are looking into the
dietary habits of the women at the time of
their pregnancies to see if there was a cor-
relation between diet and pesticide levels
in breast milk. Using questionnaires, they
also will seek to determine whether the
children of the original test group have had
any pesticide-related health problems.
Since widespread use of synthetic pes-
ticides began in the mid-1940's there has
been a controversy among researchers
about the health implications of traceable
levels of chemical residues in human milk.
Scientists are concerned not only for the
women who carry these contaminants but
also about the effects they might have on
nursing infants.
Most researchers agree that it is ex-
tremely difficult to determine cause-and-
effect relationships between ambient ex-
posure to chemicals and health problems.
They would probably also agree that until
recently there have been limited methods
for assessing many environmental health
effects, particularly in dealing with low-
level dosages. People do not keel over after
one low-level exposure to most pesticides.
The hardest fact may be that this kind of
research has not been a priority within
Federal agencies or the medical research
community. More funds are needed for
monitoring and research. Because this type
of research takes so long, the sad news is
that we may not know much more in ten
years than we know now.
Since their introduction pesticides have
brought real benefits. Because of their
broad application, low cost, and effective-
ness they have been of great importance in
both agriculture and public health. Pesti-
cides have reduced diseases such as
malaria, yellow fever, and typhus. They
also have helped to increase crop yields by
reducing pests and protecting stored
food-stuffs.
Mother and Child by Mary Cassatt
However, one characteristic that some
pesticides, such as the chlorinated hydro-
carbons, have is persistence or longevity
in the environment. Because they do not
break down easily, some pesticides tend to
accumulate in the food chain, contaminat-
ing it at various levels. These residues are
a world-wide phenomenon. They have been
detected in virtually all animal tissues and
even in regions far removed from areas of
pesticide use. We are all exposed to pesti-
cides whether we live in urban, suburban,
or rural areas. The major routes of human
exposures are through food, air, and water.
When pesticides were found in mother's
milk, public concern naturally arose as to
what effect this might have on breast-fed
infants. The World Health Organization
calculates acceptable daily intake levels of
pesticides, and these levels are believed
sufficient to protect adults against chronic
poisoning by ingestion of pesticide resi-
dues in food. Although comparable accept-
able intake levels have not been calculated
for infants, they would probably be lower,
since immature livers are less able to filter
out these substances. EPA does, however,
generally consider those people (including
infants) whose diet is largely milk when
it sets tolerance residues for cow's milk.
Many early studies were limited to deter-
mining the presence of DDT in breast milk.
Most of the studies were based on rela-
tively few samples (some tests involved
only five women), and analytic procedures
varied widely.
What research is underway today in the
area of the health effects of pesticide resi-
dues? The following is a summary of the
major work being done. This new body of
research and monitoring may illuminate
new directions to be followed to resolve
the controversy.
In 1975 the Human Effects Monitoring
Branch of the EPA Pesticide Program be-
gan the largest survey program of its kind,
analyzing milk samples of 1,500 women.
The purpose was "to estimate the distribu-
tion of selected organochlorine pesticide
levels in human milk among nursing moth-
ers giving birth in general care hospitals
in the United States."
Factors taken into account in obtaining
samples were: the geographic distribution
of mothers, their age, occupation, race,
and whether anyone living in the household
was employed in a pesticide-related
industry.
The compounds analyzed in the study
were: DDT, dieldrin, chlordane, heptachlor,
heptachlor-epoxide, mirex, oxychlordane,
BHC. HCB, TransNonachlor and poly-
chlorinated biphenyls (PCB's).
The EPA found detectable levels of three
pesticide metabolites in the milk of the
nursing mothers. Dieldrin appeared in 80
percent of all the milk samples, heptachlor-
epoxide in roughly 63 percent and oxy-
chlordane in 74 percent.
EPA has since curbed the use of all those
pesticides. As a result of EPA's ban on DDT
in the early 1970's, these has been a sig-
nificant decrease in traceable levels of
DDT in fat tissues. This may also happen
in the cases of aldrin, dieldrin, heptachlor,
chlordane, and their metabolites in human
milk, since the Agency has now restricted
their use. These actions were not a result
of the breast milk study but rather because
of persistence, bioaccumulation and other
effects in animal testing and wildlife
studies.
EPA is awaiting the results of its follow-
up study of 1,500 women while the Agency
continues monitoring pesticide residues in
human milk.
The EPA monitoring program begun in
1972 also included PCB's, a carcinogenic
industrial chemical of growing concern
to researchers working in the area of
human milk studies.
Nine years ago more than 1,000 Jap-
anese were poisoned when they cooked
with rice oil accidentally contaminated
with PCB's. Their symptoms included
severe acne, temporary loss of vision,
darkened skin, and neurological disorders.
Dr. James Allen at the University of Wis-
consin Medical School has been studying
the effects of PCB's on infant rhesus mon-
continned on page 39
Molly Broughton Peter is a contractor to
EPA working on environmental health
issues with the women/consumer
constituency.
NOVEMBER/DECEMBER 1978
13
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Volunteerism
and the
Environment
By Mary DeCarlo
Two social forces have con-
verged to accommodate
women as leaders in protecting
the environment. Awareness of
the contamination and destruc-
tion of the natural environment
systems and resources launched
environmental interest groups.
Concurrent with that awareness
was the emergence of the
women's movement. Two ap-
proaches emerged in the envi-
ronmental movement. One is
voluntary and the other institu-
tional. Institutional support
came in such forms as the es-
tablishment of environmental
education curricula, research
programs, and institutes. Vol-
untary action'was the mode for
local resistance to environmen-
tally destructive practices.
From these forces women
have emerged as leaders in the
environmental movement. Be-
ginning with Rachel Carson
and her book Silent Spring and
continuing with the recent ap-
pointment of Ruth Clusen, who
was named Assistant Energy
Secretary for the Environment,
women have been prominent in
the articulation of issues related
to the environment.
Environmental activism is
also a logical transition point
for many women. Volunteering
in community work is a tradi-
tional sharing in the shaping
and defining of community
issues.
Matilda Koval watched her
Baltimore neighborhood deteri-
orate as the older ethnic popu-
lation moved out and those who
moved in took little pride in
Mary DeCarlo is the president
of the Volunteer Development
Institute, and an Associate
Professor in the volunteer ad-
ministration program atAntioch
University, Baltimore, Md.
caring for their homes, yards,
and streets. Instead of moving
out as she originally intended,
Koval decided to organize her
neighbors into a self-help proj-
ect for block-wide improve-
ment. For her, voluntary action
was more than working for an
organization. She created her
own volunteer job; in a sense
acting as a one-person volun-
teer association.
Neighborhood spirit runs
high in Baltimore, and Matilda
Koval, along with her newly-
mobilized neighbors, joined to-
gether with other like-minded
groups in Baltimore to obtain
money for neighborhood proj-
ects and increasedcity services.
Koval worked hard to improve
the physical environment of her
community and the city at large.
She worked to stop further
spread of polfution through en-
couraging code enforcement,
restoring land and water, cre-
ating playgrounds and parks,
cleaning up litter, getting rid of
rats, abating noise, and operat-
ing recycling centers.
Matilda Koval through per-
severance, motivation, and
enthusiasm inspired others. She
left behind her a testimony to
women as volunteers combin-
ing traditional concerns with
environmental activism.
According to the Task Force
on Women and Citizen Partici-
pation Report—completed for
the Alliance for Voluntarism—
studies found that women
tended to be better represented
on boards (policy-formulating
bodies) in environmental
groups than among other more
established agencies devoted
to education, health, and social
services.
The women's movement pro-
vided a new impetus for women
to assert leadership in behalf of
matters that affected the
quality of their lives.
National organizations such
as the League of Women Vot-
ers, American Association of
University Women, National
Federation of Business and Pro-
fessional Women's Clubs,
Association of Women in Sci-
ence, National Organization for
Women, Women's Active Alli-
ance, etc., are vital organiza-
tions drawing on the female
population. In some cases,
these organizations have major
study or work programs in the
area of energy and conserva-
tion. Some are doing contract
work on environmental issues
for EPA. A recent grant from
the Office of Solid Waste at
EPA has enabled the league of
Women Voters in seven com-
munities to inform, educate,
and involve citizens in a re-
cycling program that will con-
tinue through volunteer efforts
after the grant has run out.
The League, which has an
increasing number of members
who are men, is active in all
stages of policy formulation
locally, statewide, and nation-
ally. In addition to providing
support for environmental leg-
islation, League members have
published over fifty environ-
mentally-related pamphlets and
magazines as well as informa-
tion bulletins to awaken the
public to the environmental
issues facing this Nation.
According to Herta Loeser,
author of Women, Work, and
Volunteering, many women
have developed careers in vol-
untarism. Viewed as a con-
tinuum, a voluntary career may
progress through a hierarchy or
ranking system of positions in
voluntary action. For many vol-
unteers the opportunity to par-
ticipate may develop into a
general volunteer equivalent of
an occupational career. Often
as one progresses through a
volunteer career, skills are de-
veloped and reinforced that are
comparable to those found in
the mid- or upper-management
levels in paid organizations.
In much the same way, a
person moving up the volunteer
ladder assumes greater influ-
ence relative to organizing,
directing, or managing volun-
tary activity. A volunteer man-
ager may develop a technical
expertise in areas such as re-
search, finance, or public rela-
tions. The flexibility of the
volunteer activity allows for
the pursuit of individual pref-
erences.
Many women build on their
volunteer experience to develop
and create jobs which they in
turn occupy before moving to
other career opportunities. Jean
Crolius started her volunteer
career as an unpaid executive
director of a small preservation
organization. Simultaneously
she enrolled in the University
Without Walls (which is under
the aegis of the Union of Experi-
mental Colleges and Univer-
sities in Maryland). Her work
came tc the attention of the
Academic Dean at Goucher
College in Baltimore, Md., who
asked herto draw up a B.A.
program in Historic Preserva-
tion. This was one of the first
programs of this kind in the
country.
Jean Crolius continues to
serve as Vice President of Pres-
ervation Action, Inc., member
of the Board of Governors of
Citizens Planning and Housing
Association, head of the Balti-
more City Committee of the
l.-l
EPAJOURNAL
-------
Maryland Historical Trust, and
is continuing her education at
Antioch University where she
has developed her own indi-
vidualized course of study.
The social needs of this
country are beyond the capacity
of public funds to meet them.
The voluntary actions of indi-
viduals have served well to pro-
vide not only leadership, but
direct services, and have stimu-
lated policy alternatives, in-
creased accountability, and
public awareness.
According to the Survey of
Need for Volunteers commis-
sioned by ACTION, the need
for volunteers will continue to
grow. With regard to the future
roles of women in the environ-
mental movement, women's
groups and environmentalists
wil! increasingly participate to-
gether in ways that will move
consciousness from protection
to anticipation to prevention.
Women dedicated to volun-
tary action are increasingly
forming community coalitions
and formulating "plans of ac-
tion" to create an "environmen-
tal state of the community."
This will include increased sur-
veillance of the quality of the
air and water as well as issues
related to solid waste and toxic
substances. And in this way,
they will continue to educate
themselves, and obtain an in-
creasing awareness of the en-
vironment and the interrelation-
ships between those various
components affecting the com-
munity. This knowledge will
indeed continue to be an under-
pinning to government-citizens
dialogue about important
values.
Volunteers, working together
in community after community,
contribute much to a more
healthful environment.D
NOVEMBER/DECEMBER 1978
15
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Food Safety
and the
Consumer
By Carol Tucker
Foreman
Assistant Secretary of
Agriculture for Food
and Consumer
Services
There is a tendency for every
generation to think itself in
some sense unique. Perhaps
that is why we usually think of
the consumer movement as
something of recent origin. It
may be true that the term "con-
sumerism" has only recently
become part of the American
vocabulary, but the concern for
consumers and by consumers is
not something that suddenly
emerged on the national scene
in the 1950's.
Long before Ralph Nader first
appeared before a Congression-
al Committee, Senator Porter J.
McCumber of North Dakota
made the following statement
on the floor of the Senate: "One
of the prime objects in refer-
ence to the power of Congress
over interstate commerce is to
protect the people—not only to
protect their pocketbooks, but
to protect their lives." The year
was 1906, and Senator Mc-
Cumber was speaking in sup-
port of the proposed Pure Food
and Drug Law, a measure that
was passed and signed by
President Theodore Roosevelt
later that year. A broad-based
coalition of groups including
labor organizations, the Ameri-
can Medical Association, the
Federated Women's Clubs of
America, and the Consumers
League played an active role in
promoting and lobbying for this
landmark piece of consumer
legislation.
There is also a tendency for
us to think that many of our
present day problems are to-
tally new. A good example is
the mounting public concern
over the presence of chemical
adulterants in our food supply.
Without question, the dangers
of chemical additives, animal
drugs, and environmental con-
taminants have been greater
during the post-World War II
era than at any other time in
history. As EPA Administrator
Costte pointed out in the Sep-
tember issue of this Journal, we
have undergone a chemical rev-
olution in this country in the
past 30 years. This revolution
has made our society a "chem-
ical addict" and now poses
problems of the first magnitude.
It does not minimize the seri-
ousness of our present con-
cerns, however, to point out
that even at the time of the pas-
sage of our first national pure
food law, the driving concern
was the presence in the food
supply of harmful chemical ad-
ditives. We commonly associ-
ate the pure food law of 1906
with Upton Sinclair's The
Jungle, a vivid portrayal of the
filthy conditions in the meat
packing houses. But much of
the committee testimony lead-
ing up to passage of the bill
dealt with substances such as
boric acid, sulfuric acid, ben-
zoic acid, formaldehyde, and
potassium nitrate.
The final legislation reflected
the desire to keep the American
food supply free of harmful
chemicals. One of the key pro-
visions in the 1906 law prohib-
ited the addition of any sub-
stance that may be poisonous
or harmful to human health. The
strict language of this provision
has served the American con-
sumer well over the years. In
fact, the adulteration provisions
of the present meat and poultry
inspection acts have language
that is much the same as the
wording of the original pure
food law.
The situation facing us today
differs from the concerns of the
turn of the century mainly in
terms of the sheer number of
chemical contaminants that
have been found to threaten the
public health. The widespread
use of pesticides and animal
drugs in the post-World War II
era has brought the benefits of
agricultural abundance. But it
has also brought the threat of
harmful chemical residues on
fruits and vegetables or in meat
and poultry. For example, the
use of sulfa drugs in swine feed
has reduced illness in hogs and
has thus resulted in increased
pork production. However, we
have also found that 1 0 percent
of the pork going to consumers
contains sutfa residues that
may cause allergic reactions or
present long-term risks to
human health.
