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                                   APH  27  2010

MEMORANDUM


SUBJECT:    OCSPP Final FY 2011 NationaLPrpgram Manager (NPM) Guidance to Regions
                                I  ^
FROM:       Steve Owens^^-^K/	X
             Assistant Administjraipr

TO:           Regional Division Directors I-X
       I am pleased to transmit the Office of Chemical Safety and Pollution Prevention's
Final FY 2011 National Program Manager Guidance. This guidance defines our FY 2011
program priorities, implementation strategies and performance measures in accordance with
EPA's Draft 2009 - 2014 EPA Strategic Plan and FY 2011 Annual Plan and Budget and
reflects Administrator Jackson's new priorities.

Overarching Program Priorities

       The OCSPP guidance for FY 2011 represents participatory dialogue with EPA
Regional Offices, States, Tribes and other concerned stakeholders. This guidance was also
developed with improved coordination with the Office of Enforcement and Compliance
Assurance (OECA) to align program and enforcement priorities, ensure that our work
supports each other and continue to strengthen and focus our joint strategic planning.
Included in the Guidance are Regional office program priority areas and strategies that were
identified by the Office of Pollution Prevention and Toxics (OPPT) and the Office of
Pesticide Programs (OPP).

       OPPT ensures the safety of new chemicals entering U. S. commerce, assesses the safety
of existing chemicals already in use and acts to reduce identified risks through a combination of
regulatory and voluntary efforts, promotes the development and use of safer chemicals and
technologies, promotes pollution prevention as the guiding principle for controlling pollution,
and reduces legacy chemical risks (e.g., childhood lead poisoning) resulting from prior industrial

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revolutions and practices. OPPT's Regional Office performance priorities include: reducing the
incidence of childhood lead poisoning nationally and in targeted vulnerable populations by 2011
and beyond; enhancing existing Pollution Prevention activities through alignment with and
implementation of the P2 Program Strategic Plan; and, reducing risks from other high-concern
chemicals.  OPPT's overall  objectives and measures are found in Goals 4 and 5 of the
developing Draft 2009-2014 EPA Strategic Plan. For more information on OPPT, go to
http://www.epa.gov/opptintr/.

       OPP regulates the use of all pesticides in the United States and establishes maximum
levels for pesticide residues in food, thereby safeguarding the nation's food supply. EPA has
expanded access to information on risk assessment and risk management actions to help increase
transparency of decision-making and facilitate consultation with the public and affected
stakeholders. In addition to its regulatory functions, OPP's programs include providing
information and coordination on issues ranging from worker protection to prevention of misuse
of pesticides. OPP participates in a variety of partnerships related to pesticide use, including the
Pesticide Environmental Stewardship Program, a voluntary private and public partnership
dedicated to reducing pesticide use and risk, and  Integrated Pest Management (TPM) in Schools.
OPP's performance priorities include pesticide worker safety, Protection of Water Sources from
Pesticide Exposure, implementation of the Pesticide Container-Containment Rule, and
Antimicrobial Hospital Disinfectant Efficacy. Some of these priority activities are included in
this Guidance for significant action.  At this time, others are more Headquarters focused, but may
require Regional and State engagement with stakeholders. While the Strategic Agricultural
Initiative (SAI) is not proposed as an NPM priority for FY 2011, the Agency remains committed
to SAI as an important tool for addressing the FY 2011 NPM priorities and helping growers
transition to less toxic farming practices.  We expect the regional and OPP investment in SAI
will remain unchanged from previous years. OPP objectives and measures are found in goal 4 of
the Draft 2009-2014 EPA Strategic Plan which is currently under development. For more
information on OPP,  go to http://www.epa.gov/pesticides/.

       OCSPP programs understand that the priorities highlighted in the guidance will require
some flexibility in order to accommodate Regional Office, State, Tribal and local concerns on a
region-by-region basis. We will continue to foster innovation and re-engineer the way we work
together to establish common directions for our programs.

Administrator Jackson's Priorities

       Administrator Lisa Jackson recently outlined her seven top priorities for EPA in the
January 12, 2010 memorandum. All of the items on her list are important, but one-" Assuring
the Safety of Chemicals"-is particularly significant for OCSPP and will guide our work in the
years ahead. The Administrator is counting on us to take the lead in enhancing chemical risk
management in this country, and she has great confidence in our ability to get the job done. I
look forward to continuing to work with all of you as we implement Administrator Jackson's
vision and priorities for EPA.

Children's Health and Environmental Justice

       As noted in one of Administrator Jackson's priorities, children's health and
environmental justice principles should be an intrinsic part of decision-making at every level of


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the Agency. To this end, we are integrating children's health and environmental justice
perspectives into our rulemaking and decision making processes to improve children's health
protection and more effectively address environmental justice concerns. OCSPP will continue to
support and build on existing activities and accomplishments to ensure policies, programs,
activities, and standards address disproportionate risks to children and other vulnerable
populations where possible. Additional language has been added throughout the guidance to
highlight those activities.

Strengthening State Grants

       EPA continues to work with State and Tribal partners and other grant recipients to
improve performance measures and enhance the alignment of State Grant Workplan goals
and measures with EPA's national performance goals and measures.  These improvements
have enhanced the Agency's ability to demonstrate grant results to OMB, Congress and the
public. It is important that EPA and the States and Tribes build on these efforts to ensure
that grant workplans meet the basic requirements necessary to facilitate the translation of
grant results into the Agency's strategic and annual planning, budgeting, and accountability
processes.  Additional  information on grants improvements and the grants management
process can be found at http://www.epa.gov/ogd.

FY 2011 Performance Measurement and Alignment

       OCSPP headquarters and regional program managers and staff completed their internal
measures improvement workgroups last year to assess the quality and utility of the performance
measures and to recommend any necessary improvements to the FY 2011 measures. As a result,
we are introducing this limited suite of regional performance measures to streamline the
reporting requirements, reduce reporting burden on the Regions, manage critical program
activities needed to achieve strategic goals, and support Administrator Jackson's priorities.
Attachment A provides our draft list of FY 2011 NPM Guidance measures and Attachment B
also lists the FY 2011 changes in our priorities, strategies, and measures since the Final FY 2010
NPM Guidance.  The FY 2011 measures in the Annual Commitment System (ACS) will remain
as draft until final performance agreements are reached in October 2010.  Additional information
on the EPA performance measurement, planning and budgeting can be found at
http://www.epa.gov/ocfopage/index.htm.  Specific information on the EPA NPM Guidance can
be found at http://www.epa.gov/ocfopage/npmguidance/index.htm.

Conclusion

       Thank you for your on-going assistance in drafting the FY 2011 guidance.  OCSPP
remains committed to this partnership process and believes that our mutual efforts will focus
and strengthen our activities in the field.  I look forward  to our continued collaboration on
solving the many environmental challenges that we face now and in the future.

       For general  comments or questions, please contact either Jennifer Vernon (202-564-
6573).  For program-specific questions you may contact Daniel Helfgott (OPP/ Field &
External Affairs Division; 703-308-8054), Mike Burns (OPPT/Environmental Assistance
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Division; 202-564-8273), Tala Henry (OPPT/National Program Chemicals Division; Lead
and Asbestos, 202-564-2959), Thomas Tillman (OPPT/ Pollution Prevention Division; 202-
564-8263) or Linda Strauss (OPPT/CARE; 202 564-0797).

Attachments
cc:    Deputy Regional Administrators
      OCSPP Regional Branch Chiefs
      Assistant Administrators
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                          TABLE OF CONTENTS

EXECUTIVE SUMMARY	1
  ENHANCED COLLABORATION WITH OFFICE OF ENFORCEMENT AND
  COMPLIANCE ASSURANCE	1
  STATE GRANT RESULTS AND REPORTING	2
  FY 2011 REGIONAL OFFICE PROGRAM PRIORITIES	3
  REGIONAL OFFICE PROGRAM IMPLEMENTATION STRATEGIES	3
  SIGNIFICANT CHANGES TO PRIORITIES OR STRATEGIES FROM FY 2011	5
  PROGRAM OFFICE CONTACTS	5
KEY PROGRAM PRIORITIES AND STRATEGIES	7
  I.   REDUCING LEAD POISONING	7
    Strategic Plan Targets	7
    Program Description	7
    Children's Health and EnvironmentalJustice	8
    Proposed Principal Activities for the Regional Offices	8
    Proposed Measures	9
    Definitions and Clarification of Measures	10
  II.  REDUCING CHEMICAL RISKS	11
    Strategic Plan Targets	11
    Program Description	12
    Children's Health and EnvironmentalJustice	13
    Proposed Principal Activities for the Regional Offices	13
    Proposed Measures	14
    Definitions and Clarification of Measures	14
  III.    PESTICIDE OCCUPATIONAL WORKER SAFETY (INCLUDING SOIL
  FUMIGATION)	15
    Strategic Plan Targets	15
    Program Description	15
    EnvironmentalJustice	17
    Proposed Principal Activities for the Regional Offices	18
    Proposed Measures	20
    Definitions and Clarification of Measures	20
  IV.    ANTIMICROBIAL HOSPITAL DISINFECTANTS EFFICACY AND
  MISBRANDING	21
    Strategic Plan Targets	21
    Program Description	21
    Proposed Principal Activities for the Regional Offices	22
    Proposed Measure	22
  V.  PESTICIDE CONTAINER-CONTAINMENT REGULATION IMPLEMENTATION 22
    Strategic Plan Targets	22
    Program Description	23
    Proposed Principal Activities for the Regional Offices	24
    Proposed Measures	25
    Definitions and Clarification of Measures	25
  VI.    PROTECTION OF WATER SOURCES FROM PESTICIDE EXPOSURE	25

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    Strategic Plan Targets	25
    Program Description	26
    Proposed Principal Activities for the Regional Offices	27
    Proposed Measures	28
    Definitions and Clarification of Measures	28
  VII.   POLLUTION PREVENTION	28
    Strategic Plan Targets	29
    Program Description	29
    Proposed Principal Activities for the Regional Offices	29
    Proposed Measures	30
    Definitions and Clarification of Measures	30
OTHER PROGRAM ACTIVITIES	33
  PESTICIDE TRIBAL	33
    Program Description	33
    Proposed Principal Activities for the Regional Offices	33
    Proposed Measures	33
    Definitions and Clarification of Measures	34
  COMMUNITY ACTION FOR A RENEWED ENVIRONMENT (CARE)	34
    Program Description	34
    Proposed Principal Activities for the Regional Offices	34
    Proposed Measures	35
    Definitions and Clarification of Measures	35
                                        11

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                            EXECUTIVE SUMMARY

The Office of Chemical Safety and Pollution Prevention (OCSPP) National Program Manager
(NPM) Guidance for FY 2011 results from a participatory dialogue and coordination with other
EPA National Program Managers, EPA Regional Offices, States, Territories, Tribes, and other
concerned stakeholders. (Throughout this document, the term State may also include Territories
and Tribes.) It identifies OCSPP Regional Office priorities and other critical activities needed to
achieve the proposed FY 2011 Annual Performance Plan as articulated in the FY 2011
President's Budget, guided by  the Draft 2009-2014 EPA Strategic Plan. Furthermore, OCSPP
NPM Guidance for FY 2011 supports Administrator Jackson's Priority on Managing Chemical
Risk and integrates the Administrators' Themes into the program implementation strategies and
activities when appropriate.

