&EPA
WHAT IS
PROJECT XL?
WHAT IS THE P2
FRAMEWORK?
United States
Environmental Protection
Agency
Office of the
Administrator
[Mail Code 18021
EPA-100-F-00-031
September 2000
(http://www.epa.gov)
Project XL: Kodak
P2 FRAMEWORK
—
Project XL, which stands for "excellence and Leadership," is a national initiative that
tests innovative ways of achieving better and more cost-effective public health and
environmental protection. The information and lessons learned from Project XL are
being used to assist the U.S. Environmental Protection Agency (EPA) in redesigning
its current regulatory and policy-setting approaches. Project XL encourages testing of
cleaner, cheaper, and smarter ways to attain environmental results superior to those
achieved under current regulations and policies, in conjunction with greater
accountability to stakeholders. It is vital that each project tests new ideas with the
potential for wide application and broad environmental benefits. As of September
2000. thirty-two pilot experiments are being implemented and over twenty additional
projects are in various stages of development.
The Pollution Prevention (P2) Framework is a set of chemical screening methods that
EPA's Office of Prevention, Pesticides and Toxic Substances (OPPTS) developed to
screen chemicals and products for risk in cases where data are missing or limited.
OPPTS developed the P2 Framework to help screen pre-manufacture notifications
(PMN) for new chemical substances that are submitted to the Agency under Section 5
of the Toxic Substances Control Act (TSCA). TSCA requires that prospective
manufacturers (or importers) wait 90 days after submitting a PMN before they can
begin to manufacture (or import) a new chemical substance. Within that 90-day
period, the Agency must evaluate the report and identify potential risks of the new
chemical substance. The P2 Framework has allowed the Agency to screen new
chemical substances quickly in the absence of data.
SUMMARY OF
THE KODAK XL
PROJECT
SUPERIOR
ENVIRONMENTAL
PERFORMANCE
Kodak manufactures cameras, scanners, film, and photographic paper and chemicals.
As a leader in new technology development in the imaging industry, Kodak registers
many new chemical substances with the EPA each year. Under this project, Kodak's
facility in Rochester, NY, will use the P2 Framework and seek administrative flexibility
to manufacture PMN chemicals for commercial test marketing 45 days, rather than 90
days after notification to EPA. Kodak will use the P2 Framework during the early
stages of product development, allowing them to improve the environmental
performance of products while reducing costs, saving time, enhancing competitive
advantage, and decreasing potential liability. Kodak also will conduct a series of
innovative actions to demonstrate to other stakeholders how the P2 Framework can
help develop products that are both environmentally and economically sustainable.
This XL project, EPA's 32nd, was signed on September 14, 2000.
By using the P2 Framework, Kodak will be able to develop products and processes
that are innovative, cleaner, and safer for the environment, in less time, while
operating manufacturing and waste handling processes at higher levels of
environmental performance.
FLEXIBILITY
Under the Toxic Substances Control Act (TSCA). a prospective manufacturer must
wait 90 days after submitting a pre-manufacture notice (PMN) before beginning to
manufacture a new product. EPA often concludes its review of the PMN after 28 days
for chemicals that are identified as "low risk" Through its use of the P2 Framework,
Kodak expects that EPA generally will complete its review of Kodak's PMN chemicals
within 28 days or less. Kodak therefore proposes that, in cases where EPA's review of
Page"!
-------
Kodak's PMN is completed in 28 days, it be allowed to begin manufacture after 45
days rather than 90,days. The shortened 45-day waiting period will be available only
for chemicals for which EPA has no further concerns.
STAKEHOLDER
INVOLVEMENT
APPROACHES TO
BE TESTED
Public meetings were held to inform the general public about this XL project and invite
their comments and participation. Kodak will work with its Active Kodak Park
Community Advisory Council to involve citizens and others interested in this project.
Kodak also publishes a bi-monthly update, in which they will notify stakeholders about
the status of the XL project and encourage participation.
* Will use of the P2 Framework early in the design and development of chemical
substances result in products that are safer and better for the environment?
• Will shorter EPA review periods for chemicals identified as low-risk products reduce
costs, decrease potential liability, and improve market share-resulting in a
competitive advantage for companies?
CONTACTS
EPA Region 2:
EPA Headquarters:
Kodak:
Aleksandra Dobkowski-Joy
Janet Murray
Bill Waugh
Maggie Wilson
John O'Donoghue
212-637-3676
202-260-7570
202-260-3489
202-260-3902
716-588-4741
FOR ELECTRONIC
INFORMATION
More information about the Kodak XL Project, or the Project XL Program, is available
on the Internet at http://www.epa.gov/projectxl under "Information on Specific XL
Projects," or via Protect XL's Information Line at 202-260-5754.
Page 2
------- |