We have also found in recent
years that some additives once
thought to be safe and to serve
a useful purpose may, in fact,
be dangerous. Sodium nitrite
has been used for many years
as a curing agent in such popu-
lar products as bacon, ham, and
hot dogs. Scientists discovered
in the late 1960's that when
bacon is cooked, nitrite can
combine with other chemicals
to form substances known as
nitrosamines, which are potent
cancer-causing agents. More
recently, a study at MIT has in-
dicated that nitrites by them-
selves can cause cancer in lab-
oratory animals.
It seems as though we are
confronted almost daily with
new evidence of another haz-
ardous chemical in our food. As
a result, we are now hearing the
argument that our present food
safety laws are too rigid to deal
with the discovery of small
amounts of potentially harmful
chemicals. According to this
view, the law should be
changed so that only the high-
est risk chemicals are strictly
prohibited. It is true that mod-
ern science has made us aware
of an increasing number of haz-
ardous substances. But this fact
would seem to be an argument
for stronger food safety laws,
rather than the reverse. A dele-
terious chemical in the food
supply becomes no less delete-
rious simply because the law
no longer requires government
action to eliminate it. Unless
the government does act to
assure food safety, agricultural
producers as well as consumers
will suffer. Farmers will have
strong markets for their prod-
ucts only if consumers have
confidence in the safety of
those products.
The present laws on food
safety are strict, and there may
be other means of dealing with
the problem of dangerous
chemicals in food. But a better
way has not yet been demon-
strated. In the meantime, the
present law has been flexible
enough to enable the Depart-
ment of Agriculture to launch a
cooperative program with farm-
ers that should result in the
elimination of sulfa residues in
pork. It has also enabled us to
take regulatory action to reduce
significantly the amount of
nitrite in bacon. In a joint effort
with FDA, we also are now for-
mulating a regulatory course to
eventually phase out entirely
the use of nitrite as a food
additive. In sum, the present
food safety laws put us in a
strong position to take the effec-
tive action that an increasing
number of consumers are
demanding.
Some argue that consumer
sovereignty in the market place
should permit consumers to
purchase anything, no matter
what its health effects. But in
other areas, the Federal govern-
ment does not fall back on that
argument as a way out of its
responsibilities. The Federal
government regulates danger-
ous or toxic chemicals. We
attempt to control water and air
pollution. Government funds
the construction of municipal
sanitation systems. Federal pro-
grams help protect people
from disease via vaccination
and inoculation campaigns.
Government should play a no
less responsible role in the food
system. D
16
EPAJOURNAL
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Environmental Almanac: November/December 1978
A Glimpse of the Natural World We Help Protect
Living
with the
Kudzu
As one of the world's most vig-
orous plants rests through
the winter months its networks
of tangled brown vines keep
{heir grip on the red earth and
nearby trees and telephone
poles along thousands of miles
of Southern roadways.
With the return of spring
temperatures and more direct
sunshine the Kudzu, a vine
imported from the Orient, will
once again begin its astounding
growth.
The introduction of this plant
provides a classic illustration
of the need for careful study of
an import's overall environ-
mental impact.
The Kudzu was brought to
the U.S. a century ago and
planted in the Florida pan-
handle. From there it has
gradually spread over about
one million acres of land in the
Southeastern States.
At first the plant, which can
grow as much as one foot a
day and 1 00 feet in a year, was
regarded as a savior of the
South. Its advantages included:
The growth of great billow-
ing waves of Kudzu washing
over fields and highway em-
bankments helped control soil
erosion.
The vine, a member of the
legume family, helped fix
nitrogen in the soil.
Cattle, goats and other
livestock would eat this plant.
Its deep-probing roots help
aerate the soil.
For many years it was
regarded as a miracle crop that
would help restore the South's
worn and eroded soil. Conser-
vationists and others joined in
a crusade to help promote
distribution of this marvel
crop.
One of the plant's main
boosters was Channing Cope,
former long-time agricultural
editor of the Atlanta Constitu-
tion, who proclaimed "Cotton
isn't king here any more.
Kudzu is King."
In the 1950's, however,
farmers began to become dis-
illusioned with this exotic crop.
They noticed after the vine was
planted it often began to
intrude into neighboring fields
where it ruined other crops.
Telephone poles were some-
times pulled down by the vine
and power companies were
forced to spray Kudzu with
herbicides periodically to
prevent it from climbing high-
voltage towers, and causing
damage.
Good lumber and pulpwood
trees were destroyed when the
thick foliage on the climbing
vine shut off the sunlight
needed for growth.
Also substitutes were found
which were considered better
than Kudzu for pasture and soil
erosion control.
However, by the time culti-
vation of the vine had stopped
it had leapt fences and run
wild. There are parts of
Mississippi where highways
slice through countryside so
completely enveloped with
Kudzu that all other vegetation
has been killed. A traveler feels
he has entered another and
somewhat ominous world.
James Dickey, the noted
Georgia poet, referred to the
plant in his poem "Kudzu" as
"green, mindless, unkillable
ghosts." The poem states:
"In Georgia, the legend says,
That you must close your
windows
At night to keep it out of the
house,
The glass is tinged with
green,
even so . . ."
In areas where it is necessary
to control the plant, along
highway right-of-ways, for
example, the Kudzu is mowed.
The chemical 2-4-D is also
frequently used to check the
spread of this plant.
Gale A. Buchanan. A former
editor of the magazine, Weeds
Today, and agriculture pro-
fessor at Auburn University,
has conducted many experi-
ments on controlling the pfant.
Regarding the future of
Kudzu, Buchanan said: "I don't
see it taking over much more
territory. I think it has probably
reached its limits. It is a
problem along highways, but
not in cultivated fields where
cows, for example, can kill it
by over-grazing. However,
cows can't chase it up tele
phone poles.
"There art: chemicals and
other control measures that can
be used to keep it in check.
The level of effort: being made
now to control it is probably
adequate. The lesson we need
to learn from the Kudzu
experience is how careful we
must be about importing new
plants into our environment."
—C.D.P.
NOVEMBER/DECEMBER 1978
17
-------
Regulatory
Council
Goals
The new Regulatory Council will help
meet statutory goals at minimum
economic costs and regulatory burden
without undermining the Administration's
commitment to the protection of public
health, safety, and the environment.
This explanation was given by EPA
Administrator Douglas M. Costle after he
was named by President Carter to his
second high Federal post—the chairman-
ship of the new Council that will monitor
the economic effects of government
regulation.
The President said that Costle will head
the Council until Jan. 1, 1980, and that
during that period he will continue as EPA
Administrator.
The Council is part of the anti-inflation
package President Carter recently adopted.
In announcing the creation of the Council,
Carter said it "will help inform me, the
public, and the Congress about the
cumulative impact of regulation on the
economy."
To help in this key job, the Council will
publish twice a year a calendar of govern-
mental regulations, listing their goals,
benefits, legal requirements, and expected
life, along with available estimates of
economic impacts. The first calendar will
be published by February 1, 1979.
At a press conference after his appoint-
ment, Costle said that the Council will be
"an important new tool for managing the
government's overall regulatory program."
He added that the President had per-
sonally assured him of his strong support
for better and more informed government
action while protecting regulation's social
goals.
Asked what he would like the Council
to accomplish over the next 18 months,
Costle said first would be gaining more cost
effective regulation; second, getting the
regulatory job done that Congress directed;
and third, be forthright in suggesting
changes in the regulatory mission where
needed.
While pointing out that the Council is
just getting started, Costle gave his
"preliminary thoughts" on its strategies.
"The first important step is to get a
good grip on what is going on in Federal
regulation," the Administrator said. He
called it finding out "where ail the moving
pieces are."
To get informed, the Council will give
top priority to the calendar of major
regulations, giving the President and the
public for the first time a comprehensive
list of proposed Federal rules.
Second, Costle saw the need for the
Council to identify areas of potential
duplication and overlap in regulations,
coordinate efforts to eliminate such dupli-
cation, and pinpoint opportunities for joint
development of rules.
Third, Costle said the Council will
address issues and problems that require
cross-agency attention or resolution. These
include combined economic impact on
specific industries, opportunities to share
data and information and thus reduce
reporting burdens on industry or State and
local government, and consistency of
agency policies.
For example, Costle pointed to the need
for a consistent national policy for the
regulation of carcinogens.
Costle emphasized that the Council
can't interpose its own suggestions where
a Federal law has prescribed a certain
approach. But where there is flexibility, he
expected the Council to be "quite
influential" in regulatory decisions.
However, "none of this means we are
going to use a meat ax on the body of
Federal regulation," he said. Regulations
implementing acts of Congress "have
brought us some very important successes
in recent years."
For example, the Administrator noted
that the Nation's air today has half the dirt
in it that it had in 1970, and that rivers
that were contaminated in some instances
are now open to fishing and swimming.
Turning to another concern, Costle said
that while regulation's impact on inflation
will be considered by the Council, it won't
be the "sole emphasis."
Regulation imposes costs, Costle said,
both on the government which designs and
enforces the regulations and on cities,
States, industries, and businesses. But
these costs are not inflationary if the
benefits exceed the outlay.
For instance, he cited rules requiring
power plants to stop emitting sulfur
dioxide from their smokestacks. "If those
near the plant save more through reduced
medical care charges, less crop loss or
lost wages than they pay in higher electric
bills to amortize the investment in smoke-
stack scrubbers, clearly the regulations
are not inflationary."
But regulations can be inflationary in
certain cases, Costle added. One example
would be if costs exceed benefits. Another
would be if costs are greater than needed
to do a job. For instance, when many
communities did not permit the use of
plastic pipe, homeowners were forced to
use expensive, sometimes scarce,copper
pipe.
Such inflationary problems will be on
the Council's agenda, Costle said, along
with opportunities to use regulatory
authority to do a better job of attaining
national goals that laws seek to achieve.
The Council will be made up of repre-
sentatives of all Executive Branch
departments and agencies with major
regulatory responsibilities. Independent
regulatory commissions will be invited to
participate.
18
EPAJOURNAL
-------
A New
Direction in
Interagency
Cooperation
By Douglas M. Costle
EPA A dministrator
Showing the scope of Federal regula-
tory activity, Costle said there are now
more than 1 79 rulemaking bodies in the
government, with 120 in departments and
59 outside, including EPA.
The idea for the Council grew from
cooperative, ad hoc arrangements among
several Federal regulatory agencies. One
key source is the Interagency Regulatory
Liaison Group, with four health agencies,
including EPA. The EPA is recognized as
a leader in regulatory reform.
The job of directing the new Council
will "consume a great deal of my time,"
Costle told the press conference. "I am
just going to put in extra hours." But,
he added, he has very able Assistant
Administrators and a very able Deputy
Administrator to help in the EPA
responsibility.
Looking at Federal regulations over the
long range, Costle said the Council
represents "a logical and necessary next
step."
With the piecemeal growth of regulatory
authority over the last decade, in response
to serious national problems, a vast number
of regulatory programs has been built up,
Costle pointed out. Now, he said, it is
important to have "a clear overview of the
full range of regulatory activity by the
Federal government and be in a position
to recommend informed practical reforms
and improvements."
Explaining the regulators' role in the
overview effort, Costle said, "we've got to
involve the people who are themselves
doing the regulating, who are responsible
day to day for running regulatory
programs."
"President Carter established the
Regulatory Council because he believes
we can, over time, do a better job of
regulating, and at less cost," Costle said.
"I share that belief, and I arn honored that
he has made me the Council's first
chairman." d
Nearly a year and a half ago the heads
of four Federal agencies sat down
together at lunch to see if there were some
way to coordinate the implementation of
the numerous statutes that their agencies
are responsible for carrying out. In time, I
would expect that everyone reading this
article will be affected in some way by the
outcome of that luncheon.
The four agency heads included myself;
Eula Bingham, Assistant Secretary of Labor
in charge of the Occupational Safety and
Health Administration (OSHA); Don Ken-
nedy, Commissioner of the Food and Drug
Administration (FDA); and John Byington,
Chairman of the Consumer Product Safety
Commission {since replaced by Susan
King).
Each of us had some very challenging
laws to implement, particularly where
those laws dealt with controlling toxic and
hazardous substances. The President, in
his Environmental Message of May, 1977,
had emphasized the importance he placed
on dealing with such substances. But none
of us was confident about getting together
the resources needed to do the job. Faced
with these common problems and common
goals, the four of us agreed to pool our
resources and coordinate our programs in
order to mount the most effective attack we
could with the limited resources available.
We set up a coordinating body com-
prised of two high-level people—who were
to act as "surrogates" for each of us—
from each agency, and gave it the title of
the Interagency Regulatory Liaison Group,
orlRLG.
The surrogates launched an intensive
round of meetings during which they
wrestled with such questions as the feasi-
bility of establishing common testing
standards; the feasibility of a common
approach to assessing the risks posed
by toxic and hazardous substances; the
possibility that all the agencies could regu-
late specific substances in a consistent
way; and many more. Generally, the
surrogates set in motion a broad-scale
effort to identify areas where the four
agencies could best cooperate, with the
basic aim of making each of their programs
more effective while reducing the unneces-
sary costs resulting from duplication of
effort.
On the basis of this initial work, we
agreed to establish eight interagency work
groups. Each was assigned the responsi-
bility for promoting cross-agency consist-
ency in one of the following issues: testing
criteria and policies, risk assessment,
information collection and exchange, re-
search and development policies (possibly
including methods of sharing costs and
facilities), joint regulation and regulatory
development activities, compliance and
enforcement procedures and policies,
public communication and education, and
epidemiological practices and procedures.
Since setting their initial goals, each of
the work groups has been meeting fre-
quently throughout the year. Each surro-
gate works with one of the work groups,
and my three colleagues and I each sit on
two of the work groups. The eight surro-
gates also meet weekly to ensure that the
IRLG efforts are progressing smoothly, and
my colleagues and I meet at least once a
month on IRLG matters.
NOVEMBER/DECEMBER 1978
19
-------
At the same time that we were setting up
this structure in Washington, similar
relationships were being established in
each of the regions. We believe that some
of the IRLG's most significant accomplish-
ments will occur as our field offices share
laboratory space, coordinate inspection
and enforcement efforts, share technical
expertise, undertake cooperative public
education programs, coordinate their re-
sponses to emergency situations, and so
forth.
The fruits of our efforts are beginning to
appear. They should become more and
more evident over the coming months.
Here are some examples:
• The Testing Standards and Guide-
lines Work Group has already completed
five draft guidelines. These are now being
reviewed within each of the agencies, and
eight more are expected to be completed
soon. By establishing testing procedures
that are acceptable to all four agencies,
the confusion facing private firms that
submit test data to more than one of our
agencies should be substantially reduced.
• The Research Planning Work Group
has completed an inventory of all toxic
substances research being supported by
the four IRLG agencies and three research
institutes—the National Cancer Institute,
National Institute for Environmental Health
Sciences and the National Institute for
Occupational Safety and Health. The group
has also done detailed analyses of research
efforts in both the toxicology and metals
areas. Partly as a result of this work, EPA
and FDA have agreed to establish a joint
neurotoxicological program in North
Carolina.