The OCSPP supports two objectives within the Draft 2009-2014 EPA Strategic Plan:

•      Objective 1 of Goal 4 - Prevent and Reduce Pesticide and Industrial Chemical Risks to
       Humans, Communities, and Ecosystems; and,

•      Objective 2 of Goal 5 - Improve Environmental Performance through Pollution
       Prevention and Other Stewardship Practices.
ENHANCED COLLABORATION WITH OFFICE OF ENFORCEMENT AND
COMPLIANCE ASSURANCE

Steve Owens, Assistant Administrator for OCSPP, and Cynthia Giles, Assistant Administrator
for the Office of Enforcement and Compliance Assurance (OECA), have launched an effort for
enhanced collaboration between the two programs.  Although both Offices have distinct
missions, they are mutually re-enforcing and each program has unique tools and expertise to
bring to bear on the common challenge of protecting the public and environment from pesticide
risks. To address the increasing program demands and issues, the two programs need to work
together even more closely. This includes pursuing joint work and exchanging timely and
meaningful information on case development.

An important part of this cooperative effort is to better align our Offices in articulating common
priorities in the performance management documents for Regions and States.  Clear alignment of
priorities will avoid the inefficient confusion, competing  demands and splintering of limited
resources that can result from inconsistent program management priorities and guidance from
OCSPP and OECA.  Based on inter-program discussions and  input from the Regions, States and
Tribes, improvement has occurred in aligning priorities.

OCSPP' highest priorities  for Regional attention and for OCSPP/OECA collaboration are:

  •  Continued reduction of Lead-based paint risks to children,

  •  Pesticide Worker  Safety, including assistance to support  the new soil fumigation
     requirements,

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  • Protection of Water Sources from Pesticide Exposure,
  • Antimicrobial hospital disinfection efficacy/misbranding, and

  • Pesticide Container-Containment Regulation implementation.

While these are not the only valuable activities for either program, they represent the most
important areas where both offices will work together to achieve meaningful progress on risk
reduction. Some of these priority activities are included in this Guidance for significant action.
At this time, others are more Headquarters focused, but may require Regional and State
engagement with stakeholders.  This coordinated approach will enhance overall program
efficiency and accelerate progress toward achievement of our common strategic objectives.
STATE GRANT RESULTS AND REPORTING

In FY 2011 EPA remains committed to strengthening our oversight and reporting of results from
state grants, not only linking state grant work plan commitments to EPA's strategic plan, but also
enhancing transparency and accountability.  EPA and the States will continue working in FY
2011 to achieve this through two related efforts:

State Grant Workplans:  The Agency's long-term goal is for EPA and the States to achieve
greater consistency in workplan formats. To achieve that goal, the Office of Grants and
Debarment (OGD) will convene a State/EPA workgroup of grant practitioners to develop a menu
of formats for EPA and States to use when negotiating workplans for the 14 identified
categorical  grant programs. In developing these formats, the workgroup will build upon the
results of the FY 2009 State Grant Workplan Pilot.

The formats will be available for use beginning with the FY 2011 grants cycle. In consultation
with the practitioners workgroup,  and recognizing that the formats will need to be  phased in over
time, OGD  will develop performance metrics to ensure that 100% of workplans under the 14
categorical  grant programs use one of the approved formats by no later than the FY 2013 grants
cycle.  If a particular State agency has difficulties under State law in adopting one  of the
established  formats, OGD will work with the affected Region and NPM to resolve the issue.
Please contact Howard Corcoran,  OARM/OGD, at 202-564-1903 should you have any questions.

State Grant Performance Measures (formally known as  State Grant Template Measures):
The current set of measures flagged as State Grant Template Measures in ACS will be retained
for FY 2011 reporting.  As in FY 2010, the use of the template to capture results for these
measures is not required. However, reporting on the results remains the responsibility of the
Regions and States.  The Agency and members of ECOS have had ongoing discussions as to
whether there is utility in identifying a set of common measures that reflect the primary
functional work areas under each of the 14 categorical grants. Issues that have been raised
include how the Agency would capture and use these measures. In FY 2011,  the Agency, in
consultation with ECOS, will evaluate the workplan initiative discussed above and determine
whether it sufficiently enhances transparency and accountability such that developing a common

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set of measures is unnecessary.  Please contact Margo Padgett, OCFO/OPAA, at 202-564-1211
should you have any questions.
FY 2011 REGIONAL OFFICE PROGRAM PRIORITIES

The OPPT Regional Office performance priorities for FY 2011 are:
•     Reduce Lead Risks: Continue progress towards achieving and maintaining federal
      government-wide goal to eliminate childhood lead poisoning and EPA goal to reduce
      disparity in blood lead levels between low income and non-low income children.
•     Reduce Risks from Other High-Concern Chemicals:  Reduce exposure to and risks from
      chemicals of high concern, including legacy chemicals with well established risks and
      newly identified chemicals of concern.

•     Prevent Pollution: Achieve annual targets in hazardous materials, greenhouse gas, water
      use, and cost reductions.
The OPP Regional Office performance priorities for FY 2011 are:
•     Pesticide Occupational Worker Safety: Provide worker protection standard (WPS)
      compliance assistance, education and outreach for growers, applicators and workers, and
      augment state and tribal pesticide worker safely program efforts, including the new soil
      fumigation requirements.
•     Antimicrobial Hospital Disinfectants Efficacy/Misbranding: Address questions from the
      regulated community and the public related to the Antimicrobial Testing Program (ATP)
      and the efficacy of hospital disinfectants and tuberculocides.
•     Pesticide Container-Containment Regulation Implementation:  Reduce incidents
      associated with occupational exposure or environmental exposure that are caused by the
      failure, inadequate storage or improper handling of pesticide containers.

•     Protection of Water Sources from Pesticide Exposure:  Ensure that pesticides do not
      adversely affect the nation's water.
 REGIONAL OFFICE PROGRAM IMPLEMENTATION STRATEGIES

•  Reduce Lead risks:
   o   Provide assistance to States, Tribes, the District of Columbia, and territories to develop
       and implement authorized programs for lead-based paint abatement and Lead-Based
       Paint Renovation, Repair and Painting (RRP) Rule activities, and directly implement
       such programs in unauthorized areas, to:
       •   Certify abatement workers within established time frames;
       •   Accredit providers of renovation and dust sampling technician training; and,
       •   Certify renovators, dust sampling technicians and renovation firms.

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 o  Contribute to a comprehensive outreach and education plan to educate the public about
    the need for certified firms and workers, use of lead-safe work practices, and compliance
    with disclosure and pre-renovation notification requirements.
 o  Coordinate implementation of Lead Program activities with OECA's implementation of
    compliance assistance, monitoring and enforcement strategies encompassing the full suite
    of lead regulations, as articulated in OECA's TSCA Compliance Monitoring Strategy
    (under development).
 o  Increase lead risk awareness in communities with high concentrations of children with
    elevated blood-lead levels (hot spots) and among populations of children most vulnerable
    to lead risks.

Reduce Risks from Other High-Concern Chemicals:
 o  Continue to interpret regulatory requirements to  delegated state and local asbestos
    programs.
 o  Provide assistance to schools regarding Asbestos Hazard Emergency Response Act
    (AHERA).
 o  Help asbestos training providers comply with the Model Accreditation Plan.
 o  Provide assistance to schools in assessing presence of Poly chlorinated Biphenyls (PCBs)
    in caulk and other sources.
 o  Provide assistance as needed in implementing other risk management strategies for other
    chemicals of concern.

Pesticide Occupational Worker Safety (Including  Soil Fumigation)
 o  Continue WPS compliance assistance, education and outreach for growers (including soil
    fumigation), applicators and workers.
 o  Conduct special regional worker safety projects designed to augment state and tribal
    pesticide worker safety program efforts.

Antimicrobial Hospital Disinfectants Efficacy and Misbranding
 o  Address questions from the regulated community and the public related to the
    Antimicrobial Testing Program (ATP) and the efficacy of hospital disinfectants and
    tuberculocides.

Pesticide Container-Containment Regulation Implementation
 o  Support State efforts to implement the new container and containment requirements, and
    assess whether States have developed the capacity to implement the regulations.
 o  Prepare the regulated community to come into compliance with the new regulations.
 o  Conduct special regional projects designed to contribute to the implementation and
    enhancement of the container-containment field  program.

Protection of Water Sources from Pesticide Exposure
 o  Ensure that water quality concerns due to pesticide use are identified and mitigated over
    time.

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   o   Provide technical assistance to support development and implementation of Pesticide
       National Pollutant Discharge Elimination System (NPDES) permits issued under the
       Clean Water Act.
   o   Provide outreach on the new pesticide NPDES permits to pesticide users who may be
       covered by the new requirements where routine opportunities present themselves.

•  Prevent Pollution (P2):
   o   Award and manage P2 State and Tribal Assistance Grants (STAG) to support P2
       technical assistance programs, P2 leadership programs, and other innovative programs
       that promote pollution prevention practices that reduce pollution and use of fossil fuel
       energy sources, and conserve energy use and water use.
   o   Award and manage Source Reduction Assistance grants using Environmental Program
       Management (EPM) appropriation resources to further promote pollution prevention
       practices among entities in the industrial, energy, health, education, transportation,
       agricultural, and other sectors.
   o   Directly promote P2 among businesses, governments, organizations and the public in
       concert with HQ P2 Centers of Results.

SIGNIFICANT CHANGES TO PRIORITIES OR STRATEGIES FROM FY 2011

Information about the Chemical Risk Management Program and the Chemical Risk Review and
Reduction Program is combined into one section to provide a more holistic understanding of
OPPT's strategies and Regional Office contributions to address chemical risks. Regional Office
resources in this area continue to  be limited to the Chemical Risk Management Program, but the
focus is expanded from Asbestos to include other chemicals of concern (e.g., mercury, PCBs)
that may require Regional Office attention in FY 2011 and beyond, consistent with the focus of
the national program.

In the Lead Program, one addition and four deletions to the Region's ACS measures have been
made, implementing decisions made by the Regional Division Directors based on
recommendations from the Regional Offices/HQ workgroup.

While the Strategic Agricultural Initiative (SAI) is not proposed as an NPM priority for FY 2011,
the Agency remains committed to SAI as an important tool for addressing the FY 2011 NPM
priorities and helping growers transition to sustainable farming practices. We expect the regional
and OPP investment in SAI will remain unchanged from previous years.
PROGRAM OFFICE CONTACTS

Office of Pesticide Programs:
      Daniel Helfgott, FEAD (703-308-8054)

Office of Pollution Prevention and Toxics:
      Mike Burns Acting Deputy Director, EAD (202-564-8273)

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Tala Henry, Acting Deputy Director, NPCD (202-564-2959)
Tom Tillman, Deputy Director, PPD (202-564-8263)
Linda Strauss, CARE (202 564-0797)

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              KEY PROGRAM PRIORITIES AND STRATEGIES
    I.  REDUCING LEAD POISONING

Strategic Plan Targets

Sub-Objective 4.1.1: Reduce Chemical Risks. By 2014, prevent and reduce chemical risks to
humans, communities, and ecosystems.

    •   Through 2014, maintain elimination of childhood lead poisoning as a public health
       concern by ensuring that the percent of children (aged 1-5 years) with elevated blood lead
       levels (>10ug/dl) remains at zero, compared to a 2006 baseline of 0.9 percent.

    •   By 2014, reduce the percentage of children with blood lead levels above 5 ug/dl to 2.5
       percent or less compared, with a  1999-2004 baseline of 7.4 percent.

    •   By 2014, reduce to 26 percent the percent difference in the geometric mean blood lead
       level in low-income children 1-5 years old as compared to the geometric mean for non-
       low income children 1-5 years old,  compared to a 1999-2002 baseline of 32 percent.

Program Description

Recent data show that tremendous progress has been made in the continuing effort to eliminate
childhood lead poisoning as a public health concern. EPA has measured progress by tracking
reductions in the number of children with elevated blood lead levels of 10 micrograms per deciliter or
higher.  Data released in 2009 by the Centers for Disease Control and Prevention indicate that the
incidence of childhood lead poisoning, defined as above, has declined from approximately 1.6 percent
of children in 2002 to 0.9 percent of children in 2006.  The data show that EPA is on track to meet
ambitious federal government-wide goals to eliminate childhood lead poisoning as a public health
concern at those blood levels.

At the same time, new data are revealing adverse health effects to children at lower levels than
previously recognized.1  EPA, therefore,  plans to begin measuring progress by tracking reductions in the
number of children with elevated blood lead levels of 5 micrograms per deciliter or higher. Thus, even
though initial gains have been encouraging, EPA wishes to achieve further reductions in the incidence
of children with these lower, but still significantly elevated, blood levels.
1 U.S.EPA.  Air Quality Criteria for Lead (September 29, 2006)
http://cfpub.epa.gov/ncea/CFM/recordisplav.cfm?deid=158823

Rogan WJ, Ware JH. Exposure to lead in children - how low is low enough? NEngl JMed.2003;348(16): 1515-
1516 http://www.precaution.org/lib/rogan.nejm.20030417.pdf

Lanphear BP, Hornung R, Khoury J, et al. Low-level environmental lead exposure and children's intellectual
function: an international pooled analysis. Environ Health Perspect. 2005; 113(7):894-899
http://www.pubmedcentral.nih.gov/articlerender.fcgi?doi=10.1289/ehp.7688

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                     KEY PROGRAM PRIORITIES AND STRATEGIES
EPA's Lead Risk Reduction program contributes to the goal of alleviating the threat to human health,
particularly to young children, from environmental lead exposure in the following ways:

    •   Establishes standards governing lead hazard identification and abatement practices and
       maintains a national pool  of professionals trained  and certified to  implement those
       standards;

    •   Provides information to housing occupants so they can make informed decisions and take
       actions about lead hazards in their homes;

    •   Establishes lead-safe work practice standards for  renovation, repair and painting projects
       in homes and child-occupied facilities with lead-based paint;

    •   Works to establish a national pool of  renovation contractors trained and certified to
       implement those standards.
For more information please visit http://www.epa.gov/lead.

Children's Health and Environmental Justice

OPPT's Lead risk reduction program - with its twin goals of eliminating childhood lead
poisoning and reducing blood lead level disparities between low income and non-low income
children - has long been recognized as one of EPA's premier children's health and
environmental justice strategies.  In addition to being the program's overall focus the Lead
Program has awarded several million dollars in grants in recent years to conduct specific
activities to reduce incidences of childhood lead  poisoning in vulnerable populations of at-risk
children and communities with a high concentration of children with elevated blood-lead levels
(hot spots)and conducted other environmental justice activities including outreach and public
education in appropriate languages of the community, monitoring, training, and other innovative
means of communication with communities regarding reducing the risk of lead poisoning.  In
addition, the Program has awarded millions of dollars in grants to support Tribal efforts to reduce
lead risks. The Lead Program plans to continue and increase the vigilance of these efforts in FY
2011 and beyond in its continued pursuit of its landmark children's health  and environmental
justice goals.

Proposed Principal Activities for the Regional Offices

    1)  Implement lead-based paint risk reduction education, outreach and regulatory
       implementation programs in target areas with high concentrations of children with
       elevated blood levels.

    2)  Continue overseeing the Section 404(g) grant program to maintain  a trained workforce of
       lead-based paint professionals in authorized states and continue operating the program in
       non-authorized states.

    3)  Provide outreach of the Pre-Renovation Education Rule (406) and Disclosure Rule
       (1018).

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                     KEY PROGRAM PRIORITIES AND STRATEGIES
   4)  Support the Training and Certification Rule (402) in EPA States and Tribes; and
       coordinate with State and Tribal programs, as needed, for 402 rule compliance assistance
       in authorized states.

   5)  Pursue opportunities for partnerships to address lead-paint based hazards and exposure
       reduction.  For example, utilize the Indian Health Service Environmental Health Office to
       accommodate Tribes in this area by performing lead-based testing in sensitive areas
       where children are prone to 8-hour activity.

   6)  Continue implementing the Lead-Based Paint Renovation, Repair and Painting (RRP)
       Rule including providing Section 404(g) grants to States, Tribes, and territories to
       develop and carry out authorized programs; working with the grantees to encourage
       successful  delegation of the rule; working to accredit qualified training providers;
       providing information and compliance assistance to firms and other regulated parties, as
       well as beginning the certification process for firms; and providing effective public
       outreach so that demand for qualified RRP contractors is strong.

   7)  Coordinate implementation of Lead Program activities with OECA's implementation of
       compliance assistance, monitoring and enforcement strategies encompassing the full suite
       of lead regulations, as articulated in OECA's TSCA Compliance Monitoring Strategy.

Proposed Measures
 ACS
 Code
           Regional Measure
   Unit of
  Measure
     Comments
  13A
   Annual percentage of viable lead-based
  paint abatement certification applications
    that require less than 20 days of EPA
    Regional effort to process (For Direct
 Implementation - Regional Office efforts)
   Percent
  13B
   Annual percentage of viable lead-based
  paint abatement certification applications
   that require less than state-established
   timeframes to process (for authorized
 	States).	
   Percent
     State Grant
Performance Measure
   14
 Number of abatement activities performed
 by certified abatement workers occurring in
	the Regions	
 Abatement
  Non-Commitment
      Measure
 RRP2
  Number of active accreditations for lead-
 based paint renovation, repair and painting
    certification training providers in the
	Region.	
 Number of
accreditations
  Non-Commitment
      Measure
 TR-1
  Number of tribal partnerships addressing
   lead based paint hazards and exposure
                reduction.
 Partnerships
  Non-Commitment
      Measure

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                     KEY PROGRAM PRIORITIES AND STRATEGIES
Definitions and Clarification of Measures

An internal measures workgroup comprised of Regional Office and Headquarter (HQ)
management and staff developed a new suite of measures for FY 2011, reflected in the table
above. The measures were approved by the Regional Division Directors and are described
below. These refined measures better reflect work currently done in Regional offices by more
comprehensively describing how Regional Office activities are supportive of the overall
programmatic goals.

ACS measure 14 is a new measure which looks to measure the number of abatements that occur
within each state.  The measure will provide valuable information on the true impact of the
abatement contractors certified by EPA and the authorized programs.

ACS Measure 13 A examines the efficiency of the Regions as they process viable individual
abatement certification applications. EPA Regions are measured on the number and percentage
of individual certification applications processed in less than 20 calendar days. This measure is
calculated by using two timeframes. Timeframe 1 is the number of days elapsed from the "Sent
to Region" date (when the contractor sends the application to the Region) to the "Region
Review" date (when the Region enters its recommendation to approve/disapprove.)  Timeframe 2
is the number of days from the "Approval or Disapproval Letter Generated" date entered by the
Region to the "Final Package Sent" date entered by the Region.

Timeframes 1 and 2 are added together to give the total processing time.  These two timeframes
do not include time from any other federal Lead-based Paint Program (FLPP) process and
specifically exclude any time associated with fee confirmation.  All of the dates discussed are
only valid if recorded in FLPP, and the date recorded in FLPP is the date that these activities are
checked off in the database. For example, if a final package is mailed to an applicant on
September 1, and then two weeks later (on September 15) the Regional staff enters FLPP to
update the database, and clicks the "Final Package Sent" radio button for that application, the
September 15 date is entered into FLPP as the date the final package is was sent (rather than the
actual September 1 date).  This cannot be overridden, so be sure to enter your progress on the
day that you accomplish each action.

ACS measure 13B is a state grant performance measure which examines the efficiency of
authorized Grantee-States as they process viable abatement certification applications within the
Grantee-State established timeframes. Regional Offices should ensure that their respective states
achieve the minimum planning target, stated as the Regional Office bid.   The Regional Offices
should use the comment field to report their authorized Grantee-State timeframes (number of
days taken by Grantee-State to process a viable application) for each shareholder (State or Tribe)
and the percentage of applications processed under the Grantee-State established timeframe. The
timeframe may vary by  State, taking variables such as regulations and contractor processing time
into account. The number agreed upon  should be a reasonable determination that reflects the
length of time that it takes the Grantee-State to process an application, as identified by the
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                    KEY PROGRAM PRIORITIES AND STRATEGIES

Grantee-State and represented to the public. Below is an example of the information that should
be reported by the Regional Offices in the comment field.
Shareholder
AL
GA
KY
MS
NC
TN
Timeframe (calendar days)
25
20
20
10
20
60
% Processed within timeframe
72.5
75
72
75
72
100
ACS measure RRP2 is a non-commitment measure which seeks to capture the number of
training accreditations for Renovation, Repair and Painting (RRP) work. Ensuring an adequate
workforce of accredited, qualified and competent training providers is important to a successful
ongoing RRP program.

ACS measure TR-1 is a continuing non-commitment measure which tracks the number of tribal
partnerships or other projects addressing lead-based paint hazards and exposure reduction on
tribal lands.  Tribal partnerships are a more focused subset of overall lead partnerships.
Examples of tribal partnerships or projects include: Direct Implementation Tribal Cooperative
Agreements (DITCAs), on-going projects, outreach, DITCA related activities, cooperative
agreements, formal agreements, tribal grants, Memoranda of Understanding (MOUs),  etc.
   II.  REDUCING CHEMICAL RISKS

Strategic Plan Targets

Sub-Objective 4.1.1: Reduce Chemical Risks. By 2014, prevent and reduce chemical risks to
humans, communities, and ecosystems.

   •   By 2014, achieve a 50 percent cumulative reduction from 1998 in risks posed by TSCA
       Inventory Update Rule-reported chemicals, as measured by the Risk Screening
       Environmental Indicators model's production-adjusted risk based score.  (Baseline:
       cumulative reduction reported from 1998-2006 is 33 percent.)