• The Information Exchange Work
Group has sponsored a series of studies on
how we can improve the exchange of infor-
mation among the agencies. A lack of com-
munication was one of the more serious
problems we turned up when we created
the IRLG. In an effort to correct it, the work
group is investigating the possibility of
developing a regulated chemicals direc-
tory, which would provide information on
all toxic substances regulations, standards,
and guidelines in the four agencies.
It's also studying the idea of developing
common codes for chemicals and other
products. In addition, the use of common
codes for business firms is being tried in
one of the regions where the four agencies
operate. The idea is to make it possible to
cross-reference permits, inspections, and
information given to businesses or plants
by the different agencies.
• The Compliance and Enforcement
Work Group is developing a nationwide
"hot line" system to improve the Federal
response to such chemical emergencies as
the Kepone incident in Virginia and the
problem with chemical wastes dumped
in the Love Canal near Niagara Falls in
New York. This group, working with agency
field offices, is also looking at possibilities
for making use of one another's inspectors.
Cooperation of this kind offers a promising
avenue for making our programs substan-
tially more effective with little increase in
cost.
• The Regulatory Development Work
Group has collected the regulatory devel-
opment plans for 24 different substances
from different agencies. It is devising ways
to make sure that the agencies are aware
of one another's efforts on each of these
substances and that the efforts are coordi-
nated. It's also looking at how the agencies
can coordinate the way they set priorities
in such areas as: responding to petitions
for rule-making; conducting joint public
hearings; and determining the most appro-
priate laws to rely on in rule-making
actions.
• The Education and Communications
Work Group is developing general curricu-
lum guides on hazardous substances for
schools. It has also been coordinating pub-
lic information efforts on the regulation of
hazardous substances.
• The Epidemiology Work Group is
preparing a directory of epidemiology pro-
grams and personnel in the government. It
has also been drawing up guidelines for
conducting epidemiological studies, and
will prepare a dictionary of all epidemio-
logical research supported by the Federal
Government.
• The Risk Assessment Work Group
has been developing detailed guidelines
for the assessment of cancer risk. This will
be used by all four agencies in making deci-
sions about whether a particular chemical
substance should be regulated. This proj-
ect may be the most ambitious one pres-
ently being completed. It would require the
agencies to conform to a common set of
principles even though they are dealing
with different situations, and often are
working with different requirements in
their respective laws.
So far, some of the most evident progress
has been in the agency field offices,
which is in fact where we hope for some of
the biggest gains. The fact that agencies
are working more closely together is
reflected both by day-to-day communi-
cations, and by the fact that they are par-
ticipating in one another's management
meetings at the field-office level.
20
EPAJOURNAL
-------
There are a number of cases where field
laboratory work is being carried out jointly,
and where cross-agency inspection refer-
rals are occurring. Another source of po-
tential savings is the idea of combining
small field offices that the individual agen-
cies are now supporting in areas such as
Alaska.
In addition, there has been a substantial
improvement in alerting of all the affected
agencies about emergency spills and other
emergency health problems in several re-
gions. Before the IRLG, an agency such as
FDA might not have been told by EPA if a
hazardous spill occurred in a stream. Now
it's informed promptly, so that FDA offi-
cials can move quickly to make sure the
spill doesn't contaminate the water used,
for example, by a downstream food proc-
essing plant.
These are only some of the accomplish-
ments we are beginning to see as a result
of our luncheon in the summer of 1 977.
We expect to see many more in the months
ahead. And the idea is catching on. Mon-
tana, for instance, is working out an IRLG
arrangement at the State level. We hope
other States will follow suit.
We realize that there are still a number
of problems to overcome. Our progress will
not be as fast nor as extensive as some
might have wished. But these cooperative
efforts will make each of our agencies more
effective, and they will save the government
money.
I think it's clear that the four agency
heads remain as committed as ever to the
goals established a year ago. We intend to
continue to push our agencies to realize
the advantages that improved cooperation
can bring. And we look forward to a time
when every employee in our agencies, in
all of his or her work, will automatically
think of how it should be coordinated with
the other three agencies, and how this
coordination will make the job easier and
the results better. D
OSHA and the
American
Working Man
and Woman
By Eula Bingham
Assistant Secretary of Labor
Occupational Safety and
Health
Perhaps never in history have the aver-
age American working man and woman
faced a more conflicting world than they
do today.
On the one hand, the chemical revolution
since World War II has radically changed
lives. We take for granted the conveniences
it has made possible—from polyester knits
to pest-free crops.
But all of us, especially those in our
mills, factories, and various plants, are
aware of the price being paid for this
"progress." Thousands of new chemicals
have been poured into the workplace and
into our air, water, and soil without testing
for health effects and without understand-
ing their ultimate impact on the environ-
ment.
Almost invariably, the workers who pro-
duce and handle hazardous substances are
the first and worst exposed. At least
100,000 working men and women die each
year from occupational diseases.
Sometimes the link between the job and
disease is clear. A rare form of liver cancer,
angiosarcoma, is directly related to vinyl
chloride. Mesothelioma, a cancer of the
lining of the lung, is caused almost exclu-
sively by exposure to asbestos. Benzidine
has been indicted in cases of bladder can-
cer. Coal dust and cotton dust are respon-
sible for "black lung" and "brown lung"
diseases.
Often the cause-and-effect relationship
is clouded by the combined effect of mul-
tiple exposures. One substance, for exam-
ple, may increase the carcinogenic or other
toxic effects of a second substance. As-
bestos workers who smoke are eight times
more likely to get lung cancer and cancer of
the esophagus than those who don't smoke.
Moreover, many experts in the field fear
that present-day knowledge represents
only the tip of the iceberg. Results of ex-
posure to some substances, particularly
carcinogens, do not become evident for 1 5
or 20 years or even longer.
Far too often in our modern age, OSHA
is alerted to a hazard through the suffering
of a specific group of workers. For example,
animal studies some number of years ago
strongly suggested that vinyl chloride was
harmful. But it took a dramatic announce-
ment in 1974 about workers dying from
liver cancer to convince us of its devasta-
ting effects.
More recently, we witnessed the trag-
edies of workers poisoned by the
pesticides Kepone, leptophos and DBCP. In
the past few months, a chemical catalyst
used in the manufacture of polyurethano
foam products has caused physiological
and neurological problems among workers
in Maryland and Massachusetts.
Far too many workers surfer from pro-
gressively disabling and often fatal lung
diseases caused by asbestos, silica, beryl-
lium, cotton and coal dusts. The retired
cotton mill worker in South Carolina whose
lungs are so weakened that he or she can-
not walk a block is every bit as much a
workplace victim as is one suffer ing from
occupational cancer.
NOVEMBER/DECEMBER 1978
21
-------
Pulmonary sensitization, though rarely
fatal, profoundly affects the lives of many
workers. Skin sensitization is a source of
chronic discomfort or worse for thousands
of workers who handle corrosive and
irritant substances.
Usually considered minor annoyances,
skin problems consistently are the leading
cause of lost work time. In addition, there
is evidence that skin absorption is a major
route of exposure for many toxic sub-
stances. Sterility, caused by the fumigant
DBCP, for example, is suspected of result-
ing from absorption through the skin and
lungs.
Unfortunately, occupational illness does
not stop at the factory gates. Wives and
children and other relatives of asbestos
workers have died of cancer from exposure
to asbestos on work clothes. Children of
some lead workers, exposed to dust on
their fathers' clothes and shoes, have high
levels of lead in their blood. Wives and
children of Kepone workers in Virginia be-
came ilS; communities surrounding copper
smelters have unusually high rates of lung
cancer, possibly because of arsenic in the
air.
Occupational disease extends even to
future generations. The National Institute
for Occupational Safety and Health, for
example, estimates that of the 16 million
working women of childbearing age, about
one million are exposed to chemicals that
could harm their unborn children.
Reproductive hazards, however, are not
limited to women. Lead, Kepone and
DBCP can cause sterility and impotence in
men. Both sexes are susceptible to genetic
damage that can show up as a birth defect
in their children later on. Evidence shows
that the wives of workers exposed to lead.
vinyl chloride, and anesthetic gases used in
hospital operating rooms often have higher
than average rates of miscarriages and
birth defects among their children.
We at OSHA feel we can no longer
afford simply to react to occupational and
environmental damage. We must shift the
emphasis from cleaning up after the fact to
preventing exposures from happening. The
pace has been too slow. During its first six
years, OSHA issued only four major health
standards—covering asbestos, vinyl chlo-
ride, coke oven emissions and a group of
14 carcinogens. We have increased the
tempo significantly and set standards to
protect workers from exposures to DBCP,
benzene, acrylonitrile, inorganic arsenic
and cotton dust. A new standard for inor-
ganic lead is expected in the near future.
But it has become obvious that setting
standards for one substance at a time will
not contain the threat of the ever-growing
number of toxic substances. About 2,000
of the 30,000 commercially available
chemicals are suspected of causing cancer,
but only a few hundred have been ade-
quately tested. Moreover, industry begins
using a new potentially hazardous chemi-
cal every 20 minutes.
OSHA currently is in the midst of devel-
oping "generic standards" for controlling
all work-place cancer-causing substances.
The proposed policy, will establish a sys-
tematic way for identifying, classifying and
regulating all potential carcinogens in
American workplaces so that OSHA can
respond with greater speed and efficiency
to these threats to worker health.
Cancer, of course, is one of our greatest
concerns since despite our medical ad-
vances, the death rate from cancer con-
tinues to increase. More than 1,000
persons a day die from cancer, making it
the second greatest cause of death in
America. But atthe same time, the World
Health Organization estimates that from 60
to 90 percent of the ca ncer cases are
caused by environmental factors and that
at least 10 percent are thought to result
from exposure on the job.
OSHA also is developing a generic
standard to protect workers who produce
the more than 33,000 registered pesticides
in this country. Also, an advisory commit-
tee has been formed to study skin hazards
and recommend a work practices standard
for the safe handling of irritant and corro-
sive agents.
OSHA currently is preparing a standard
that will require all hazardous substances
entering the workplace to be clearly identi-
fied and labelled. Employers will be re-
quired to inform workers about the dangers
they face.
In the drive for a better informed popu-
lace, OSHA has awarded $6.4 million in
grants to labor unions, universities, trade
associations, citizens groups, and other
non-profit organizations to help develop
health and safety programs.
Within the Federal government, OS.HA
and the three other regulatory agencies
with similar problems and goals—the
Environmental Protection Agency, the Con-
sumer Product Safety Commission, and
the Food and Drug Administration—are
working together to share information, to
avoid duplication of effort, and to make
sure that serious hazards aren't overlooked.
OSHA also is in the midst of revising its
various standards. We have revoked more
than 1,100 provisions in the general in-
dustry standards which have little or noth-
ing to do with worker safety and health.
Other OSHA standards for agriculture,
construction and the maritime industry are
being reviewed. Q
22
EPAJOURNAL
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Consumer
Safety
and
Regulation
By Susan B. King
Chairperson, Consumer Product
Safety Commission
In 1971, the National Commission on
Product Safety found that 20 million
injuries, resulting in 30,000 deaths and
110,000 permanent disabilities were asso-
ciated with the use of consumer products.
The National Commission also concluded
that many such injuries could be avoided.
These findings prompted the Congress to
pass the Consumer Product Safety Act and
create the Consumer Product Safety Com-
mission. The five laws we administer give
us broad powers and a variety of regulatory
tools to promote product safety and reduce
needless deaths and injuries from product-
related hazards.
While the primary aim of the Commis-
sion is to protect consumers we are not un-
aware of the complications that can arise as
a result of government regulations. The
Commission is working to reduce the bur-
den of government regulatory actions
through our active and fruitful involvement
in the Interagency Regulatory Liaison
Group. The group consists of this Com-
mission, the Environmental Protection
Agency, the Food and Drug Administration,
and the Occupational Safety and Health
Administration. These agencies came to-
gether to coordinate activities in the area
of toxic substances/chemicals. We are
working to share information, to avoid
duplication, and to develop consistent reg-
ulatory policy. The positive actions taken by
these agencies cannot help but reduce con-
fusion and potential adverse impacts on
business and industry. Common problems
can be identified and addressed jointly,
thereby conserving the resources of alt of us
As we work to minimize problems
caused by regulation it is appropriate and
necessary that we take a long hard look at
what we have tried to do, and to evaluate
where we have failed or succeeded,
and why.
Last spring, rumors began to appear in
the papers that there were plans to abolish
the Commission and transfer its functions
elsewhere. While the agency has been
criticized in the past—some of it war-
ranted, much of it not—this proposal
seemed to us to be both ill-conceived and
ill-timed.
I am happy to say that President Carter,
several key members of Congress, repre-
sentatives from business and industry, and
the consumer organizations all came to the
defense of the Consumer Product Safety
Commission. They recognized that con-
sumer safety regulation is essential and
that the Commission has the independence
and authority to en sure the public gets the
protection it needs. After three days of
Senate Commerce Committee hearings and
public testimony from many witnesses, it
became apparent that Congress was not
interested in abolishing the agency but
rather wanted to give the newly constituted
Commission a fair opportunity to prove
itself.
Today, the CPSC is the only Federal
agency whose primary purpose is to
protect consumers from unsafe products in
their homes. Obviously, there are other
agencies, like the FTC, that have strong
consumer affairs programs, but we are the
only organization concerned exclusively
with consumer interests.
The legislation that created the Commis-
sion transferred existing product-safety
responsibilities from the Commerce De-
partment, the Federal Trade Commission
and the Food and Drug Administration.
It also gave the new 5-member commission
the mandate to reduce "unreasonable risks
of injury associated with consumer
products."
The Commission has the power to:
• set mandatory product safety stand-
ards, using procedures which fully involve
consumers and outside parties;
• ban products from the marketplace
when a safety standard would not ade-
quately protect the public;
• act quickly if the hazard is imminent
and remedial action cannot await lengthy
administrative proceedings;
• require industry to take corrective
action, such as repairing, replacing, or
refunding the purchase price of a product,
or providing public notice if the Commis-
sion finds it presents a substantial hazard;
• work with industry to foster voluntary
safety standards;
• issue informational, educational, or
warning materials to consumers to aid
them in selecting products and using them
safely.
Over the past five years, the Commission
has been involved with product recalls
affecting over 7 million individual items,
from toys to electrical appliances to flam-
mable clothing. The agency has banned
products such as flammable contact adhe-
sives, unstable refuse bins, and certain
products containing asbestos, which may
cause cancer. We have issued safety stand-
ards for products such as matchbooks and
architectural glass such as that used in
patio doors.
NOVEMBER/DECEMBER 1978
23
-------
Regulatory
Reform and
FDA
By Donald Kennedy
Commissioner, Food and Drug
Administration
Unfortunately, we can't always quantify
the impact of our activities. We can't
always engage in the numbers game that so
many people like to play. We have no way
to measure how many accidents didn't
happen, or how many deaths were avoided.
We do know, for example, that 34% fewer
children accidentally ingested poisonous
substances. As a result, as many as 200 to
300 children's deaths were prevented be-
tween 1973 and 1976. We believe this to
be attributable in large measure to the
Commission's administration and enforce-
ment of requirements for childproof
closures on prescription drugs, many over
the counter drugs, and a number of dan-
gerous household products. However no
financial benefit can be directly tied to this
accomplishment.
Right now, inflation is a matter of enor-
mous concern, and it is a very real and
serious problem. It is also apparent that
government regulation has been singled
out, by critics in both the public and private
sectors, as a major cause of inflation. More
importantly, a chief target of inflation
fighters seems to be safety, health, and
environmental areas. Why? Is it because
these activities are among the largest and
most burdensome activities ever under-
taken by government? Certainly not.
Outlays for public health and safety pro-
grams comprise less than one percent
of this year's Federal budget.
It is particularly inappropriate, in rny
view, to single out safety, health, and en-
vironmental regulations as targets right
now. Take this Commission as an example.
We focus on hazards which are serious,
often unforeseeable and often unavoidable.
Market forces do not operate to ensure
consumer protection from unsafe products.
We've learned this lesson over and over
again. The costs imposed on industry to
ensure product safety may in some in-
stances be high. But what of the costs to
society associated with the deaths and in-
juries caused by unsafe products? What
does it cost to replace a home destroyed by
fire caused by old technology aluminum
wiring? What cost shall we assign to each
person who surfers or dies from cancer?
We should all be aware that if consumer
protection activities are cut back, we will
all bear the costs in other ways.
Ultimately, the bottom line question be-
comes one of how, and when, certain costs
will be distributed in society. Health
and safety regulation is by definition pre-
ventive in nature. It may be expensive, but
so is treatment after the fact, as we are
learning the hard way with regard to some
modern chemicals. In sum, I believe we
have a responsibility to anticipate problems
and to prevent potential tragedies to the
greatest degree possible. I also believe
that business and industry share in this
responsibility.
It is critical that, in trying to deal with
the legitimate questions of government
waste, duplication, and over-regulation,
we not throw the baby out with the bath-
water. We have come to the end of an era
in which we viewed our resources as in-
finite, and no problems unresolvable if
only sufficient governmental money and
muscle were applied. Uncle Sam is no
longer Uncle Deep Pockets.
We recognize an obligation to attempt to
understand and better define the relation-
ships between the separate entities of
burdens, risks, and benefits. This can only
result in better decisionmaking. We intend
to carefully consider the benefits and bur-
dens of our actions, and we can promise
you that we'll be fair, reasonable, and
rational. We also intend to be tough where
toughness is called for. [71
This article was excerpted from speeches
given by Susan King before the FTC Work-
shop for Women and the Public Affairs
Council. Complete texts of the speeches are
available from the Media Relations Office.
Consumer Product Safety Commission,
1111 18th Street NW, Washington, D.C.
20207.
Regulatory reform is more than a slogan;
it is a reflection of a deep desire on
the part of the American people to gain a
greater degree of control over their own
lives and to get from government what they
pay for: service rendered quickly and
without waste.
Organization is always the key to more
productive systems, whether they involve
energy locked up in the ground or energy
locked up in the Federal establishment.
It involves sorting out what we have so that
we don't waste limited scientific resources
re-inventing the wheel, coming up with
brilliant solutions to problems solved last
week somewhere else, failing to use what
is already available or, worse, coming up
with four different solutions to the same
problem.
And I believe excellence in organization
is nowhere more crucial than in the area
of protecting the public and the environ-
ment from hazardous chemicals. That is
why I consider the interagency agreement
signed September 26,1 977, by EPA, CPSC,
OSHA, and FDA to be so important.
As you know, that agreement signalled
an intention, indeed a determination, to
work together in eight specific areas of
cooperation, and to explore ways of co-
operating in a ninth.
24
EPA JOURNAL
-------
Let me review these:
First, devising testing protocols, criteria
for interpretation, quality assurance proce-
dures and other policies relating to the
testing of toxic and hazardous substances;
Second, working out common ap-
proaches to the assessment of risks and
benefits;
Third, agreeing on methods of obtaining,
analyzing, storing and exchanging informa-
tion;
Fourth, establishing common research
and development policies;
Fifth, coordinating regulations and reg-
ulatory development activities, such as
joint public hearings or rulemaking;
Sixth, developing compliance and en-
forcement procedures and policies;
Seventh, establishing public communi-
cation and oducational programs and
informational services to industries
affected by our regulatory activities;
Eighth, stimulating the flow of epidemio-
logical data; and
Ninth, exploring cooperation among gen-
eral counsels. Congressional affairs, per-
sonnel, and public information offices;
regional coordination; planning and evalu-
ation; environmental impact study and
good laboratory practice groups; and
budget coordination. Some specific activi-
ties in the ninth area include mutual train-
ing programs, personnel exchange pro-
grams, and jointly-sponsored contracts or
grants.
To advance these goals, eight task
forces, made up of representatives of each
of the agencies, have been working to
develop and carry forward specific plans
for increased cooperation and coordina-
tion. Since much of this activity is designed
to overcome the unfortunate side-effects of
overcentralization, it would be a contradic-
tion in terms as well as a violation of good
sense to ignore the fact that most of the
knowledge needed to make this effort work
resides in each of the ten regions, and
I want to emphasize that regional initiative
is a key element in this entire effort.
This is certainly true in the key area of
toxicity testing and toxicological research.
Given the dynamics of modern chemical
synthesis and the speed with which we are
able to analyze more comprehensively,
even the most efficient use of resources
may fall short. And it is obvious that
resources were not being used efficiently,
but were instead characterized by incon-
sistency in testing guidelines. These de-
mands have too often strained the patience
of those we regulate as well as their phy-
sical resources to conduct these experi-
ments. More importantly, duplication has
caused delay in the testing of many sub-
stances about which important safety
information is still lacking.
In an effort to reduce unnecessary dup-
lication of testing by industry, each of the
four agencies already has begun to re-
evaluate and improve its standard setting
procedures. At FDA, for example, I have
directed that new Toxicology Testing
Guides be developed for industry to ex-
plain FDA's new testing policy in five differ-
ent areas—genetics and reproduction, im-
plantation toxicity, metabolism studies,
long-term or low-exposure toxicity studies,
and short-term tests for neoplasia. FDA
scientists are currently working with other
experts to design these testing guidelines.
A principal goal will be to insure that
these testing guidelines are compatible
with those established by the other
agencies.
In designing this compatibility into our
testing guidelines, we will have to answer
these kinds of questions:
• What are the problems of meshing
separate regulatory authorities into one
scientific policy?
• Do we really need more testing on a
certain chemical or group of chemicals, and
if so what kind?
• If we need more tests, how do we
design them so that the results will be
relevant to the broadest range of regulatory
decisions?
• How can the agencies determine to-
gether the proper use of short and long term
tests and the proper extrapolation of this
data to health effects in man?
• How can we develop new initiatives for
improving the quality of toxicity testing
research in the private, as well as the
public, sector?
Answering such questions will not lead
to one simple set of tests for industry to
follow in every circumstance. It will, how-
ever, help develop a common and reason-
able data base upon which industry can
build additional information to serve sep-
arate agency needs. I am not saying that all
duplication can be avoided, but needlessly
duplicative and unnecessary costs of reg-
ulation—and of compliance with regulation
—can and will be reduced.
All of the testing and all of the regula-
tions that are our concern are designed to
tackle perhaps science's most baffling ques-
tion: How do we measure the risk to
humans of any given chemical in our in-
creasingly chemical society? We face the
added problem of trying to explain what
we are trying to do to a confused and some-
times skeptical public. It is not easy to heed
a warning about asbestos—a substance
that may take 40 years from the time of
exposure to result in human cancer.
We are therefore faced with a real cred-
ibility gap in the business of assessing risk.
The problem is further complicated by the
fact that the methods for evaluating risks
in people are still poorly defined and in-
exact; and may require extrapplation from
animal studies. The saccharin case illus-
trates that public confidence is difficult to
retain even when the quality of the science
is good.
The resources of the FDA, EPA, CPSC or
OSHA alone will never be enough to re-
store and reinforce public confidence.
Working together, we have a chance—and
to me, this is more than ample justification
and incentive for the program we are
working on. D
This article is excerpted from a speech
given by Donald Kennedy to the Inter-
agency Orientation Symposium.
NOVEMBER/DECEMBER 1978
25
-------
People
Dr. A. F. Bartsch
He has been awarded EPA's
highest honor, the Distin-
guished Career Award. Dr.
Bartsch, who retired as Director
of the Agency's Corvallis
Environmental Research
Laboratory in October, was
commended for 31 years of
"dedicated and distinguished
service to the Federal Govern-
ment." He joined the govern-
ment as a biologist with the
U.S. Public Health Service,
and is recognized as a world-
wide authority in aquatic
biology and water pollution
control research. In 1962 he
organized the cooperative
Washington State-Public
Health Service pollution inves-
tigations on Puget Sound. He
was appointed Director of the
Pacific Northwest Water
Laboratory in Corvallis, Ore.
When the lab was incorporated
into EPA in 1970 Dr. Bartsch
was named Director. In 1969
he received the Department of
the Interior Award for Meri-
torious Service. Dr. Bartsch
received his B.A. in botany
from the University of Minne-
sota and his Ph. D. in aquatic
biology from the University
of Wisconsin.
Patricia Berger
She has been appointed Chief
of Information Resources and
Services Branch at EPA. Her
previous service includes ex-
tensive experience in managing
government and corporate
libraries.
Mrs. Berger had served as
Chief of the Library Division,
National Bureau of Standards,
1976-78. From 1972 to 1976
she served as Chief of the Gen-
eral Reference Branch and sub-
sequently Deputy Chief Librar-
ian of the Patent and Trademark
Office, Department of Com-
merce. Previously she
was Chief Librarian for the
Commission on Government
Procurement; consultant on
information security and library
programs for Systems Planning
Corp., and Chief of the libraries
of the Lambda Corp., Institute
for Defense Analyses, Center
for Research in Social Systems,
CEIR, and General Research
Corp.
She holds an A.B. degree
from George Washington Uni-
versity and a Master of Library
Science degree from Catholic
University. She is the author of
numerous articles on library
and information systems. For
her work on the Commerce De-
partment International Women's
Year program, she received the
•Department Special Achieve-
ment Award in 1976.
•
Thomas J. Charlton
An EPA official who won a gold
medal for the U.S. in the 1956
Olympics rowing champion-
ships, Charlton is looking for-
ward to his 30th season of com-
petitive rowing next year.
Charlton, 44, who has been
rowing for the Potomac Boat
Club of Washington, D.C., since
1971, reached the semi-finals
last summer in an eight-oar
event at the Henley Royal Re-
gatta in England.
An engineer with EPA's Divi-
sion of Oil and Special Mate-
rials Control, Charlton also took
part in several other rowing
events in the past few months
in the U.S. and Canada. He was
part of the four-oar team that
took a first while representing
the South at the National Sports
Festival in Colorado Springs
sponsored by the U.S. Olympic
Committee.
Gary N. Dietrich
He is the new Associate Deputy
Assistant Administrator for
Solid Waste.
Dietrich joined EPA in 1971
after serving with the Federal
Water Pollution Control Admin-
istration, one of EPA's prede-
cessor agencies, the U.S. Public
Health Service, the Los Angeles
County Sanitation Districts, and
the Dallas, Tex., Water Depart-
ment.
Before his new EPA post,
Dietrich had served as Special
Assistant to the Assistant Ad-
ministrator for Water and
Hazardous Materials (now
Water and Waste Management)
and as Associate Deputy Ad-
ministrator for Resources Man-
agement. Dietrich joined EPA in
1971 as Director of the Division
of Program Analysis in the
Office of Resources Manage-
ment.
He is a graduate of the Cali-
fornia Institute of Technology
with a B.S. in Civil Engineering
and has done graduate work at
Cornell University.
Ivan W. Dodson
He has been appointed to
direct Region 7's new Montana
Operations Office in Helena.
His post with EPA since 1973
has been Chief of the Pesticides
Branch in the Air and Hazard-
ous Materials Division. Dodson
joined the government service
as Head Range Conservationist
for the State of New Mexico
with the USDA in 1954, and
served with the Federal Water
Quality Administration from
1967 to 1970. He received his
B.S. in agriculture from New
Mexico State University and
completed graduate work there
in biology and ecology.
26
EPA JOURNAL
-------
Dr. Hend Gorchev
She is serving on detail to the
World Health Organization in
Geneva, Switzerland to assist
in the revision of international
drinking water standards. Dr.
Gorchev has been an environ-
mental scientist in the EPA
Office of Research and Develop-
ment, Office of Health and
Ecological Effects.
A native of Egypt, she re-
ceived a Bachelor of Science
degree in industrial chemistry
from Alexandria University,
Egypt, in 1955, a Master of
Science in sanitary chemistry
in 1957, and a Ph.D. in sanitary
engineering in 1961, both from
Radcliffe College.
Dr. Gorchev was a Research
Fellow at the Harvard School of
Public Health 1964-65 and
served as a technical assistant,
sanitary engineer, and programs
specialist with the Federal
Water Pollution Control Admin-
istration from 1967-1971 when
she joined EPA as a Research
and Development Program
Specialist in Region 1 . She
transferred to Headquarters as
a physical scientist in 1972 in
ORD. She participated in the
Congressional Fellowship Pro-
gram in 1975-1976.
Robert L. Humphries
He has been named Director
of Congressional and External
Affairs in EPA's Atlanta
Regional Office. Before joining
EPA he was the Environmental
Information Manager for
Georgia Power Company.
Humphries was a biologist in
fishery research with the North
Carolina Wildlife Resources
Commission from 1955-64.
He was employed by Curtin
Scientific of Atlanta, Ga., from
1964-73. He also has worked
as a consultant in real estate
investments. Humphries earned
a B.S.and M.S. inzoology from
the University of Georgia. In
his new post he directs the
Office of Public Awareness,
the Office of Congressional
and Intergovernmental Rela-
tions and the library.
Ritchie R. Julian
He has been named Director
of EPA's Personnel Manage-
ment Division at Research
Triangle Park, N.C. Before
coming to EPA he was Chief of
Labor and Employee Relations
at the Defense Mapping
Agency, St. Louis, Missouri.
His experience there included
Supervisory Personnel Manage-
ment Specialist and Chief of
Classification and Wage
Administration. Julian received
the Exceptional Civilian Service
Award for program results in
Equal Employment Opportunity
while serving with the Defense
Mapping Agency. He received
an undergraduate degree in
education from the University
of Nebraska, a master's in
management from Chapman
College, Orange, CaL and is
presently working toward a
doctorate in human behavior
studies.
Dr. Barbara Metzger
She has been named Director
of EPA's Region 2 Surveillance
and Analysis Division at
Edison, N.J.. replacing Dr.