   •   By 2014, ensure that 100 percent of new chemicals introduced into commerce do not
       pose unreasonable risks to workers, consumers, or the environment.
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                     KEY PROGRAM PRIORITIES AND STRATEGIES
Program Description
The Chemical Risk Management (CRM) Program supports national programs to lessen chemical
risk and exposure through  reductions in use and  safe removal, disposal and containment of
certain prevalent, high-risk chemicals, known generally as legacy  chemicals.  Some of these
chemicals were used widely in commerce and introduced into the environment before their risks
were known.  The CRM Program currently focuses on providing assistance to Federal agencies
and others  with  responsibility  for ensuring proper use of polychlorinated biphenyls (PCBs),
reducing or eliminating the use of products containing mercury, and implementing statutory
requirements to address asbestos risks in schools. In FY 2010, OPPT issued an Advance Notice
of Proposed  Rulemaking  (ANPR)  on the  Agency's potential reassessment of  its  current
authorizations for PCB use and distribution in commerce and held a series of public meetings to
gather comments, data  and information on certain areas  of the PCB regulations under TSCA
from stakeholders.

The Chemical Risk Review and Reduction Program (CRRR), which does not house any direct
Regional Offices resources,  spans the full range of EPA activities associated with screening,
assessing and reducing risks of new and existing chemicals. However, many Regional Offices
seek to advance CRRR efforts through collateral activities under other EPA Statutes (e.g., the
Safe Drinking Water Act, Resource Conservation and Recovery Act,  etc.),  EPA Programs (e.g.,
Children's Health, Environmental Justice, Ecosystem Offices, etc.) or as a  result of State
initiatives or requests for assistance.  Regional Offices may, directly or indirectly, through
collateral work, address CRRR efforts through data gathering and management, outreach or other
collaborative efforts.  Key program efforts at Headquarters include:

   •   Reviewing and  acting on 1,500 TSCA Section 5 notices,  including Pre-Manufacture
       Notices (PMNs), received annually to ensure no unreasonable risk by new chemicals
       before they are introduced into U.S. commerce.

   •   Assessing and acting on the thousands of existing chemicals already in commerce before
       the Toxic Substances Control Program (TSCA) took effect, including:

          o  Obtaining and managing data to support hazard assessment and risk management
             actions for High Production Volume (HPV) chemicals (produced in volumes
             greater than one  million pounds per  year), and processing  2010 TSCA Inventory
             Update (IUR) reports anticipated to  be submitted in FY 2011 for approximately
             7,000 existing chemicals produced in quantities  greater than 25,000  pounds in
             2010 and  making IUR  data  publically  available  more  quickly  than  in past
             reporting cycles;
          o  Assessing the hazards  and  risks of High Production Volume  (HPV) and other
             existing chemicals; and,
          o  Taking risk management action to reduce human health and environmental risks
             posed  by  a  number  of priority existing  chemicals  using  TSCA  regulatory
             authorities
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

Children's Health and Environmental Justice

OPPT is developing risk management plans for chemicals of concern and is committed to
expanding its consideration of children's health and environmental justice concerns in
developing and implementing associated regulatory and non-regulatory risk management actions.
OPPT will be implementing pending Agency guidance to address environmental justice concerns
in all stages of the rulemaking process through new and expanded analyses and invigorated
efforts to meaningfully engage low income, minority and tribal populations, the Regions and
their State and local partners in the decision making process.  To advance these efforts, OPPT is
working to develop better methods to estimate the disproportionate impact of chemical
exposures. While the Office has developed exposure tools and models2 and has access to some
data needed for these types of analyses, we are working to improve our capabilities, in
collaboration with other Federal Agencies, EPA NPMs, EPA Regional Offices, and State and
Tribal partners. Certain subpopulations such as children and the elderly are disproportionately
affected by exposure to certain chemicals of concern. For example, OPPT will look more
closely at possible impacts to children and other sensitive subpopulations for Long-Chain
Perfluorinated Chemicals3 and Short-Chain Chlorinated Paraffins4.  OPPT will continue to work
closely with other Federal agencies working on these priority chemicals.  In addition, legacy
chemicals such as asbestos and PCBs have well-defined human health effects and exposure
pathways that frequently involve children, particularly children living in low income, minority
and tribal communities (e.g., asbestos and PCBs in schools). OPPT will continue to manage
these risks with special attention to protecting these vulnerable populations.

In the case of the interaction between OCSPP programs and schools, efforts should be taken to
improve coordination among OCSPP programs and with other NPMs to ensure consistency in
our messages/direction to schools and reduce burdens stemming from duplicative interactions
with school officials.

Proposed Principal Activities for the Regional Offices

    •   Chemical Risk Management Program:

          1)  Maintain education and outreach efforts to bring schools into Asbestos Hazard
              Emergency Response Act (AHERA) compliance.

          2)  Promote education and outreach efforts, especially with new materials now under
              development. As an example, education and outreach activities can be delivered
              to any of the following: Local Educational Authorities (LEAs), School
              Districts/Boards, individual schools (including charter schools), Principals, PTA's
              (including individual parents  and teachers), maintenance workers, and individual
              students. This education and outreach can be accomplished through any of the
              following mechanisms: web products, written publications (fact sheets, booklets,
2 http://www.epa.gov/oppt/exposure/
3 http://www.epa.gov/oppt/existingchemicals/pubs/pfcs_action_planl230_09.pdf
4http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/sccps_ap_2009_1230_final.pdf
                                           13

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                     KEY PROGRAM PRIORITIES AND STRATEGIES

             reports), public meetings, conferences, exhibits, community outreach, training
             sessions, award programs, mass mailings (electronic or postal), and phone calls.

          3) Work with training providers to ensure compliance with requirements.

          4) Provide assistance to schools when requested in assessing presence of PCBs in
             caulk and other sources.

          5) Provide assistance as needed in implementing other risk management strategies
             for other chemicals of concern.

       Chemical Risk Review and Reduction Program:

       No Regional activities are proposed for FY 2011 under the Chemical Risk Review and
       Reduction (CRRR) Program due to the absence of direct resources appropriated to
       Regional Offices under this Program/Project.
Proposed Measures
 ACS
 Code
           Regional Measure
 Unit of
Measure
Comments
  ISA
   Number of children reached through
  outreach activities (e.g., public meetings,
conferences, exhibits, community outreach,
  training, award programs, mass mailings,
   phone calls, etc.) conducted to address
                asbestos.
Children
  15B
  Number of outreach products produced
  [e.g., web products, written publications
  (fact sheets, booklets, reports), exhibits,
training packages, mass mailings (electronic
  or U.S. postal mail) addressing asbestos.
Products
Definitions and Clarification of Measures

ACS measure ISA seeks to track the number of children reached through outreach activities as
well as identifying the type of activities utilized by the Regional Office.  The Regional Offices
will use the ACS comment field to report the outreach activities they coordinated to reach the
targeted number of children.

ACS measure 15B seeks to track the number of products produced by the region that will
partially generate the outputs in measure ISA. Product development is distinct from using
products in outreach efforts and merits recognition through ACS.
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

Example 1: Region G reported that they reached 250,000 school children by participating in 3
distinct activities.  This would be reported as 250,000 for measure 15A and 3 for measure 15B.

Example 2: Region Q participated in 6 Local Educational Authorities (LEA) designee
workshops, providing specific briefings on the AHERA program requirements. Workshops
occurred in Bath, NY; Neversink, NY; Result, NY; Surprise, NY; Brick, NJ; and  Good Intent,
NJ where 75,000 school children were reached. 75,000 would be reported in measure 15A and
the 6 workshops would be reported for measure 15B.

Example 3: Region R developed a brochure and a training video on implementing AHERA and
ASHARA requirements, and disseminated those products to 20 school systems enrolling a total
of 10,000 students. 10,000 would be reported in measure 15A and 2 would be reported under
15B.
  III.  PESTICIDE OCCUPATIONAL WORKER SAFETY (INCLUDING SOIL
       FUMIGATION)

Strategic Plan Targets

Sub-objective 4.1.3: Protect Human Health from Pesticide Risk. Through 2014, protect human
health by implementing our statutes and taking regulatory actions to ensure pesticides continue
to be safe and available when used in accordance with the label.

   •   Through 2014, reduce and maintain the concentration of pesticides detected in the
       general population by 50% percent. (Based on urinary metabolites reported 1999-2002
       Centers for Disease Control's National Health and Nutrition Examination Survey
       (NHANES). Measure is based on NHANES 50th percentile concentrations for all (seven)
       organophosphate analytes reported: Dimethylphosphate <  0.58 ug/L;
       Dimethylthiophosphate = 1.06 ug/L; Dimethyldithiophosphate < 0.10 ug/L;
       Diethylphosphate = 0.78 ug/L; Diethylthiophosphate = 0.5 ug/L; Diethyldithiophosphate
       < 0.10 ug/L; and 3,5,6-Trichloro-2-pyridinol = 1.9 ug/L .)

   •   By 2014, improve the health of those who work in or around pesticides by reducing the
       number of moderate to severe occupational incidents for six acutely toxic pesticides with
       the highest number of incidents by 50%. . (Based on the approximately 325 moderate and
       severe incidents reported to the Poison Control Center (PCC) National Poison Data
       System (NPDS) 1999-2003. for the six pesticides of concern; chlorpyrifos, diazinon,
       malathion, pyrethrins, 2,4D, and carbofuron.)

Program Description

EPA will collaborate with states/tribes, other federal agencies, industry groups, trade
organizations, advocacy groups, community-based organizations,  the regulated community and
other program stakeholders in efforts to reduce the occurrence of pesticide related incidents in
pesticide workers.  This includes agricultural workers, private applicators (farmers) and their
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

family members working around pesticides, commercial applicators, pest control operators, those
who work as pesticide mixers/loaders/handlers, and the full range of other workers that may
work with or around pesticides.  EPA will utilize a number of mechanisms to address issues
related to pesticide workers including proposing regulatory modifications, improvements and
enhancements to the worker protection standard and the certification and training requirements.

EPA will also coordinate with states/tribes to ensure that the regulated community is fully
informed of the requirements in the regulations and that appropriate mechanisms are in place and
utilized to ensure compliance with those requirements.  Among other things, EPA will take steps
to improve pesticide worker health and safety by: revising the worker protection standard and
pesticide applicator certification regulations (40 CFR Parts 170 and 171), providing
grants/funding to state/tribal partners to implement pesticide worker  safety programs and carry
out activities to achieve program objectives, educating and training state/tribal regulators on
federal regulatory requirements, providing compliance assistance to the regulated community;
developing and supporting outreach and/or education programs; supporting pesticide safety
training programs; establishing community-based grant programs;  developing risk-based
targeting approaches; providing outreach to health care providers that treat pesticide-related
illnesses; and, employing a variety of other innovative approaches  to promote pesticide worker
safely.