Richard Dewling. Prior to
being named Acting Director
of the Division last June she
had been chief of the Environ-
mental Impacts Branch in the
New York Regional Office for
nearly three years. Her previous
government experience began
with an EPA predecessor
agency, the Federal Water
Pollution Control Administra-
tion in 1970. Dr. Metzger has
three degrees from Rutgers
University, including a Ph.D.
in environmental science.
William W. Rice
He is the former Chief of the
Planning. Management and
Administration Staff at EPA's
Industrial Research Laboratory
at Research Triangle Park, N.C.,
who has been named Director
of the Surveillance and
Analysis Division in the
Agency's Kansas City Regional
Office. Rice held the North
Carolina post for six years after
joining the Agency as a sanitary
engineer in 1970. Prior to that
he was an industrial engineer
for the Raychem Corporation,
Menlo Park, Cal. He has a B.S.
in industrial engineering from
Oregon State University and
an M.S. in management from
Duke University.
Vivian A. Skinner
She has been given an award of
excellence by the Association
of Records Managers and Ad-
ministrators. A management
assistant in EPA's Region 6
headquarters office in Dallas,
Tex., Skinner saved the Govern-
ment nearly $20,000 by her
records disposition work over a
1 5-month period.
NOVEMBER/DECEMBER 1978
27
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Jobs
and the
Environ-
ment
By Truman Temple
-------
The Republic Steel Corpora-
tion is investing more than
a quarter billion dollars for
modernization and pollution
controls at its Mahomng Valley
District plants following an
agreement with the Environ-
mental Protection Agency.
The massive new capital im-
provements will not only bring
the company's Warren and
Youngstown, Ohio facilities in
compliance with air pollution
requirements by 1982, but also
will assure continued employ-
ment for some 6,400 people in
the troubled Mahoning Valley.
Administrator Douglas
Costle, in a White House news
conference, said the agreement
"represents a long-term com-
mitment to the vitality of the
Mahoning Valley. It will mean
cleaner air and water for the
citizens in Ohio and neighboring
States."
The modernization program
will include $75-85 million of
pollution-control equipment at
the plants. This agreement re-
quires Republic to put in water
pollution control equipment at
its coke-making facilities by
December 31, 1981, 18 months
sooner than would have been
otherwise required. By agreeing
to the expedited schedule, Re-
public received a credit which
fully offset the $3.1 million in
penalties EPA claimed was due
for air pollution violations.
In a joint appearance with
W. J. De Lancey, Republic pres-
ident, and Lloyd McBride,
president of the United Steel-
workers of America, Costle
declared:
"Republic Steel has made a
major commitment in this
agreement to the economic and
physical health of the citizens
of Mahoning Valley, and we
felt it was time that the citizens
in that valley had so megood
news."
Noting that he had met with
the company president earlier
in the year to discuss the com-
plex problems of the mills, the
Administrator congratulated
Republic on its "far-sighted and
(Truman Temple is Associate
Editor of EPA Journal)
cooperative attitude" in work-
ing out the agreement. Discus-
sions between EPA and Repub-
lic extended over several
months in 1978 before agree-
ment was reached.
The pact was considered of
special significance since it was
a comprehensive agreement
including a modernization pro-
gram that EPA had reached with
a major steel company since the
1977 amendments to the Clean
Air Act were enacted. In addi-
tion, there had been widespread
concern in the industry about
the Mahoning Valley economy
because of complex issues in-
volving not only pollution clean-
up but aging equipment and
ting down, and have talked to
the people there, you hardly can
appreciate the importance of
what is happening here today.
As we see it, this reverses this
trend."
The Senator praised govern-
ment, industry, and labor repre-
sentatives for working out solu-
tions to the problem and making
it possible for Republic to con-
tinue operations in the area.
Echoing those comments,
McBride, the Steelworkers presi-
dent said, "We feel that this
demonstrates what can be done
in terms of meeting problems
of environment, competitive-
ness, and job security which I
think is absolutely necessary
The Mahoning River flows past yard and hot strip mill in
a Republic Steel slab storage Warren, Ohio.
competition from imports of
foreign steel.
The valley derives its name
from the Mahoning River,
which flows southeast from
Warren through Youngstown
into Pennsylvania. The area is
so heavily developed with iron
and steel plants that it has been
nicknamed America's Ruhr
Valley.
Senator John Glenn of Ohio,
who also spoke at the White
House press conference, de-
scribed the situation this way:
"Unless you have gone into
a place likethe Mahoning Val-
ley at a time when layoffs are
occurring, and industry is shut-
for any community."
Under the agreement, Re-
public will build a new electric
arc shop, a new sinter plant,
and a new hot metal desulfuri-
zation unit and expand its blast
furnace capacity at Warren. All
the new facilities will meet the
lowest achievable emission rate
at this time. Republic will also
close an old sinter plant there
and keep shut down an old
sinter plant as well as close a
coke battery and three blast
furnaces at Youngstown. The
controls to be installed there
will be in full compliance with
existing air pollution control
requirements by December 31,
1 982. The company also will
halt the use of dirty water
quenching at both plants and
wi!l treat coke plant wastewater
previously used for quenching
at a new water treatment facil-
ity to be built at Warren by
December 31, 1981.
Quenching water is em-
ployed to cool the coke after it
emerges from ovens where it is
produced. For this procedure,
some steel companies have
used process water that has
been recovered as a product of
distillation of the coal in the
coking process. However, the
various dissolved solids in this
water are released into the at-
mosphere during the quenching
process as part of the large
volume of steam that rises from
the coke, and thus the operation
can create an air pollution prob-
lem. Using clean water for
quenching is one way to help
reduce air pollution.
The company anticipates that
the modernization program will
enable it to produce steel more
efficiently and therefore will
have a positive effect on the
price of its steel products.
"This program," De Lancey
said, "will have a marked im-
pact on stabilizing employment
in the Warren-Youngstown,
Ohio, area and will help insure
Republic's continued competi-
tive capability in the Mahoning
Valley well into the future."
He added that the modern-
ization would not result in any
significant change in Republic's
overall employment in the Ma-
honing Valley over the long
term.
A major environmental effect
of the investment will be almost
a 50 percent reduction in emis-
sions of dust and smoke in the
Republic facilities. The plants
now emit about 2,700 tons of
particu fates a year, and the fig
ure is expected to drop to about
1,400 tons annually. Other ben-
efits related to sulfur oxides
control and water pollution con-
trol also are expected.
NOVEMBER/DECEMBER 1978
29
-------
Sparks fly as saws cut into continuous lengths of pipe at a steel mill in Youngstown, Oh.
"I think the company found
us willing to be reasonable and
responsive in meshing the !aws
and environmental require-
ments with their modernization
plans," Costle declared. "This
is a significant example of our
efforts to work out agreements
with the steel industry for meet-
ing pollution control require-
ments that will enhance em-
ployment opportunities and
long-term economic growth."
The agreement will require
approval by State authorities in
Ohio and Pennsylvania since
both States are impacted by
the pollution. It must also be
approved by the Federal District
Court in Cleveland, where the
consent agreement was filed
and lodged for public notice.
The steel industry as a whole
has been the subject of close
scrutiny and concern by the
Carter Administration in the
past year and a half. On De-
cember 6, 1977, an Interagency
Task Force headed by Under
Secretary of the Treasury
Anthony M. Solomon submitted
a special report on the industry
with a series of recommenda-
tions dealing with prices, mod-
ernization, environmental regu-
lations, transportation, research
and development, labor prob-
lems, and other aspects.
The proposals involving en-
vironmental regulations noted
that the steel industry was "one
of the largest contributors to air
and water pollution in the na-
tion" and produced 20 percent
of all man-made paniculate
pollution from major sources
in 1975 in the United States.
The report also pointed out
that steel plants discharge
solids, acids, heavy metals,
arsenic, cyanide, phenols, oil,
grease and heat into local
waters, and that some of these
pollutants must be removed by
expensive treatment facilities
to protect drinking water sup-
plies of communities down-
stream.
The report emphasized that
funds for pollution control in
the industry should be spent
"in a way that results in the
most clean-up possible per
dollar."
"The current financial plight
of the industry should not deter
us in seeking a cleaner environ-
ment," the task force declared.
"We also recommend against
differential or more lenient
treatment in the regulation or
enforcement for the steel
industry."
It was against this back-
ground that the EPA-Republic
agreement was reached. D
30
EPAJOURNAL
-------
Letters to the Editor
The Impact
of Coal
I am concerned by the unquali-
fied statement by Lester R.
Brown in his article "Rede-
fining National Security" in the
EPA Journal, June 1978, which
notes that "A U.S. National
Academy of Sciences study
recently pointed out that the
burning of coal in the quantity
necessary (to circumvent the
impending shortage of energy
supplies)" would eventually
lead to a several-fold increase
in atmospheric carbon dioxide
and an associated and possibly
catastrophic rise in the average
global temperature."
Many of your readers will
probably find this statement to
be alarming and question the
wisdom of using coal to
overcome some of the present
and future world energy short-
ages. The facts surrounding
this matter are that the National
Academy of Sciences study" "
showed that if the world
population increases from the
present 3.9 billion to 10.7
billion by the year 2075, and
if the per capita energy
consumption increases from
52.5 million Btu per year in
1973 to 125.5 million Btu per
year by the year 2075, and if
all this increased energy
(5 times current levels) was
produced from the burning of
fossil fuel (mainly coal), the
carbon dioxide released to the
atmosphere would probably
exceed that absorbed by the
oceans and plant growth and
cause an increase in the
atmosphere which might lead
to an increase in global mean
air temperature of more than
6°C by AD21 50-AD2200 and
by 10°C in the latter part of
the 22nd century. This in-
creased air temperature might
result in adverse consequences
with respect to world climate,
rising sea levels and an overall
detrimental effect on
agriculture.
The assumptions on in-
creased population and energy
requirements in the future are
* Parenthesis by writer.
**"Energy and Climate",
NAS, 7977.
highly speculative and, as noted
in the NAS report, "A 100 year
projection must offhand seem
foolhardy. It probably is." The
report also admits that the
mathematical model used to
arrive at the predictions is
greatly oversimplified and
"does not take account of four
climatic feedback mechanisms
that could change the calcu-
lated results: atmospheric-
ocean carbon dioxide interac-
tion, cloud reaction, ocean
temperature and heat transport
changes and aerosol interac-
tions." In addition, it must be
obvious that not all the future
energy requirements will be
made available only from the
burning of coal. Some of the
energy requirements will
undoubtedly still be supplied
by oil, natural gas, and hydro-
electric power, and the
increased requirements by coal,
nuclear, solar and geothermal
plants.
I would appreciate publica-
tion of this letter so that your
readers may judge for them-
selves how small is the
likelihood of actually ever
reaching the NAS climate
scenario attributed to utilization
of the world's abundant coal
reserves.
Mr. Brown's paper itself
recognized the world's intense
energy needs. How ironic it is,
then, that he approaches the
problem of preserving civiliza-
tion by foreclosing our most
powerful energy option,
increased reliance on coal, well
before the climate research
program has actually assessed
the reality of the presupposed
threat.
Leonard Harris
Director of Research &
Development
Newmont Mining Corporation
300 Park Ave.
New York, N.Y.
Brown
Replies
It is of course true that the
National Academy of Sciences
used a number of qualifying
parameters in preparing their
assessment of the impact that
increased use of coal would
have on global climate. These
parameters are based on cur-
rent trends in population and
energy use and are presented
as being the National Academy's
best estimate of energy use
patterns if "coal conversion" is
vigorously pursued into the next
century. As the National Acad-
emy notes, it is currently im-
possible to predict with cer-
tainty the impact that greatly
increased use of coal might
have on global climate. How-
ever, the Academy study shows
that the potential for a cata-
strophic rise in average global
temperature is all too great.
As the study goes on to say,
"Unfortunately, it will take a
millennium for the effects of a
century of use of fossil fuels to
dissipate. If the decision is
postponed until the impact of
man-made climate changes
has been felt, then, for all
practical purposes, the die
will already have been cast."
Fortunately, massive reli-
ance on coal is not the only
energy alternative open to the
world. Increased reliance on
conservation and the use of
renewable energy resources
are now important options,
holding out the possibility of
adequate long-term energy
supplies without the threat
of climatic disaster.
Lester Brown
President
WorldWatch Institute
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NOVEMBER/DECEMBER 1978
31
-------
Update
Noise
Noise Control Visit
The noise from traffic
bothered more people in
Darlington, England, than
any other source, accord
ing to a recent survey.
Representatives of the
city recently visited the
U. S. to discuss the sur-
vey and other aspects of
an experiment to make
Darlington quiet. The
Britons visited Allentown,
Pa., where the EPA is
sponsoring an experiment
similar to the one in Darl-
ington to find ways to
reduce noise.
Pesticides
DBCP Controls
EPA has proposed ending
some uses of the pesti-
cide DBCP but allowing
other uses to continue
under strict precautions.
The pesticide has reduced
sperm levels among work-
ers producing it.
The proposal would
make permanent an ac-
tion the Agency took in
October, 1977, when it
temporarily suspended
most uses of DBCP on
vegetables, but permitted
other crop and commer-
cial treatments, if made
by trained applicators
wearing protective cloth-
ing.
Public concern over
the pesticide's safety
arose in 1 977 when it
was identified as the
cause of sterility and low
sperm levels among pro
duction workers at the
Occidental Chemical
plant in Lathrop, Calif.
EPA was already investi-
gating DBCP as a suspect
human cancer agent.
At press time the pro-
posal had not yet become
final.
Pesticide Policy
Steps need to be taken to
combat the problem of
disease and crop damage
caused by insect pests
making a comeback, said
Administrator Douglas
M. Costle recently. But
it is "overly simplistic"
to advocate a return to
long-lasting, potentially
dangerous pesticides
such as heptachlor, diel-
drin, and Mirex, he said.
"A better solution
probably lies in the oppo-
site direction—in the
development and use of
more selective pesticides
or natural controls that
kill the pests but do not
harm beneficial insects,
wildlife or people,"
Costle said.
"In addition, more
investigation into the
relationship between
pest populations and
farming practices, such
as growing the same crop
on hundreds of acres year
after year, may yield
other methods for dis-
couraging insect explo-
sions," he said.
Toxics
Enforcement
Fluorocarbon Action
At press time, EPA had
forbidden further bulk
production of fluorocar-
bons for use in most aero-
sol products. The Agency
also is joining the Food
and Drug Administration
and the Consumer Prod-
uct Safety Commission in
a next step—forbidding
the manufacture of most
fluorocarbon spray prod-
ucts as of Dec. 1 5.
With a planned third
step April 1 5, the process
of banning fluorocarbon
gases in spray cans is ex-
pected to be complete.
According to a theory
first advanced in 1974,
fluorocarbons used as
propellents in ordinary
household spray cans
drift up to the strato-
sphere to destroy ozone,
leading to added risks of
skin cancer in humans,
possible damage to crops
and wildlife, and long-
term changes in climate,
Trees to Get
Human Drug
Peach, cherry, and nec-
tarine trees in Michigan
and New York will be
treated with the drug Ter-
ramycin,normally pre-
scribed for humans.to pro-
tect them from a malady
called "X disease," the
EPA recently announced.
The disease kills leaves,
spots branches, causes
fewer, smaller fruit, and
can eventually destroy
the trees.
EPA has given the two
States emergency permis-
sion under Federal pesti-
cides law to inject up to
27,000 trees in 30 coun-
ties with the antibiotic,
often prescribed for peo-
ple to clear up bacterial
infection. At the moment,
the medicine seems to be
the only practical, eco-
nomical weapon for con-
trolling "X disease," said
Steven D. Jellinek, As-
sistant Administrator for
Toxic Substances.
Gas Switch
Damages
Car Cleanup
The emission control sys-
tems in nearly 4 million
U. S. cars have been rend-
ered ineffective since
1974 by switching to
leaded gas, EPA officials
estimate.
Under Federal law, if
someone is caught the
only person liable for
prosecution is the service
station operator where
the car owner filled up.
But individuals could be
prosecuted under many
State laws.
If auto emission sys-
tems are properly main-
tained they should work
indefinitely, said an EPA
spokesman. This means
lead-free gas, good tune-
ups, oil changes, and air
filter and spark plug
changes.
But the clean-up sys-
tems are ruined if the car
owner knocks out a re-
striction device in the filler
neck of the gas tank and
uses a few tankfuls of less
expensive leaded gas.
Gasohol Potential
Administrator Douglas
M. Costle said recently
that the Agency is encour-
aged by the prospect of
energy savings from the
use of Gasohol, and will
continue to analyze its
environmental impacts.
Gasohol is 90 percent
gasoline and 10 percent
ethanol. It is now being
produced and sold experi-
mentally in about 65 gas
stations in Nebraska, Illi-
nois, and Jowa.
Under the Clean Air
Act, certain fuel additives
such as Gasohol are auto-
matically banned unless
EPA grants a waiver. The
Agency is expected to
finish its review of the
waiver question by De-
cember 1 6, the deadline.
In the meantime, EPA is
not enforcing the ban on
Gasohol.
Fuel Additive
Turned Down
EPA recently disapproved
an Ethyl Corporation re-
quest to continue selling
a chemical called MMT as
an additive in unleaded
gasoline. EPA turned
down the request because
MMT increases auto
emissions. The additive
is now used in about half
of all unleaded gasoline
as an octane booster.
After the EPA refusal,
MMT was automatically
banned as a gasoline ad-
ditive under the 1977
Clean Air Act Amend-
ments. The law provided
that MMT would be
banned unless EPA
granted a waiver.
Administrator Douglas
M. Costle said it would
cost more for the auto
industry to meet emis-
sion standards with MMT
in fuel than it would for
the refining industry to
increase refining opera-
tions to make up for oc-
tane lost due to the MMT
ban.
Safeguard
Extension
Sought
EPA is seeking extension
of two key provisions of
a decree that prohibits
U.S. automakers from
working together to avoid
the development of im-
proved auto exhaust
clean-up systems.
The two provisions
prevent the automakers
from exchanging re-
stricted information,
such as trade secrets,
relating to emission con-
trol technology. They also
prevent joint presenta-
tions to government agen-
cies regarding proposed
motor vehicle air pollu-
tion requirements. The
Automobile Manufactur-
ers Assn., Inc., is also
covered in the decree.
These provisions will
expire in October, 1 979,
32
EPAJOURNAL
-------
unless extended by the
U.S. District Court in Los
Angeles. EPA has asked
the Justice Department to
request a permanent ex-
tension on the Agency's
behalf.
Memphis Pays
$25,000 Penalty
Under a recent consent
decree the city of Mem-
phis has paid $25,000 in
civil penalties for viola-
tions by a wastewater
treatment plant of a Na-
tional Pollutant Discharge
Elimination System per-
mit. The violations were
by the T. E. Maxson
Wastewater Treatment
Facility between June 30,
1975, and July 22, 1977.
The consent decrso
was entered into by the
Federal government and
the city of Memphis in
settlement of a lawsuit
filed at the request of
EPA. The Federal Court
for the Western District
of Tennessee signed the
decree. Additional pen-
alties for any future viola-
tions are called for by
the decree.
Catch-up Rules Set
EPA recently announced
the rules it will follow in
issuing, approving, and
disapproving delayed
compliance orders under
the Clean Air Act. These
orders may be issued by
EPA or the States to eli-
gible stationary sources
and contain catch-up
schedules to comply
with air clean-up require-
ments.
To encourage public
participation, EPA will
put proposed delayed
compliance orders in the
Federal Register. In the
Register notice EPA will
request public comments
on the order and offer the
opportunity to request a
public hearing. The new
rules also provide for a
notice before EPA acts on
delayed compliance or-
ders issued by States.
R & D
Air
Solid Waste
Water
Japan Praised
for Scrubbers
Administrator Douglas
M. Costle recently called
on U. S. utility executives
to strive to equal Japan's
successful application of
scrubber technology to
control sulfur dioxide pol-
lution from power plants.
Although many Amer-
ican utilities have done a
commendable job in the
use of scrubbers, applica-
tion of the technology in
Japan has generally pre-
ceded that in the U.S.,
Costle said. He was an-
nouncing the report of a
task force, including an
EPA representative,
which visited Japan to
study its scrubber use
and applicability to U.S.
power plants.
Final Standard
Set for Lead
Administrator Douglas
M. Costle recently an-
nounced EPA's final
atmospheric air quality
standard to protect the
public health from expo-
sure to airborne lead. The
pollutant may, even at
low levels of exposure,
harm human nervous and
blood-forming systems.
"It is well known that
at certain levels lead is
highly toxic and can lead
to permanent health dam-
age or even death,"
Costle said. "What we
are finding increasingly,
moreover, is that even
low levels of lead may
have more harmful and
persistent effects than we
thought previously."
The final standard for
airborne lead is 1.5 micro-
grams—that is, 1.5 mil-
Months of a gram—per
cubic meter of air. This
is the first national am-
bient air standard EPA
has issued since 1971.
Clean Air Grant
EPA and three other
Federal agencies have
awarded a $245,000
grant to the U. S. Confer-
ence of Mayors. The aim
is to organize workshops
for elected officials and
prepare publications to
help States and localities
meet various require-
ments of the 1977 Clean
Air Act.
Special attention will
go to new State plans to
meet national air stand-
ards, principles for growth
in areas now violating
clean air standards, plans
to control auto use in pol-
luted cities, and the pre-
vention of significant air
deterioration in pristine
areas.
The other funding
agencies were the Depart-
ment of Commerce, De-
partment of Housing and
Urban Development, and
the Department of Trans-
portation.
EPA Commends
Florida Law
on Solid Wastes
EPA has commended the
State of Florida for inno-
vative legislation dealing
with solid waste. The new
law exempts resource re-
covery equipment owned
or operated by a mu-
nicipality from the Flor-
ida sales tax. Showing
the potential economies,
it is expected that $2 mil-
lion will be saved on Dade
County's resource recov-
ery project and about $1
million on Pinellas Coun-
ty's facility.
The law is "a unique
and very positive ap-
proach to furthering re-
source recovery" in
Florida and should be a
model for others, said
Steffen Plehn, EPA's
Deputy Assistant Admin-
istrator for Solid Waste,
in a letter to Governor
Reuben Askew.
Water Savings
Get EPA Boost
Conserving water in the
home can result in lower
water and energy bills. It
can also mean big savings
to taxpayers by reducing
a community's sewage
treatment costs. This was
a key theme for a water
conservation conference
scheduled by EPA for
November 28 and 29 in
Des Plaines, III.
EPA believes that sav-
ing water can not only
ease the pressure in
water-short areas, but can
reduce the volume of
wastewater a community
has to treat to protect
health and the environ-
ment. It can also preserve
options for community
growth without the need
for capital facilities such
as sewage plants.
Marine Agreement
For Use, Protection
EPA and the National
Oceanic and Atmospheric
Administration (NOAA)
have agreed to formally
coordinate research and
regulatory activities re-
garding the use and pro-
tection of oceanic and
coastal waters. Among
the first priorities will be
a search for ways the two
agencies can coopera-
tively implement the
Clean Water Act of 1977
under which EPA must
set criteria for marine dis-
posal of municipal waste-
water discharges.
Formation of the
NOAA-EPA Interagency
Committee for Program
Coordination was an-
nounced by Administrator
Douglas M. Costle and
NOAA Administrator
Richard A. Frank. D
NOVEMBER/DECEMBER 1978
33
-------
Senior
Environ-
mental
Aides
Honored
Twelve workers in the Senior
Environmental Employment
program were honored at a
White House ceremony recently
for their outstanding service.
The program, which employs
older citizens in various
environmental projects, is
cosponsored by EPA and the
Administration on Aging at the
Department of Health, Educa-
tion, and Welfare."
The program began in 1976
and has since provided jobs
for more than 200 people in
one national and 1 0 state
projects. The jobs include
surveying toxic chemicals used
in industrial areas, educating
the public on areawide water
quality planning, educating the
public on programs in noise
abatement, establishing and
managing agency environmen-
tal libraries, presenting
educational programs on the
uses of pesticides and the
hazards of poisoning to farm-
workers, and working on sur-
veys of environmental
carcinogens.
In order to qualify for the
program workers must be over
55. The jobs they fill must
augment or expand current
or planned programs in State
governments rather than replac-
ing existing positions. This
makes experienced assistance
available to environmental
projects without displacing
established workers.
Deputy Administrator
Barbara Blum told the re-
cipients "you have reconfirmed
my strong belief that the
enthusiasm and dedication of
older citizens is much too
valuable not to be used."
She cited the outstanding
reputation of the Senior
'See "Enlisting the Elderly tor the Envi-
ronment EPA Journal Vol 4 $2
Environmental Employment
program and continued, "We
look forward to increasing this
program because it has been
so successful."
According to Robert Bene-
dict, Commissioner of the
Administration on Aging, the
program is "a vehicle through
which older people can begin
to have a tremendous impact
on social and economic prob-
lems facing the country."
Blum presented a special
citation to John Ropes of
EPA's Office of Noise Abate-
ment and Control. As Director
of State and Local programs
Ropes was extensively involved
in the development and imple-
mentation of the Senior
Environmental Employment
program.
The 12 Senior Environmental
Employee workers receiving
awards were:
• Dennis Wile of Clarkston, Ga ,
who offers information to cities
in an eight-State region on noise
problems and control methods.
• John P. Waters of Glaston-
bury, Conn, who researches and
writes articles and booklets for
public information on environ-
mental issues.
• Harvey Duharnel of Palmyra,
N.J., who is a retired chemical
engineer now working as a pro-
gram coordinator in the solid
waste administration, there.
• George Siegel of Clarks
Summit, Pa., who is inventory-
ing wells in his State that serve
25 or more people.
• Norman Nylund of Louisville,
Ky, who is an inspector of pesti-
cides for the State.
• Walter Blair of Elmhurst, III.,
who is a technician assisting
public water supply operators.
• Delyle Compton of Fayette-
vifle. Ark., who makes audio
visual presentations on environ-
mental subjects to civic groups
in the State.
• Bertel Soderblom of Hays,
Kans., who makes slide presen-
tations on water quality manage-
ment and planning to interested
groups in the State.
• Harold Campbell of Water-
town, S. Dak., who is an area
supervisor for solid waste, air
and water quality, and air
hygiene programs.
• Josephine Sandoval of
Fresno, Cal., who is secretary
for the program on pesticide
information and surveys.
• Zelma Gorrell of Spokane,
Wash., who is a technician in the
water program.
• Chester Biesen of Seattle,
Wash., who is disseminating
information on noise hazards
and control methods
Biesen spoke at the ceremony
on behalf of the recipients of the
awards. "We older Americans
take great pleasure in being
singled out for appreciation in
the White House," he said. "Our
environment has always been
good to us, but we have not
been so good to it. We take
particular pride in working for
the Environmental Protection
Agency to help stem the tide of
the past, to correct past mis-
takes, and pass on to future
generations a viable and livable
environment such as we have
had.
"We older Americans have
been taken off the shelf and
brought back into the main-
stream of society," Biesen said.
"We want to put our abilities
back to work, not just for the
sake of our natural resources,
but for the sake of our human
resources as well," he said.
The recipients included one
representative from each of the
1 0 State projects and 2 from the
national project. They will parti-
cipate in local ceremonies at a
later date to share the honors
with the remaining workers.
Three State project officers
involved in the program were
honored also. They are Denise
Mikics, New Jersey Depart-
ment of Environmental Protec-
tion; Jack O'Nan, Kentucky
Department of Natural
Resources and Environmental
Protection, and Katherine
Leitch, Washington Depart-
ment of Social and Health
Services, Office of Aging.
A group called the Consor-
tium of Aging Contractors was
cited. It includes the National
Retired Teachers Association/
American Association of
Retired Persons, the National
Center on Black Aging, the
National Council on Aging, and
the National Farmers Union
Green Thumb.
Recently enacted amend-
ments to the Older Americans
Act were signed by President
Carter the day of the awards
ceremony. These changes will
expand the employment oppor-
tunities for older citizens.
Other Federal agencies are
studying Senior Environmental
Employment program as an
example of what can be done
in this area. D
Deputy A dministrator
Bnrbarn Blum presented u
certifcate of appreciation to
John Hopes, Director of State
and Local Programs in
EPA 's Noise Program for his
work in developing the
Senior Environmental
Employment program.
EPA JOURNAL
-------
Hazardous Waste
Funds
News Briefs
EPA recently announced that $15 million in
Federal grant funds is available to help
States set up programs to manage hazardous
wastes and EPA is expected to propose
regulations shortly. Examples of hazardous
wastes include unrinsed pesticide containers,
etching acid sludges, used lubricating oil,
and some paint wastes.
Clean-up
Award Entries
Applications are now being accepted for
the National Environmental Industry Awards,
the Council on Environmental Quality and
the Environmental Industry Council jointly
announced. The deadline for entries is
Jan. 5, 1979. The two groups sponsor the
awards program.
Congress Approves
Bike Measures
Congress voted a helping hand to the Nation's
bikers in two separate pieces of legislation
before adjourning this year. The National
Energy Act declared that bicycles "represent
a viable commuting alternative to many people,
offer mobility at speeds as fast as that of
cars in urban areas, provide health benefits
through daily exercise," and "reduce noise
and air pollution." It authorized the
Department of Transportation to conduct a
year-long study of the bicycle including
its energy conservation aspects and to develop
a program for increased bike use. In the
Surface Transportation Assistance Act of 1978,
Congress also voted a total of $20 million to
establish standards for bikeways and make
grants to the States and localities to
construct them on a 75—25 percent Federal—
State matching basis.