For FY 2011, it will also be a priority under the worker safety program to provide education and
outreach to states/tribes and affected agricultural and commercial pesticide handling
establishments about the new risk mitigation labeling requirements being implemented for the
soil fumigants chloropicrin, dazomet, metam sodium/ potassium, and methyl bromide. The
Agency published amended reregi strati on eligibility decisions (REDs) for the above soil
fumigants on June 3, 2009. The RED decisions call for new risk mitigation measures for the soil
fumigants to mitigate risks to fumigant handlers and post-application workers, as well  as
bystanders.  EPA expects fumigant labels with the new label requirements implementing the risk
mitigation measures will begin to appear in the field in 2010 and 2011. Ensuring state/tribal
officials and fumigant users understand the new label requirements is an important component of
the risk mitigation package. The Office of Pesticide Programs/Pesticide Re-evaluation Division
(OPP/PRD) will develop materials to aide education and outreach  efforts such as fact sheets,
standard presentations, inspector checklists, and Q&As.  These materials should be utilized by
the regional offices as routine and appropriate opportunities present themselves, such as
meetings with state or tribal co-regulators (e.g., workplan negotiations, mid or end-of-year
evaluations, pre-State FIFRA Issues Research and Evaluation Group (SFIREG) Meetings,
regional tribal meetings), site visits, grower meetings, and applicator programs.  For FY2011,
for certain high fumigant use states, it may be appropriate for outreach on the new soil
fumigation requirements to occur at the expense of other worker protection outreach activities, or
be the basis  of the worker safety region-specific project or initiative contributing to the
implementation and enhancement of WPS. In the June 2009 amended soil fumigant REDs, the
Agency identified the following states as high soil fumigant use states: California, Washington,
Idaho,  Oregon, Wisconsin, Michigan, Florida, Minnesota, North Carolina, Virginia, Arizona,
Nevada, Georgia, Colorado, and North Dakota.
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

The regional offices will be primarily responsible for working with states and tribes to
implement our regulatory field programs, developing outreach and/or education programs to the
regulated community related to worker safety, and carrying out special projects or initiatives to
enhance the worker safety field program. Headquarters will have the primary lead in national
program coordination, coordinating with health care providers and regulatory development
activities which include revising the worker protection standard and pesticide applicator
certification regulations. Headquarters will follow the Agency's rule development protocols and
involve the regional offices in the rule revision process as appropriate. Headquarters will also
coordinate with regional offices on other national program issues, and will involve the
appropriate regional office when  conducting activities in  a particular region.

EPA will strive to implement and collect improved data related to pesticide worker safety
including occupational safety.  This information will be used in program management, to meet
federal program achievement goals, and in  communications with the public.  EPA will also begin
to collect additional data from field activities such as inspections. Headquarters will utilize
national data collection systems such as SENSOR (Sentinel Event Notification System for
Occupational Risk) to collect occupational  pesticide poisoning information.  Regions should
encourage and work with our states and tribal partners to  implement and utilize these data
collection systems to inform their regulatory program decisions and field activities. The NPM
measures for this priority are intended to reflect the contributions of the EPA regional offices in
promoting and assuring the safe use of pesticides in occupational settings.

Environmental Justice

Effective implementation of EPA's Worker Protection Standard (WPS) is one of OPP's highest
priorities.  The WPS program is critical to assuring that agricultural farmworkers are protected
from occupational pesticide hazards, and it is also a key component of EPA's and OPP's
Environmental Justice (EJ) activities within the pesticide  program.  According to the most recent
findings of the National Agricultural Workers Survey (NAWS), it is estimated that there are
nearly 2 million migrant and seasonal farmworkers in the United States.  Although the NAWS
finding indicate the majority of farmworkers are Hispanic, the farmworker population is very
racially and culturally diverse, being composed of people from many different nationalities.
Farmworkers also represent some of the most economically disadvantaged people in the U.S.,
further highlighting the need for EJ focus for this population.  According to the NAWS report
from the 2001-2002 survey5, the average individual income of crop workers was between
$10,000 and $12,499. Total family income averaged between $15,000 and $17,499. Thirty
percent of all farm workers had total family incomes that  were below the poverty guidelines.

Additionally, agriculture is consistently ranked as one of  the most dangerous occupations in the
nation. Exposure to the elements, pesticides and dangerous equipment are common in farm
labor. Falls, heat stress, dehydration and pesticide poisoning are frequent injuries.  However,
 Findings from the National Agricultural Workers Survey (NAWS) 2001 - 2002: A Demographic and Employment
Profile of United States Farm Workers. U.S. Department of Labor. Office of the Assistant Secretary for Policy.
Office of Programmatic Policy. Research Report No. 9. March 2005.
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

agriculture is not subject to the same safety legislation under Occupational Safety and Health Act
that protects workers in other industries.

Farmworkers provide an important labor service to agriculture, and the abundant and affordable
U.S. food supply benefits greatly from the labor they provide.  It is important to protect this
population from occupational pesticide hazards to ensure their safety in the workplace and
viability as a community. EPA's WPS provides important regulatory protections for this
population by requiring several safeguards such as training on recognition of pesticide hazards,
protection from pesticide exposure, and emergency assistance in the event of a pesticide
exposure or injury. OPP will continue to ensure that WPS implementation is an EJ priority for
the program and a priority field activity for regional offices, states and tribes.

Proposed Principal Activities for the Regional Offices

    1)  Regions should ensure appropriate implementation of pesticide worker safety programs
       by states and/or tribes in their jurisdiction. This includes assuring states/tribes follow
       national FIFRA cooperative agreement guidance, making appropriate commitments in
       their work plans and meeting these commitments. In addition, the regional offices will
       report, according to the agreed upon format, all relevant activities.

   2)  Regions should provide education  and outreach to states/tribes and affected agricultural
       and commercial pesticide handling establishments and about the new risk mitigation
       labeling requirements being implemented for the soil fumigants chloropicrin, dazomet,
       metam sodium/ potassium, and methyl bromide.  OPP/PRD will develop materials to aide
       education and outreach efforts such as fact sheets, standard presentations, inspector
       checklists, and Q&As. These materials should be utilized by the regional offices as
       routine and appropriate opportunities present themselves,  such as meetings with state or
       tribal co-regulators (e.g., workplan negotiations, mid or end-of-year evaluations, pre-
       SFIREG Meetings, regional tribal meetings), site visits, grower meetings, and applicator
       programs.

   3)  Regions should ensure that all states and tribes submit  complete C&T accomplishment
       reporting information, as required by 40 CFR Part 171.7(d), to the Certification  and
       Worker Protection Branch in OPP  via the Certification Plan and Reporting Database
       system (CPARD). Regions must ensure that all states/tribes enter the required reporting
       information into the CPARD system by the end of the  first quarter of the federal fiscal
       year.  Therefore,  states would not be required to enter this data on the state grant
       performance measure.

   4)  Regions should ensure that all states and tribes, as applicable, maintain updated  plans for
       certification of pesticide applicators. The plans must comply with 40 CFR Part  171
       requirements. Regions must ensure that all states/tribes have entered their complete plans
       into the CPARD system; and they must ensure states/tribes maintain those plans by
       annually updating their plans in the CPARD system and entering all applicable
       information into the CPARD system about any modifications that were made to the plans
       during the annual  reporting period.
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                 KEY PROGRAM PRIORITIES AND STRATEGIES
5) Regions must carry out at least one region-specific project or initiative that contributes to
   the implementation and enhancement of the worker protection (WPS) and/or pesticide
   applicator certification (C&T) field programs.  The project or initiative must be related to
   the WPS program or the C&T program. The goal of a WPS project should be to enhance
   the protection of agricultural pesticide workers, and the goal of a C&T project should be
   to enhance the competency of certified pesticide applicators.  The project may entail
   outreach and education, compliance assistance, stakeholder coordination, program
   evaluation, state or tribal program capacity building, or other similar project/initiatives
   that may lead to enhancement of the program. The headquarters national program office
   (NPO) will provide guidance to regional offices on submitting the project write-up and
   final project report. Regions must submit the final project write-up to the NPO by
   October 31st, and the project should be completed by the end of the federal fiscal year.
   Regions must submit their final report on the outcomes of the project to the NPO within
   30 days of the end of the federal fiscal year.

6) EPA is initiating the revision of the worker protection standard and pesticide applicator
   certification regulations (40 CFR Parts 170 and 171), and will be carrying out a variety of
   efforts and activities related to the revisions of these regulations. Regions will have the
   opportunity to participate in this process. Regions should ensure they stay abreast of the
   regulatory development process and communicate with states and tribes and other
   regional program stakeholders about the status of the process, providing information to
   these entities about the process as needed when it is updated and made available.
   Regions should encourage states and tribes and other program stakeholders to stay
   engaged and  participate in the regulatory development process and provide information
   and feedback to EPA as appropriate.

7) Regions should encourage the states and tribes to adopt Certification and Training
   Assessment Group (CTAG) recommendations, including at a minimum the adoption of
   the national core manual and exam and the minimum age requirements for certification of
   applicators.  Other recommendations may also be forthcoming. After notification by
   headquarters of the recommendations, the regional offices will work with states and
   tribes to encourage their implementation. Updated information on CTAG can be found at
   http://pep.wsu.edu/ctag/.

8) Regions should encourage states and tribes to adopt the use of national worker safety
   program materials such as the national core manual and exam, national aerial category
   materials, WPS train-the-trainer materials, and other products. Regions should also work
   with states and tribes to identify barriers to adoption of national program materials,  and
   have discussions with their states and tribes about potential problems with developing a
   new ACS state grant performance measure for the program related to number of
   states/tribes adopting national program materials.  Regions should report any feedback on
   these issues to headquarters.

9) Regions should support the measures implementation process by working with their
   states and tribes in developing the information  for the measures. The measures are
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

       critical to program management and refinement as well as for addressing the needs of and
       communicating with the Office of Management and Budget, partners, stakeholders and
       the general public.  The regional activities for this NPM priority will contribute toward
       reaching the strategic targets listed under this sub-objective by promoting applicator
       competence in the safe use of pesticides and assuring compliance with EPA's WPS  and
       applicator certification rule provisions, which in turn reduces pesticide related incidents
       that may adversely impact human health and the environment. There is less likelihood of
       occupational pesticide exposures and/or pesticide-related environmental incidents
       occurring when pesticide users and workers are trained and competent.
Proposed Measures
ACS
Code
WPCT
26
Regional Measure
Number of region-specific projects or
initiatives contributing to the
implementation and enhancement of the
worker protection (WPS) and C&T field
programs.
Total number of certified applicators.
Unit of
Measure
Projects or
initiatives
Certified
applicators
Comments

State Grant
Performance Measure
Definitions and Clarification of Measures

Measures for these programs have been developed through a process with the regional offices,
states, tribes, and other stakeholders. The measures are intended to provide direction for
program improvement, and to describe progress in meeting the Agency goals and objectives.

The worker safety measure as listed above (WPCT) reflects an effort by a regional and OPP
workgroup to streamline pesticide human health measures. The new FY2011 WPCT measure
combines the FY 10 worker protection measure (WP1) and certification and training measure
(CT1), to form a single measure in FY2011 (WPCT).

The table above also includes the pesticide state grant performance measure for 2011, "total
number of certified applicators." The certification of applicators that use restricted use
pesticides, which are the most hazardous pesticides, helps ensure that these applicators will have
the level of competence needed to handle and apply these pesticides with the minimum potential
risk to human health and the environment. It is our first line of risk mitigation for the most
hazardous pesticides on the market. There are varying state/tribal requirements for who has to
get certified in each state or area of Indian country, especially  for commercial applicator
certification, so the total number of applicators requiring certification in each state or area of
Indian country can vary greatly depending on state/tribal laws  and  regulations.  The total number
of certified applicators per state  or area of Indian country is not based on or directly related to
federal certification requirements or funding. Total number of applicators requiring certification
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

in each state or area of Indian country can vary depending on, state/tribal laws and regulations,
population, level of agricultural production, pest pressures, certification costs, and other factors.