States Served by EPA Regions
Region 1 (Boston)
Connecticut, Maine.
Massachusetts. New
Hampshire. Rhode Island,
Vermont
617-223-7210
Region 2 (New York
City)
New Jersey. New York,
Puerto Rico, Virgin
Islands
212264-2525
Region 3
(Philadelphia)
Delaware. Maryland.
Pennsylvania Virginia.
West Virginia. District of
Columbia
215-597-9814
Region 4 (Atlanta)
Alabama. Georgia,
Florida, Mississippi.
North Carolina, South
Carolina, Tennessee.
Kentucky
404-881-4727
Region 5 (Chicago)
Illinois, Indiana, Ohio.
Michigan, Wisconsin,
Minnesota
312-353-2000
Region 6 (Dallas)
Arkansas, Louisiana,
Oklahoma, Texas, New
Mexico
214-767-2600
Region 7 (Kansas
City)
Iowa, Kansas, Missouri.
Nebraska
816-374-5493
Region 8 (Denver)
Colorado. Utah.
Wyoming. Montana.
North Dakota. South
Dakota
303-837-3895
Region 9 (San
Francisco)
Arizona. California,
Nevada, Hawaii
415-556-2320
Region 10 (Seattle)
Alaska. Idaho. Oregon.
Washington
206-442-1220
NOVEMBER/DECEMBER 1978
35
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Around the Nation
Sewer Upgrade
Evaluated
Region 1 has released its
draft Environmental
Impact Statement on the
upgrading of the Boston
Metropolitan Area Sewer
system. The EPA evalua-
tion recommends alterna-
tives, which at this time
appear to be the most
environmentally sound
and cost-effective, for
upgrading wastewater
treatment for Boston
Harbor and the lower
Charles, Mystic, and
Neponset Rivers. It
recommends expansion
and upgrading of a
primary treatment plant
at Deer Island to provide
secondary treatment for
approximately 586
million gallons per day
of wastewater. The exist-
ing sewer system and
pumping stations would
be expanded and modi-
fied as needed to handle
peak flows of sewage.
Some wastes would
receive preliminary
treatment at a plant at
Nut Island and then be
transported to Deer
Island through a pipeline
tunnel system under
Boston Harbor. Disposal
of dewatered sludge from
the plant would be
accomplished by a com-
bination of composting,
incineration, and direct
landfilling. Ash disposal
and composting would
take place at Squantum
Point.
pal sludge 60 miles out
to sea has been
recommended by Region
2 in the final Environ-
mental Impact Statement
for the New York Bight
site that is presently
being used. The move is
a precaution against any
possible dangers to public
health and coastal water
quality that might result
from overtaxing the exist-
ing dump site 12 miles
offshore. The alternative
location would be used
on a contingency basis
only until the dumping
ends in 1981.
As older wastewater
treatment plants in the
Greater New York
Metropolitan Area are
upgraded to provide at
least secondary treatment
the volume of sludge is
expected to increase. By
1981 the volume of
sludge produced should
be one and a half times
that produced in 1977.
EPA is concerned over
the possible effects of
dumping increased
volumes of sludge at the
existing site.
Regional Administra-
tor Chris Beck said, "We
are recommending that
the existing dump site be
monitored closely for
potential threats to public
health or degradation of
water quality. There is a
regional surveillance
program already estab-
lished and on-going to
this end. If a possible
threat is confirmed, then
waste dumpers would
be required to use the
alternative disposal site."
The alternate site is
located at the northern
end of the New York
Bight in order to minimize
the effects on commercial
sheilfishing, exploration
for gas and oil, and other
offshore activities, most
of which are concentrated
in the southern area of
the Bight.
Sludge Alternative
Listed
An alternative ocean
disposal site for munici-
Steel Facility Impact
Assessed
Regions 3 and 5 have
released their comments
on the draft Environ-
mental Impact Statement
prepared on U.S. Steel's
proposed lakefront steel
mill near Conneaut, OH.
The $3.5 billion total
process steel mill would
straddle the Ohio-
Pennsylvania border on
the shore of Lake Erie.
EPA found that the
statement gave inadf -
quate information to
fully assess the impact
of the plant in several
critical areas. These
include air pollution
analysis, population
projections, stream relo-
cation, wastewater
treatment alternatives,
construction of a pier,
and operation of water
intakes.
These issues must be
resolved before Federal
permits necessary for
construction can be
issued, but EPA is hopeful
that cooperation by the
parties involved will
result in an agreement
that will allow the project
to proceed. EPA sent the
comments to the U.S.
Army Corps of Engineers,
which compiled the
statement from informa-
tion submitted by U.S.
Steel and its consultants.
Both EPA Regional
Offices have worked
closely with the Corps,
U.S. Steel and other
involved parties on this
project over the past year.
Air Compliance
Ordered
A Federal judge has
ordered the West Penn
Power Company to begin
a cleanup program that
could result in the
installation of flue gas
desulfurization equipment
(scrubbers) at the com-
pany's Mitchell Generat-
ing Station near
Monongahela, Pa. The
preliminary injunction
order issued by the judge
requires the company to
prepare a preliminary
control plan and com-
pliance schedule within
six months. Design work
on the control system
must be completed within
a year, with bids procured
and evaluated three
months later.
permanent site in the
State to use for disposal
of the debris. The nearest
EPA-approved disposal
site for PCB's is in
western Alabama near
Livingston.
PCB Cleanup
Proceeds
EPA is working with
North Carolina officials to
clean up PCB contamina-
tion along some 250
miles of roadway in 1 5
counties, where the liquid
was allegedly dumped
from a tanker truck. A
Jamestown, N.Y., man
and his two sons were
arrested on a Federal
warrant and also face
State charges in the case.
Cost estimates for
removing 72 million
pounds of contaminated
soil and burying it in an
EPA-approved site ex-
ceed $2 million. The
contaminated roadside
areas were first treated
with activated charcoal
and emulsified asphalt to
keep the PCB's from
washing into other areas.
Various methods of pick-
ing up the hazardous
material were tested
before wide-scale cleanup
operations began.
Workers received blood
tests to determine liver
function and establish
existing levels of PCB's.
They wore protective
clothing and respirators
during the cleanup
process. North Carolina
officials are examining
some 60 areas to find a
Awards Program Set
EPA's Chicago office has
initiated an award pro-
gram to recognize out-
standing wastewater
treatment facilities in the
States that make up
Region 5. According to
Deputy Regional Admin-
istrator Valdas V. Adam-
kus, "The purpose of this
program is to emphasize
the importance EPA at-
taches to the job per-
formed by wastewater
treatment plant operators,
to encourage treatment
plant personnel through-
out the Region to improve
their operation and main-
tenance of these facili-
ties, and to enhance our
relationship with State
and local agencies."
The first two awards
indicate that the criteria
for excellence have been
established without bias
toward the size of the
plant. The first was pre-
sented to East Lansing,
Mich., which handles 10
million gallons a day, and
the second to New
Auburn, Minn., which
serves a rural community
of 300 people. They were
chosen from facilities
nominated by the States.
The East Lansing plant
was noted for the low
level of pollutants found
in discharges to the near-
by river, excellent staff
training programs, high
quality of upkeep, and
continuing involvement in
research into new meth-
ods of water treatment
and re-use. All 39 plant
employees and the city's
mayor received certifi-
cates at a recent
ceremony.
36
EPAJOURNAL
-------
The New Auburn fa-
cility was recognized for
the outstanding work
done by Herman P.
Knacke, the sole em-
ployee for many years.
Knacke, who died this
year, wrote a complete
set of instructions for
running the plant. His
widow and the town's
mayor received certifi-
cates at a ceremony that
was attended by many
residents of the town.
Disposal Application
Withdrawn
Rollins Environmental
Services, Inc. of Baton
Rouge, La., has notified
EPA's Dallas office that it
is withdrawing its appli-
cation for PCB disposal at
its incinerator and landfill
facilities in Baton Rouge.
The withdrawal was at-
tributed to adverse pub-
lic opinion in Louisiana.
An application by the
company for approval of
an incinerator and landfill
disposal operational Deer
Park, Tex., is not affected.
Discharge Permit
Issued
Region 6 has issued a
permit to the Department
of Energy to discharge
brine into the Gulf of Mex-
ico from the Strategic
Petroleum Reserve fa-
cility at Bryan Mound,
Tex. The discharge will
be permitted at a point
1 2,5 miles from the coast
subject to strict monitor-
ing provisions. Regional
Administrator Adlene
Harrison must approve the
monitoring plan before the
discharge is authorized.
The discharge is expected
to average more than 28
million gallons per day as
the salt water is pumped
from the Bryan Mound
salt dome to make room
for oil storage. Monitor-
ing will be conducted by a
third party acceptable to
both Federal agencies. If
adverse effects on the
marine environment are
found, the discharges will
be halted immediately.
Toxic Incident In-
vestigated
The Region 7 Emergency
Response Section as-
sisted in the investigation
of an incident involving a
mysterious illness that
struck the Boyer family
of Pevely, Mo. In late
September local police
found the 35-year old
mother dead, and the
father and two children
critically ill. The children
suffered from convulsions
and paralysis, symptoms
that were shared by the
family pets—two dogs
and two cats. Police offi-
cers who entered the
basement home reported
a heavy, musty, metallic
odor. They suffered head-
aches and nausea for a
brief period of time.
Tests conducted by
Army epidemiologists for
nerve or chemical gases
were negative. The Poison
Control Center in St. Louis
also took tests that proved
negative. EPA's Region 7
sent a team of investiga-
tors who took samples of
air, water, material from
sink traps, soil, and styro-
foam insulation, which
had been stored in the
home. Dow Chemical Co.,
which manufactured the
insulation, also took sam-
ples of the styrofoam.
The 13-year-old boy
subsequently died. His
father and sister regained
consciousness after
lengthy treatment and are
recovering. The St. Louis
medical'examiner attrib-
uted the two deaths to
pulmonary edema and
pneumonia. EPA's tests
showed significant quan-
tities of methyl chloride
and methyl bromide in the
air and liquid samples
from the home. These
compounds also were
found in the insulation
material. EPA findings
have been referred to tox-
icologists in the St. Louis
area and to the U.S.
Center for Disease Con-
trol in Atlanta, Ga. Iden-
tification of the toxic
gases hinge on tests being
conducted by the Center
for Disease Control
Fines Fund Recycling
The Federal District Court
in Denver has approved a
settlement agreement be-
tween EPA and the cities
of Littleton and Engle-
wood, Colo, that allows
pollution fines to be satis-
fied by contribution to a
nonprofit environmental
project. The fines were
imposed by EPA because
of pollutant discharges
to the South Platte River
in 1977. According to
Lance Vinson, Region 8
Enforcement Division
Director, the good faith
and cooperation of the
cities in working with
EPA staff toward a settle-
ment was largely respon-
sible for the Agency's
decision to allow the
cities credit for fines
through funding of Little-
ton/Englewood Recy-
cling, Inc., a local non-
profit recycling project.
The legal dispute be-
tween EPA and the cities
arose over discharges of
sewage sludge from the
new sewage treatment
plant that violated the
cities' pollutant discharge
permit. EPA contended
that improper procedures
were followed during the
start-up of the plant, caus-
ing the discharges.
Under the terms of the
agreement each city will
contribute 51 5,000 to the
recycling program. Al-
though not a party to the
agreement, the firm of
Henningson, Durham, and
Richardson of Omaha.
Neb., the consulting
engineers for the sewage
treatment plant, has
agreed to contribute a
portion of the settlement.
ning. This cooperation is
especially important be-
cause of the amendments
to the Clean Air Act and
increasing coordination
among Federal agencies.
Federal Cooperation
Continuing
EPA's Region 9 has held a
transportation/air quality
workshop to discuss the
requirements for non-
attainment area plans that
must be submitted by
January 1, 1979, and to
explain the DOT/EPA
Memorandum of Under-
standing and Joint Trans-
portation Guidelines. The
workshop was part of
environmental planning
activities in which the
Regional Office cooper-
ates with the Intermodal
Planning Group. This
group includes the Fed-
eral Highway Administra-
tion, the Federal Aviation
Administration, and the
Urban Mass Transporta-
tion Administration, all of
the Department of Trans-
portation. Ad hoc mem-
bers of this planning
group include EPA, the
Department of Housing
and Urban Development
and various State highway
and planning offices.
The Intermodal Plan-
ning Group convenes on a
monthly basis. The mem-
bers have annual meet-
ings with Metropolitan
Planning Organizations to
review yearly work pro-
gram plans and to coordi-
nate all transportation and
related planning that is
affected by Federal fund-
ing or regulations. EPA's
involvement in the Inter-
modal Planning Group
laid the groundwork for
cooperation in integrating
transportation, land-use,
and environmental plan-
Air Regulations
Violated
Region 10 has issued a
civil complaint to the city
of Meridian, Idaho, for
violations of EPA's un-
leaded gasoline regula-
tions at a municipally-
operated fueling station.
Regular gasoline was dis-
pensed through a nozzle
small enough to fit the
small filler inlet of cars
requiring unleaded fuel.
Also EPA charged that
one of the Meridian police
cars, marked "unleaded
gasoline only," had been
fueled with regular gas,
again in violation of EPA
regulations. The nozzle
violation carries a maxi-
mum penalty of $1,000;
the maximum penalty for
introducing leaded gas
into a car designed for
unleaded gas is $2,000.
In neighboring Canyon
County, the local sheriff
admitted to EPA that cata-
lytic converters had been
removed from four 1978
cars in his fleet, after pas-
sage of the 1977 Clean
Air Act Amendments
made this action illegal.
EPA is considering en-
forcement action in the
Canyon County case.
NOVEMBER/DECEMBER 1978
37
-------
Margaret Mead
Rachel Carson
continued from page 7
Margaret Mead died of cancer on November 15, 1978 as this issue of EPA
Journal was going to press. In recognition of her outstanding concern for
the environment and humanity we reprint this statement sent by Margaret
Mead last July to the A thens International Symposium On The Child In
The World Tomorrow :
In a darkened world beset by the fear of nuclear holocaust, degradation
of our soil and air and imbalance of population growth that threatens to
strangle our human settlements, the Year of the Child stands like a beacon
of hope. We must see that its light guides us and gives us direction for pre-
paring a livable, sustainable, beautiful world for our children, those who
have been born, those who have been conceived but not yet born and those
children of the future not yet conceived.
By keeping our eyes steadily on the pressing needs of children, we can
determine what needs to be done, and what can be prepared for but accom-
plished later. For babies cannot wait. A few moments without oxygen, a
few hours without food or shelter, a few days of desperate emotional dep-
rivation and, if they survive at all, they carry the mark for life.
Within the world initiatives of the last decade for a safer and better cared
for earth, initiatives to protect the environment, balance population, feed
the hungry, design human settlements for human living, this coming year
can be the climax, as we focus on needs and well-being of the world's
children, and the parents and grandparents of children, the towns within
which children live, the food they eat, the water they drink, the education
and health care they receive. As we provide children with a fuller life we
will find our reasons for living and protecting the world.
Her investigation of the threatened roots of
life was so profound, and her voice so elo-
quent, that her message carried beyond the
specific problem of pesticide use.
"There is no question," a government
expert on natural resources said following
her death, "that Silent Spring prompted
the Federal Government to take action
against water and air pollution—as well as
against the misuses of pesticides—several
years before it otherwise might have
moved."
Serious questions remain about the long-
term effects of environmental contaminants
on life. Despite many changes for the good,
Americans now apply more than twice the
amount of pesticides they did before Silent
Spring was published, and totals also are
increasing around the world.
But the dialogue about the benefits and
hazards of their use will never be quite the
same. The voice of one woman opened the
"Age of Ecology," prompting other people
in all walks of life to insist on working to-
ward a clean environment for ourselves and
the creatures with which we share the
Earth. Perhaps David Brower, an eminent
conservationist in his own right, best
summed up Rachel Carson's achievement:
"She did her homework, she minded her
English, and she cared." D
A New Coalition:
Women for Environ-
mental Health
A coalition of women from environ-
mental, health, labor, consumer,
and feminist organizations have joined
together on issues that relate to women
in their daily environments: at work, at
home, and in their communities.
Women for Environmental Health
(WEH), believes it is vital to address
the total environment of people, includ-
ing occupational health issues or com-
munity health concerns. Environmental
dangers that women are exposed to at
work and in the home are not separate
issues, but part of the same problem.
Because different Federal agencies.
State, and local governments address
different parts of environmental health
issues, WEH believes there is a need for
an organization that crosses those regu-
latory lines and addresses environmen-
tal issues on a wider basis.
In the past, women within the tradi-
tional environmental organizations have
not had the opportunity to deal with this
set of issues that affect them in a very
direct manner. WEH has been formed in
the belief that feminists, like labor, con-
sumers, and other natural allies, must
begin to speak in a strong, united voice
with environmentalists on issues that
affect women's lives and health. They
believe that a coalition approach can
forge a critical link between two con-
stituencies that share mutual concerns,
increasing the effectiveness of their re-
spective movements as well.
The strength of WEH will derive from
its members' work within existing or-
ganizations and professions.
As an organization of professional
women concerned with the environment,
it has a three-fold purpose: 1) To iden-
tify and take action on group-chosen
issues through lobbying, public educa-
tion,research and political outreach. 2)
To serve as a Washington-based clear-
inghouse for information about women's
environmental health issues—to inform
other activists in other local and Federal
developments, and to help them use the
extensive network of Washington-based
groups which WEH represents. 3) To
support each other's work by sharing
information, time, resources and politi-
cal contacts, whenever needed, to im-
prove effectiveness.
WEH has pin-pointed several con-
cerns, important issues that some
member organizations are addressing
from their own perspective.
• In Oregon and other States, women
who live adjacent to forest lands are
concerned about possible side-effects
from spraying with 2,4,5-T and other
herbicides. EPA is probing the cause of
10 miscarriages between 1973 and
1977 among eight women in a small
38
EPA JOURNAL
-------
Nursing Mothers
continued from page 13
keys. He has observed the same range of
symptoms in the" monkeys nursing from
PCB-contaminated mothers that the Jap-
anese victims exhibited. Further, he found
that the infant monkeys exhibited hyper-
activity and learning disabilities.
Dr. Allen has also been involved with
research studying the effects of dioxin, a
highly toxic chemical, and a contaminant
of the herbicide 2,4,5-T. EPA is currently
looking into levels of dioxin in human milk.
As the research technology has been per-
fected it ha? become possible to detect low
level residues, not just parts per billion but
also parts per trillion. The milk data are
still being analyzed.
Groups outside of the Agency are also
looking at the problem. In March of 1970,
the Environmental Defense Fund ran an ad
in national newspapers asking: "Is moth-
er's milk fit for human consumption?"
Stephanie Harris and Joseph Highland of
EOF have been studying the subject of
breast milk and pesticides for many years,
and are authors of a booklet titled, "Birth-
right Denied: The Risks and Benefits of
Breast-Feeding." The publication is an
analysis of the factors involved in choosing
whether or not to breast-feed. Harris and
Highland described the dilemma faced by
women who want to give their new-born
children a healthful start in life. They con-
cluded that with the scientific knowledge
available today, in most cases the benefits
of breast-feeding outweigh the risks be-
cause it not only provides an infant's
dietary needs under sanitary conditions,
but also fosters a psychological feeling of
well-being in the infant.
However, Harris and Highland suggested
that women who are occupationally ex-
posed to pesticides may want to consider
alternatives to nursing their infants. At the
time of the 1975 study, Stephanie Harris
asked EPA to test 50 women who were
vegetarians and who were not part of the
original group. The researchers found they
had lower levels of pesticides in their
breast milk, but no significant difference in
the levels of PCB's. (Harris and Highland
are completing their statistical analysis of
the results of this testing.)
Another study is underway in North
Carolina under the auspices of the National
Institute for Environmental Health
Sciences. Dr. Walter Rogan has contracted
with three hospitals to test women, some
of whom are nursing and others bottle-
feeding their infants. The study is particu-
larly concerned with PCB's, DDT, and DDE.
Researchers will look at the infant formula,
colostrum (breast milk produced shortly
Oregon town to determine if the mishaps
were caused by herbicide spraying of
nearby forests. WEH wants to support
and expand the work of those groups,
such as Friends of the Earth, who are
working to ban or strictly limit the use
of such chemicals.
• Americans need stronger regula-
tions to ensure the safety of cosmetic
products. WEH believes there is grow-
ing evidence that ingredients in some
cosmetic products can cause cancer,
birth defects, and genetic damage. The
organization wants to utilize the strength
of its member groups to pressure Con-
gress for stronger cosmetic safety legis-
lation to protect consumers—both men
and women—from this hazard.
• A majority of working women,
work in the service industry, retail
trades, and in clerical occupations.
These jobs, though they expose workers
to a plethora of occupational hazards,
are termed "low-risk" by the Occupa-
tional Safety and Health Administration.
Restaurant workers, for example, daily
face: burns, heat stress, muscular in-
juries, mental stress, microwaves, cuts,
and other hazards that go unregulated
and unprotested. Most workers are not
aware of the hazards that they face, or
their rights under the law. WEH wants
to develop, in conjunction with the com-
mittees on occupational safety and
health and unions, educational materials
for women workers whose health needs
are being ignored.
• Nursing mothers throughout the
U.S. and around the world are passing
pesticide residues and other toxic con-
taminants to their babies through breast-
milk. In some cases chemical levels
several hundred times the accepted daily
intake established by FDA have been
found, WEH reports. WEH believes
women have the right to know whether
their breastmilk is safe, and, if not, what
can be done to make it safe.
As the coalition grows new issues
will develop. More information from or
about WEH, can be obtained from
Carolyn Projansky, Women for Envi-
ronmental Health, 1747 Connecticut
Avenue, N.W., Washington, D.C. 20009,
(202)667-2140.Q
after birth), blood associated with the um-
bilical cord, and the possibility of contam-
ination before birth through the placenta.
The infants will be examined at three and
six weeks, and three and six months. Dr.
Rogan has said he expects there will not
be any startling news and that perhaps the
study will reaffirm that low-level chemical
contamination of mother's milk poses very
slight danger to mother and child. He will
not be able to draw any conclusion about
occupational exposure since none of the
mothers in the test group works with
chemicals.
Dr. Marcus Wassermann and his col-
leagues at the Department of Occupational
Health of the Hebrew University of Jeru-
salem are conducting a worldwide study
on the exposure of humans and our environ-
ment to PCB's. In an unpublished paper.
Dr. Wassermann commented that, "PCB's
have become current constituents of the
human body and the biological environ-
ment." PCB residues in breast milk have
been reported in several countries in
Europe, North America, and Asia.
After almost 30 years of research, the
immediate and long-range effects of chem-
ical residues on mothers and infants are
still unknown. A newly formed coalition.
Women for Environmental Health, has
made this issue a priority item for the
coming year.
The public needs to know the effects on
mothers and their infants of chemical resi-
dues to be found in breast milk. They need
to know what effect, if any, diet has on
levels of pesticides in the human body.
What effect do geographical and occupa-
tional differences have on pesticide levels?
Most important, what health effects or
implications do chemical residues have
for infants?
In a recent issue of the EPA Journal,
Administrator Douglas Costle and Deputy
Administrator Barbara Blum stated that for
the fiscal years 1979 and 1980 a top
priority will be protecting the public health;
and further, that Research and Develop-
ment will be strengthening its health effects
work. With this kind of effort and commit-
ment, EPA hopes to help resolve the con-
troversy over the health effects of chemical
residues in mother's milk. D
NOVEMBER/DECEMBER 1978
39
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Report
By Donald Dubois
Regional A dministrator
In early June of this year, when
EPA's Northwest Regional
Office in Seattle announced its
acceptance of the Oregon De-
partment of Environmental
Quality's plan to limit air pol-
lution from the burning of fields
on 800 individual Willamette
Valley grass seed farms, it was
more than just a transaction
between two government
agencies.
The EPA anouncement was
the culmination of a process
that involved the delicate bal-
ancing of conflicting demands
that at times appeared irrecon-
cilable: an end to the nuisance
and esthetic blight of summer-
time smoke intrusions over the
cities of Eugene and Spring-
field, the protection of the
multi-million-dollar grass seed
industry from substantial finan-
cial losses, and—above all—
the need to prevent violations
of total suspended particulate
standards that would affect
human health.
How to control particulates
from the burning of grass seed
fields was a problem of long
standing. In recent years, the
controversy has been centered
on the question of just how
many acres the growers could
burn. Burning of the fields after
harvest was essential, accord-
ing to the growers, because it
was the only method available
to control plant disease, insects
and weeds, and also to elim-
inate the cost of removing and
handling the four tons per acre
of straw that remains on fields
after harvest.
Burning is necessary, said
the growers, to preserve the
yields of grass seed that pro-
duce 95 percent of the world's
ryegrass seeds, more than 80
percent of the turf seeds, and
more than 70 percent of the
forage type grasses. The value
of the crop averages $48 mil-
lion a year, and it is estimated
that nearly 9,000 Oregonians'
jobs are dependent on the
industry.
On the other hand, the Wil-
lamette Valley has been desig-
nated a non-attainment area for
total suspended particulates.
Field burning, a significant
contributor to the amount of
particulates in the Valley's air-
shed, required control in order
to meet air quality standards.
EPA and the Oregon Depart-
ment of Environmental Quality
(DEQ) began the year in what
seemed to be an impasse. The
DEQ, bound by an act of the
State Legislature that pre-
scribed acreage limitations,
submitted a plan that called for
1 80,000 acres to be burned.
But EPA, after evaluating the
plan, determined that it could
not be accepted under the
Clean Air Act as a revision to
the State Implementation Plan
because it would not insure
attainment of the health-related
particulate standards. Without
a revised plan, the growers
would be bound after the 1978
harvest to an SIP already on the
books that limited the burning
acreage to only 50,000—a re-
striction that not only appeared
to defy the will of the State
Legislature, but one that grow-
ers complained they could not
live with.
With the Legislature not in
session in 1978, DEQ and EPA
could not look to the Legis-
lature to break the impasse.
Unless something were done,
growers would be faced with
almost certain financial sacri-
fice or, just as bad, there was
the possibility of litigation that
could have left DEQ and EPA
without any control plan at all.
At this point, EPA looked for
solutions from the two parties
most directly affected. On the
one hand, the growers; on the
other, the City of Eugene whose
residents endured the nuisance
of smoke intrusions and faced
the threat of adverse health
impacts.
Considering the distance be-
tween the two parties (i.e., the
growers who would prefer no
field burning controls at all, and
the City of Eugene which at one
time favored an all-out ban on
burning), it was not surprising
that they did not come to an
agreement. They did come
close, and their discussions
formed the basis for a compro-
mise plan DEQ submitted in
May to EPA. The terms of the
plan, good until Oregon submits
a revised SIP in 1979, provided
for burning of up to 180,000
acres, but only if growers used
new burning techniques and
paid proper attention to weather
conditions and other consid-
erations that would alleviate
the emissions of particulates to
the atmosphere.
The terms of the plan were
less important than the means
by which it was developed.
The 1 978 field burning plan,
produced in a crucible of tre-
mendous deadline pressure, is
a tribute to the willingness of
persons with competing points
of view to sit down together to
find common ground on which
fair and workable compromises
could be reached. That's the
way it should be whenever pol-
lution control problems pit one
segment of the public against
another, whenever benefits for
many require sacrifices for
many others.
When it comes to environ-
mentally related trade-offs,
government's role should be
limited to seeing to it that
standards are met, that regula-
tions are implemented and that
guidelines are followed. The
business of working out the
trade-offs should be left to local
business, local government and
local citizens. EPA and the
OU.S. GOVERNMENT PRINTING OFFICE: I978 O— 620-064 'lo
40
EPAJOURNAL
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Oregon Department of Environ-
mental Quality did just that
with the field burning issue.
Alaska and the Pacific North-
west face a number of tough en-
vironmental problems in the
years ahead. Along the Pacific
Coast, where rainfall often
amounts to more than 100
inches a year, it may be difficult
for local landfill operators to
meet EPA's criteria to prevent
the leaching of harmful chemi-
cals into groundwater or near-
by lakes, rivers or streams.
Downtown merchants in Boise
and Anchorage will have to
come to terms with the un-
pleasant fact that their cities—
like Portland, Seattle, and
Spokane—may have to adopt
transportation controls to re-
duce air pollution from auto-
mobiles. It's a virtual certainty
that many farmers in the North-
west may have to change the
way they till their fields, apply
fertilizers or use pesticides in
order to reduce non-point water
pollution. The forest products
industry faces the prospect of
having to adopt a best manage-
ment practice approach to
solving air and water quality
problems associated with tim-
ber harvesting. Proposals for a
Northwest trans-shipment facil-
ity to handle Alaskan oil must
be evaluated in the context of
preserving clean air and clean
water. Local sentiment against
the designation of hazardous
waste disposal sites is an im-
pediment to finding places to
get rid of dangerous chemicals
and other materials.
Those are some of the issues
that challenge EPA in Ala ska
and the Pacific Northwest. The
best solutions to those prob-
lems probably won't come from
EPA or other agencies of gov-
ernment. They will more likely
come from businessmen, farm-
ers, environmentalists, citizen
groups and others working in a
spirit of accommodation and
mutual respect. That's the way
EPA's Region 10 will continue
to make things happen. [~]
Inside Back Cover: The mouth
of the Columbia River between
Astoria, Ore,, and the State o)
Washington.
Back Cover Twilight at Moose
River near Old Forge. N. Y
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