The total number of applicators certified by a state/tribe is not within their control and is not a
function of their efficiency or productivity. States/tribes have different populations, levels of
agricultural production, pest issues, costs to obtain certification, and regulatory requirements for
certification.  This may affect the number of people who pursue certification and the total
number of applicators certified by a state/tribe.

The regional offices will not be expected to enter this data into the ACS system.  This data will
be obtained from the states/tribes as part of the certification program's requirements established
in 40 CFR 171(d).  OPP will use the information submitted by  states/tribes to calculate this
measure and the regions will then enter the results into the ACS system.  There are a few
important caveats to the pesticide state grant performance measure that are noted following the
table above.
  IV.  ANTIMICROBIAL HOSPITAL DISINFECTANTS EFFICACY AND
       MISBRANDING

Strategic Plan Targets

Sub-objective 4.1.3: Protect Human Health from Pesticide Risk. Through 2014, protect human
health by implementing our statutes and taking regulatory actions to ensure pesticides continue
to be safe and available when used in accordance with the label.

Program Description

Antimicrobials are used in homes, hospitals, cafeterias, restaurants, and many other institutions.
While all pesticide products are required to work as claimed by the manufacturer, EPA is
particularly concerned about the effectiveness of antimicrobial pesticides because their
effectiveness is usually not obvious and studies by General Accounting Office (GAO) suggest
that at least twenty percent of pesticides are ineffective.

Over the past several years, EPA implemented a comprehensive strategy to ensure the efficacy of
antimicrobial pesticides, placing highest priority on those that have significant public health uses.
Under the Agency's Antimicrobial Testing Program (ATP) a large part of EPA's efforts involve
testing hospital disinfectants and tuberculocides. Under the ATP, product samples collected by
states and regions were evaluated for selected product performance claims to ensure that they
perform as intended.  Current results suggest that approximately thirty percent of the hospital
disinfectant products and about fifty percent of the tubeculocidal products do not meet Agency
standards significant number of products fail efficacy testing.  The initial phase for sample
collection is completed but efficacy testing will continue for products received through FY 2010.

Product samples collected by states and regions,  voluntarily submitted by registrants as well as
product samples purchased by the Agency have been evaluated for selected product performance
                                           21

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                     KEY PROGRAM PRIORITIES AND STRATEGIES

claims to ensure that they perform as intended. Approximately two-thirds of the tested hospital
disinfectant products and half of the tuberculocidal products have met EPA's post-registration
efficacy standards. The Agency has set the end of 2011 as the goal for completing the post-
registration evaluation of efficacy of the remaining hospital disinfectants and tuberculocides
under the ATP. In addition, EPA is developing an ATP Strategy that includes continued
oversight of primary and distributor products.

Regions should provide outreach on the ATP and hospital disinfectants to users, distributors and
others based on materials provided by OPP (e.g., the ATP website at,
http://www.epa.gov/oppad001/antimicrobial-testing-program.html). These outreach
opportunities should occur where there are appropriate and existing opportunities. Regions
should report back to the Office of Pesticide  Program Antimicrobial Division any questions that
are not answered by the available materials.  This will help OPP identify whether additional
communication materials need to be developed.

Proposed Principal Activities for the Regional Offices

   1)  As the ATP progresses, regions can expect an increase of questions relating to the
       Program and the efficacy of hospital  disinfectants and tuberculocides. Regions should
       provide outreach on the ATP and hospital disinfectants to users, distributors and others
       based on materials provided by OPP  (e.g., the ATP website at,
       http://www.epa.gov/oppad001/antimicrobial-testing-program.html).  These outreach
       opportunities should occur where there are appropriate and existing opportunities.

   2)  Regions should report back to the Office of Pesticide Program Antimicrobial Division
       any questions that are not answered by the available materials. This will help OPP
       identify whether additional communication materials need to be developed.

Proposed Measure

No measures will be associated with this priority.
   V.  PESTICIDE CONTAINER-CONTAINMENT REGULATION
       IMPLEMENTATION

Strategic Plan Targets

Sub-objective 4.1.3: Protect Human Health from Pesticide Risk. Through 2014, protect human
health by implementing our statutes and taking regulatory actions to ensure pesticides continue
to be safe and available when used in accordance with the label.

   •   Through 2014, reduce and maintain the concentration of pesticides detected in the
       general population by 50% percent. (Based on urinary metabolites reported 1999-2002
       Centers for Disease Control's National Health and Nutrition Examination Survey
       (NHANES). Measure is based on NHANES 50th percentile concentrations for all (seven)
                                           22

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                     KEY PROGRAM PRIORITIES AND STRATEGIES

       organophosphate analytes reported: Dimethylphosphate < 0.58 ug/L;
       Dimethylthiophosphate = 1.06 ug/L; Dimethyldithiophosphate < 0.10 ug/L;
       Diethylphosphate = 0.78  ug/L; Diethylthiophosphate = 0.5 ug/L; Diethyldithiophosphate
       < 0.10 ug/L; and 3,5,6-Trichloro-2-pyridinol = 1.9 ug/L .)

   •   By 2014, improve the health of those who work in or around pesticides by reducing the
       number of moderate to severe occupational incidents for six acutely toxic pesticides with
       the highest number of incidents by 50%. . (Based on the approximately 325 moderate and
       severe incidents reported to the Poison Control Center (PCC) National Poison Data
       System (NPDS) 1999-2003. for the six pesticides of concern; chlorpyrifos, diazinon,
       malathion, pyrethrins, 2,4D, and carbofuron.)

This NPM priority will also support the Agency Strategic Plan:

   •   Sub-objective 4.1.4: Protect the Environment from Pesticide Risk. Through 2014, protect
       the environment by implementing our statues and taking regulatory actions to ensure
       pesticides continue to be  safe and available when used in accordance with the label.

          o   By 2014, no urban watersheds will exceed the National Pesticide Program aquatic
              life benchmarks for four key pesticides of concern. Baseline; (1992 - 2001)
              percent of urban watersheds sampled by USGS National Water Quality
              Assessment (NAWQA) program that exceed the National Pesticide Program
              aquatic life benchmarks for diazinon (73%),  chlorpyrifos (37%), carbaryl (13%),
              and malathion (30%.)

          o   By 2014, no agricultural watersheds will  exceed the National pesticide Program
              aquatic life benchmarks for two key pesticides of concern. Baseline data (1992 -
              2001) percent of agricultural watersheds sampled by USGS National Water
              Quality Assessment (NAWQA) program that exceed the National Pesticide
              Program aquatic life benchmarks for azinphos-methyl(18%) and chlorpyrifos
              (21%.)

Program Description

The goal of the pesticide Container-Containment rule implementation NPM priority and the
proposed principal Regional activities listed below, is to reduce incidents associated with
occupational exposure or environmental  exposure that are caused by the failure, inadequate
storage or improper handling of pesticide containers. There is less likelihood of occupational
exposure to pesticides (and thus illness or other adverse  effects) and environmental exposure to
pesticides (and thus contamination or other adverse effects) if pesticide containers are properly
designed, bulk pesticides are stored and transferred in containment structures, and containers are
properly handled.

EPA will help  prepare states and the regulated community to come into compliance with the new
regulations.  Compliance is required with the non-refillable container and pesticide containment
regulations by  August 2009, with the label requirements by August 2010 and with the refillable
                                          23

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                     KEY PROGRAM PRIORITIES AND STRATEGIES

container and repackaging regulations by August 2011.  The Regions will work with states so
that they can carry out an adequate residue removal program as required by FIFRA.

The NPM measures for this priority are intended to reflect the contributions of the EPA Regional
Offices in reducing incidents associated with occupational exposure or environmental exposure
that are caused by the failure, inadequate storage or improper handling of pesticide containers.

The requirements of this rule are designed to minimize human exposure while handling pesticide
containers; facilitate safe container disposal and recycling; and protect the environment from
pesticide releases at bulk storage sites and from spills and leaks at refilling and dispensing
operations. The Office of Pesticide Programs (OPP) has made implementation of this rule a
priority. Therefore, this guidance will emphasize Headquarters and Regional activities to help
prepare state partners for implementation, which is a necessary step in ensuring the requirements
of the rule are followed by pesticide registrants, distributors and users, and the human health and
environmental protections are realized in the field. Additional information on the rule can be
found at http://epa.gov/pesticides/regulating/containers.htm.

Proposed Principal Activities for the Regional Offices

   1)  Regions should facilitate implementation of the Container-Containment rule. This
       includes assuring that states follow National Cooperative Agreement Guidance, making
       appropriate commitments in their work plans, and meeting these commitments. Regions
       should report all relevant activities.

   2)  Regions should coordinate with States and Tribes to implement the pesticide Container-
       Containment regulations.  Compliance is required with the non-refillable container
       standards and containment requirements as of August 16, 2009, with the label
       requirements by August 16,  2010 and with the refillable container and repackaging
       regulations by August 16,  2011.  Regions should assess whether the States/Tribes have an
       implementation program that addresses the Container-Containment rule requirements for
       the different components of the regulations: containment, non-refillable containers,
       labels, and refillable containers/repackaging. Based on this information, Regions should
       identify whether the lead for each of these components is the Region or the State/Tribe.
       This will be an on-going process during the years that the pesticide container-
       containment regulations are being phased in. It is likely that Regions would assess the
       State's or Tribe's implementation program for specific components of the Container-
       Containment rule at  different times.  For example, a region might assess a State's
       capacity to implement the containment regulations in FY2009 or FY 2010 and then
       assess that State's capacity to implement the refillable container and repackaging
       requirements in FY 2011 or FY 2012.

   3)  Regions must carry out at least one Region-specific project or initiative that contributes
       to the implementation and enhancement of the pesticide container-containment field
       program. The goal of the project should be to enhance the use of well-designed pesticide
       containers, the adequate containment for bulk pesticide storage and repackaging
       activities, and/or the proper handling of pesticide containers. The projects may involve
                                           24

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                     KEY PROGRAM PRIORITIES AND STRATEGIES
       outreach and education, compliance assistance, stakeholder coordination, program
       evaluation, state or tribal program capacity building, or other similar projects and
       initiatives that lead to the implementation and initiation of the pesticide container-
       containment field program.  The project or initiative may be one segment of a multi-year
       program.  Headquarters will provide guidance to Regions on submitting project write-ups
       and final project reports. Projects (or one phase of a multi-year project) must be
       completed by the end of the fiscal year.  Regions must submit their final project reports to
       Headquarters within 30 days of the end of the federal fiscal year.
Proposed Measures
ACS
Code
CR1
CR2
Regional Measure
Number of Region-specific projects or
initiatives contributing to the
implementation and enhancement of the
Container-Containment field program.
Number of States that the Region has
assessed to determine if they have capacity
to implement the pesticides
container/containment rules.
Unit of
Measure
Projects or
initiatives
States
Comments

Non-Commitment
Measure
Definitions and Clarification of Measures

ACS measure CR1 language was revised starting in FY 2010 to reflect Regional Pesticide
Supervisors' recommendation to modify the measure language to read similar to the existing
Worker Safety measures, which require tracking a project or initiative rather than just a counting
of the number of meetings and outreach activities.  OPP management agrees with this
recommendation since these projects will contribute to implementation and enhancement of the
container-containment field program which is the goal of this measure.

ACS measure CR2 reflects the on-going coordination that Regions will have with states and the
Region's assessment (not a formal determination) about whether the states have the capacity to
implement the  Container-Containment regulations. This will be an on-going process during the
years that the pesticide container-containment regulations are being phased in. The compliance
dates run from August 2009 to August 2011.
  VI.  PROTECTION OF WATER SOURCES FROM PESTICIDE EXPOSURE

Strategic Plan Targets

Sub-objective 4.1.4: Protect the Environment from Pesticide Risk.  Through 2014, protect the
environment by implementing our statues and taking regulatory actions to ensure pesticides
continue to be safe and available when used in accordance with the label.
                                          25

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                     KEY PROGRAM PRIORITIES AND STRATEGIES
   •  By 2014, no urban watersheds will exceed the National Pesticide Program aquatic life
      benchmarks for four key pesticides of concern. Baseline; (1992 - 2001) percent of urban
      watersheds sampled by USGS National Water Quality Assessment (NAWQA) program
      that exceed the National Pesticide Program aquatic life benchmarks for diazinon (73%),
      chlorpyrifos (37%), carbaryl (13%), and malathion (30%.)

   •  By 2014, no agricultural watersheds will exceed the National pesticide Program aquatic
      life benchmarks for two key pesticides of concern. Baseline data (1992 - 2001) percent of
      agricultural watersheds sampled by USGS National Water Quality Assessment (NAWQA)
      program that exceed the National Pesticide Program aquatic life benchmarks for azinphos-
      methyl(18%) and chlorpyrifos (21%.)

Program Description

In order to ensure that pesticides do not adversely affect the nation's water resources and the
EPA Strategic Plan sub-objective and measures listed above are met, EPA, States, and Tribes
will undertake a program to:  1) evaluate pesticide risks to local water resources, 2) take actions
where pesticide risks are identified to reduce or prevent pesticide contamination of water
resources over time, and 3) establish mechanisms to demonstrate the progress of management
strategies designed to address water quality concerns caused by pesticide use. EPA, States, and
Tribes will also investigate and respond to pesticide water contamination incidents, especially
where water quality standards or other reference points are threatened or exceeded. The Office
of Pesticide Programs (OPP), the Office of Water, Regions,  States and Tribes will also share
information and collaborate to identify and manage the risk  of pesticide use to water resources.
OPP will also use State and Tribal water monitoring data in  the pesticide registration and
registration review process. Through the Regional Office grant oversight and grantee support of
activities in this program area, the EPA Regional Offices can help ensure that water quality
concerns due to pesticide use are identified and mitigated over time.

For FY 2011, the pesticide regional offices may also need to undertake some activities to support
development and implementation of Pesticide National Pollutant Discharge Elimination System
(NPDES) permits issued under the Clean Water Act. Under the current schedule, people who
apply pesticide products to: a) control of mosquitoes and other aquatic insect species, b) control
of aquatic weeds or algae, c) wide-area pest control and control of vegetation along ditchbanks,
and d) control  of aquatic animal pests, will be required to operate under an NPDES permit after
April 2011.  Within each region, the Water Program staff will have the lead on this issue.
However, regional water program staff may also benefit from guidance, coordination or direct
assistance from the Pesticide Program regional staff. Regional pesticide programs should offer
support in the following areas:

       1. Where routine opportunities present themselves,  provide outreach to potential
          permittees in states, territories, tribal areas, and federal facilities that will be covered
          under the  federal Pesticide General Permit (PGP).
      2. Provide technical  input to assist regional Water Program staff in the review of draft
          and final state-generated PGPs for states with delegated NPDES authority (e.g.,
                                           26

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                     KEY PROGRAM PRIORITIES AND STRATEGIES

          providing information on issues related to pesticide use, impacts and/or best
          management practices).
       3.  Where routine opportunities present themselves, provide outreach to potential
          permittees in states with delegated NPDES authority

To assist in outreach efforts, regional Pesticide Program staff will be provided outreach materials
from the EPA Office of Water and/or regional Water Programs. In addition, to ensure effective
education  of the regulated community, steps should be taken to coordinate outreach opportunities
with regional Water Program staff, regional Pesticide Program staff, state lead water agency
staff, and state lead pesticide agency staff.

Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA registers pesticides
and sets conditions for their use.  These conditions can include requirements to protect water
resources. EPA also provides funding to States and Tribes to protect water resources from
pesticides.  Under the cooperative agreements managed by the EPA Regional Offices, States and
Tribes are asked to evaluate pesticides that have potential to threaten water quality standards or
other appropriate reference points, and to place those pesticides identified as a concern under
active management so as to reduce concentrations in the environment that would otherwise result
in undue exposure and risk. This evaluation process allows States and Tribes to identify where
they need to focus resources at the local level to manage the greatest risk to their water quality.
Additional information can be found at http://www.epa.gov/pesticides/health/safely.htm.

Proposed Principal Activities for the Regional Offices

Regions will negotiate annual State and Tribal water  quality commitments consistent with
FIFRA Cooperative Agreement Guidance, and will provide annual grant and program oversight.

    1)  Regional Pesticide Offices will consult with Regional Water Offices, OPP, and State and
       Tribal pesticide and other water resource agencies, as needed, to ensure that appropriate
       water quality pesticides of interest are identified and evaluated by the State or Tribe.

   2)  Regions will assist State and Tribal pesticide and water quality management agencies to
       develop programs to manage pesticides of concern that are derived from pesticides of
       interest evaluations; i.e., those that have a high potential to threaten water quality
       standards.

   3-)  Regions will work with State and Tribal pesticide agencies to assess current State and
       Tribal program progress on meeting work plan water quality commitments.  Regions will
       support States and Tribes on reporting the national water quality measures data, including
       training, and any water quality monitoring data to OPP. Measures information should be
       entered by States and Tribes into the Pesticides of Interest Tracking System (POINTS,
       www.points.wsu.edu) by December 31st, of the reporting year.  Regions will then review
       their State and Tribal POINTS data to ensure its accuracy. POINTS data should be final
       by February 28, 2011.
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

   4)  Regions should support the EPA pesticide registration review process through the
       collection and submission to OPP of State water quality monitoring data, including data
       on CWA §303(d) listed waters due to pesticide impairments, as described in the
       Cooperative Agreement Guidance.

   5)  Regions should support the Regional Water Programs in the development and
       implementation of Pesticide National Pollutant Discharge Elimination System (NPDES)
       permits issued under the Clean Water Act in the following areas:

       •  Where routine opportunities present themselves, provide outreach to potential
          permittees in states, territories, tribal areas,  and federal facilities that will be covered
          under the federal Pesticide General Permit (PGP)

       •  Provide technical input to assist regional water staff in the review of draft and final
          state-generated PGPs for states with delegated NPDES authority (e.g., providing
          information on issues related to pesticide use, impacts and/or best management
          practices).

       •  Where routine opportunities present themselves, provide outreach to potential
          permittees in states with delegated NPDES  authority

       •  To ensure effective education of the regulated community, steps  should be taken to
          coordinate outreach opportunities with regional Water Program staff, regional
          Pesticide Program staff, state lead water agency staff, and state lead pesticide agency
          staff.
Proposed Measures
ACS
Code


WQ1


Regional Measure
Number of evaluated pesticides of concern
that have been placed under State or Tribal
Program management due to their
propensity to approach or exceed national
water quality standards or other human
health or ecological reference points.
Unit of
Measure


Pesticides


Comments


Non-Commitment
Measure


Definitions and Clarification of Measures

The reporting measure described above is intended to reflect the efforts of the EPA Regional
Offices in managing cooperative agreements to ensure that States and Tribes are taking steps to
evaluate potentially problematic pesticides for water quality.
 VII.  POLLUTION PREVENTION
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                     KEY PROGRAM PRIORITIES AND STRATEGIES

Strategic Plan Targets

Sub-Objective 5.2.1: Prevent Pollution and Promote Environmental Stewardship. By 2014,
reduce pollution, conserve natural resources, and improve other environmental stewardship
practices while reducing costs through implementation of EPA's pollution prevention programs.

   •   By 2014, reduce 20 billion pounds of hazardous materials cumulatively compared to the
       2006 baseline of 0.46  billion pounds.

   •   By 2014, reduce, conserve, or offset 115 million metric tons of carbon dioxide equivalent
       (MTCO2e) compared to the 2006 baseline of 1.2 million MTCO2e reduced, conserved,
       or offset.

   •   By 2014, reduce water use by 190 billion gallons compared to the 2006 baseline of 2.3
       billion gallons reduced.

   •   By 2014, save $14 billion through pollution prevention improvements in business,
       institutional, and governmental costs cumulatively compared to the 2006 baseline of $2.1
       billion dollars saved.

Program Description

The Pollution Prevention (P2) program is one of EPA's primary tools for promoting sustainability and
encouraging environmental stewardship by business, governments, Federal and state, industry,
communities, and individuals. The P2 Program has been producing energy efficiency and fossil fuel
reduction results, along with co-benefits in chemical risk management and business cost savings,  since
the early 1990s. By helping businesses and entities with pollution prevention strategies, benefits
include reductions in greenhouse gas emissions, conservation of resources, more competitive
companies, green designed processes, products and technologies from a life cycle perspective. These
pollution prevention approaches offer sustainable solutions to the diverse set  of challenges posed  by the
Administrator's seven priorities.  The P2 program is augmented by a counterpart P2 grant program in
the State and Tribal Assistance Grants (STAG) account. For more information, please visit
http://www.epa.gov/p2/.

Nationally, pollution prevention programs are the product of collaborations between EPA,
universities, non-profits, and  State and Tribal governments.  The decentralized model serves to
leverage additional resources (50% grant matching requirement), meet the unique needs of
regional governments and deliver quality technical assistance to businesses seeking information
about source reduction opportunities.

Proposed Principal Activities for the Regional Offices

   1)  Administer the P2 State and Tribal grants program to fund state P2 technical assistance
       programs and regional P2Rx Centers, which assist businesses in ways that contribute
       significantly to the Agency achieving its P2 strategic targets. Identify  and work with the
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                     KEY PROGRAM PRIORITIES AND STRATEGIES
       States and Tribes and EPA Headquarters to replicate successful pilots for maximum
       national impact.

   2)  Promote multi-media coordination with (air, water, waste, and toxics programs) within
       each region to promote P2/sustainability outcomes.

   3)  As regional resources allow, provide direct P2 assistance to businesses, assistance to
       Environmentally Preferable Purchasing, the Federal Electronics Challenge, Green
       Suppliers Network, and Design for Environment, etc.

   4)  Continue to engage in the comparative analysis and development of a tool to improve the
       collection, tracking and reporting of P2 Grant Results.

Proposed Measures
ACS
Code
261
262
263
264
297
Regional Measure
BTUs of energy reduced, conserved or
offset by P2 program participants. (Billions
of BTUs)
Gallons of water reduced by P2 program
participants.
Business, institutional and government costs
reduced by P2 program participants.
Pounds of hazardous material reduced by P2
program participants.
Annual metric tons of carbon dioxide
equivalent (MTCO2e) reduced, conserved or
offset by P2 program participants.
Unit of
Measure
BTU
Gallons
Dollars
Pounds
MTCO2e
Comments
Non-Commitment
Measure




Definitions and Clarification of Measures

Starting in 2010, the P2 Program will transition to using measures that are calculated using new
annual results (as at present) plus recurring results (capturing continuing results in out-years for
the lifespan of the P2 improvement).  This will avoid under-counting the impacts of P2 Program
interventions, and is consistent with feedback received from the Science Advisory Board in
September 2008. The P2 Program at Headquarters will discuss with the Regional Offices how
long recurring results will be counted for regional interventions. Computing recurring results for
regional interventions will be a Headquarters responsibility.

For all Pollution Prevention measures, "reduced" is defined to mean reduction through P2
improvements and includes pollution avoided. An example of "avoiding" pollution would be
substituting a less hazardous chemical instead of a more hazardous chemical.
                                          30

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                     KEY PROGRAM PRIORITIES AND STRATEGIES

The pollution "reduced" and "avoided" must be related to source reduction, and not out-of-
process recycling. For purposes of greenhouse gas reductions only, however, the program is
considering whether to count greenhouse gas reductions from out-of-process recycling that
occurs as a co-benefit of a P2 Program intervention.  Headquarters will consult with the Regional
Offices on this matter and will update the P2 Program Measurement Guidance to reflect
decision-making on this issue. Out-of-process recycling occurs when a waste (such as paper)
exits a process, undergoes significant handling and is transported offsite to a commercial
recycling facility or waste exchange (such as a re-pulping process for paper.  The P2 Program
considers the reuse of materials as source reduction,  not out-of-process recycling.

Definition of "P2 program participants" is any party  who produces P2 results with a link to a P2
Program intervention. Examples include but are not limited to:  State and local  agencies,
businesses, manufacturers, nonprofit organizations, and other institutions.

Reduced, conserved and offset collectively cover activities that  result in less combustion of fossil
fuels. This can occur by using fossil fuel energy more efficiently, simply using less fossil fuel
energy, or switching to an energy source with a lower fossil fuel impact. For further details and
examples, consult the P2 Measurement Guidance.

ACS measure 261 is a non-commitment measure for the number of British Thermal Units
(BTUs) reduced, conserved, or offset. BTUs are a unit of energy and will be expressed in
billions. For example, 6,150,000,000 BTUs, should  be expressed as 6.15 Billion BTUs.
Standard conversion factors between megawatt-hours and BTUs are found on web-based
conversion charts.

ACS measure 262 is a commitment measure that counts the gallons of water reduced as a result
of water conservation. What is counted is the reduced use of water in the first place. This can be
accomplished through conservation and re-use of water. If water pollution is reduced, the
gallons of water associated with the pollutant effluent are not counted under this measure.  For
example, if a facility used a million gallons of water in the previous year and uses only 500,000
gallons of water in the reporting year, they can count 500,000 gallons of water conserved under
ACS measure 262.

ACS measure 263 is a commitment measure that counts the amount of money saved as a result
of the incorporation of pollution prevention practices into the daily operations of government
agencies, businesses, and institutions. Institution is defined as an established organization,
especially of a public character (e.g., hospitals, universities, group purchasing organization, etc).
The P2 Program, in consultation with the Pollution Prevention Resource Center (PPRC), has
updated the financial cost calculator which provides  specific cost savings for specific types, of
pollutants as well as water and energy conservation.  Further details and examples can be found
in the P2 Measurement Guidance.

ACS measure 264 is a commitment measure that counts the reduction of hazardous material
released to air, water, land, or incorporated into products, or used in an industrial process.
Hazardous is used in  a broad sense to include federally or state regulated pollutants, including
Clean Air Act criteria pollutants and Clean Water Act water quality criteria pollutants and
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                    KEY PROGRAM PRIORITIES AND STRATEGIES

conventional pollutants, but excludes items generally considered of low hazard and frequency
recyclable or divertible, such as paper products, cans, iron and steel scrap, and construction
waste.

ACS measure 297 is a commitment measure that counts the metric tons of carbon dioxide
equivalent (MTCO2e) reduced, conserved or offset. The P2 Program has developed a
Greenhouse Gas Reductions Calculator that is being made available for Regional Office use to
compute the conversion of electricity, fuels, BTUs, and chemicals to MTCO2e for reporting
purposes.
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                       OTHER PROGRAM ACTIVITIES
PESTICIDE TRIBAL

Program Description

In order to expand OPP's ability to protect human health and the environment in Indian Country
and Alaska Native Villages and maximize our tribal resources, the National Tribal Pesticide
Program is now emphasizing, where appropriate, policies and approaches that can benefit
multiple rather than single tribes (e.g., circuit riders and multi-tribal training). OPP is also
developing tribal Pesticide Use Assessments to help identify the areas in Indian Country with the
greatest need for tribal pesticide program and/or enforcement grants and cooperative agreements.

Proposed Principal Activities for the Regional Offices

To measure our progress in expanding our ability to protect human health and the environment in
Indian Country since adoption of the new multi-tribal approach, the Tribal Pesticide Program
will now track the national net increase in pesticide-program coverage based on the number of
tribes, number of people, and number of acres that are covered under tribal pesticide program
and/or enforcement grants and cooperative agreements for continuing environmental programs
established since FY 2005 in Indian Country (the year before the Program began emphasizing
the multi-tribal approach).

Proposed Measures
 ACS
 Code
            Regional Measure
 Unit of
Measure
   Comments
 TR-2
   Number of tribes covered under tribal
pesticide program and/or enforcement grants
 and cooperative agreements for continuing
  environmental programs established since
	FY 2005 in Indian Country.	
 Tribes
Non-Commitment
    Measure
 TR-3
   Number of people covered under tribal
pesticide program and/or enforcement grants
 and cooperative agreements for continuing
  environmental programs established since
	FY 2005 in Indian Country	
 People
Non-Commitment
    Measure
 TR-4
    Number of acres covered under tribal
pesticide program and/or enforcement grants
 and cooperative agreements for continuing
  environmental programs established since
	FY 2005 in Indian Country	
 Acres
Non-Commitment
    Measure
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                             OTHER PROGRAM ACTIVITIES
Definitions and Clarification of Measures

OPP and the Regions will use the American Indian Environmental Office (AIEO) data to
determine the number of people and acres within the tribal areas covered by grants.  The
information will be reported annually by the Regions.  That information will be rolled up
nationally by OPP to determine the percentage increase for the measure since FY 2005 (number
of tribes, people and acres covered by continuing pesticide program and/or enforcement grants
established in Indian Country since 2005,  divided by number of tribes, people and acres covered
under continuing pesticide program and/or enforcement grants in Indian Country in FY 2005,
multiplied by 100).  We expect that increased pesticide program presence in Indian Country will
result in improvements to human health and the environment in Indian Country. Because new
grants to fund circuit-riders will go to tribes with the greatest need as determined from compared
Pesticide Use Assessments, Regions will not be able to know in advance if tribes within their
region will be able to receive funding for new multi-tribal programs.  Therefore, the new tribal
measures will be strictly a reporting measure and Regions will not be required to make a
commitment to attain a certain level.
COMMUNITY ACTION FOR A RENEWED ENVIRONMENT (CARE)

Program Description

Through the CARE program, EPA provides funding tools and technical  support that enable
underserved communities to create collaborative partnerships to take effective actions to address
local environmental problems. The National Academy of Public Administration (NAPA) issued
a positive evaluation of the CARE program in May 2009 observing "...the CARE  program
complements EPA regulatory strategies with place-based strategies—strategies that consider the
local context in which environmental decisions are made and effects are felt. The Panel believes
that the CARE approach represents a "next step" in environmental improvement and protection."
Since 2005, the CARE program has awarded 64 community  partnerships across 32 states with
over 860 partners engaged a total of $10.4 million in grants.  CARE delivers funding through
cooperative agreements. In the smaller Level I agreements, the community, working with EPA,
creates a collaborative problem-solving group of community  stakeholders. That group assesses
the community's toxic exposure, environmental problems and priorities, and begins to identify
potential solutions. In the larger Level II agreements, the community, working with EPA, selects
and funds projects that reduce risk and improve the environment in the community.

Proposed Principal Activities for the Regional Offices

   1)  Provide multi-media regional support needed to ensure the success of the region's CARE
       cooperative agreements.

   2)  Identify experienced project officers/leaders for each of the CARE projects and provide
       training and support as needed.
                                          34

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                             OTHER PROGRAM ACTIVITIES
   3)  Strengthen cross program regional team organized to support CARE project leaders and
       CARE community needs with dedicated technical and programmatic support.

   4)  During CARE Level I projects, project officers help provide the technical support needed
       for communities to identify and rank their risks and build long-term, viable partnerships..

   5)  During CARE Level II projects, project officers help communities' access EPA programs
       and expertise to create and implement local solutions and measure and track their results.

   6)  Encourage staff participation in training new project leaders and at sessions during the
       national CARE workshop.

   7)  Ensure required reporting of progress and results through the Quarterly and End of Year
       Reports and assist in other efforts to aggregate program results on a national level.

   8)  Support work to capture best practices and lessons learned to help other communities
       replicate these approaches.

   9)  Support CARE national teams that have been organized to manage the CARE program
       and provide support to Regional Office teams and projects.

Proposed Measures
ACS
Code
CARE1
Regional Measure
Number of Community Action for Renewed
Environment (CARE) cooperative
agreement projects managed in order to
obtain toxic reductions at the local level.
Unit of
Measure
Cooperative
agreement
Comments

Definitions and Clarification of Measures

ACS measure CAREl seeks to track the number of CARE projects managed by the Region. The
CARE measure was developed as an inherently duplicative measure and other NPMs will have
similar CARE measures.  The Regional offices will use the ACS comment field to report the
CARE cooperative agreement projects and will report the same information if another NPM has
a similar CARE measure.
                                          35

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US ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
Attachment A: OCSPP FY 2011 NPM Guidance Measures
G/O/S
4.1.1
4.1.1
4.1.1
4.1.1
4.1.1
Measures
Central
Code
13A
13B
14
ISA
15B
Measure Text
Annual percentage of viable lead-based
paint abatement certification applications
that require less than 20 days of EPA
Regional effort to process (For Direct
Implementation - Regional Office
efforts).
Annual percentage of viable lead-based
paint abatement certification applications
that require less than state-established
timeframes to process (For authorized
States).
Number of abatement activities
performed by certified abatement workers
occurring in the Regions.
Number of children reached through
outreach activities (e.g., public meetings,
conferences, exhibits, community
outreach, training, award programs, mass
mailings, phone calls, etc.) conducted to
address asbestos.
Number of outreach products produced
[e.g., web products, written publications
(fact sheets, booklets, reports), exhibits,
training packages, mass mailings
(electronic or U.S. Postal mail)]
addressing asbestos.
Non-
Commitment
Indicator
(Y/N)
N
N
Y
N
N
State Grant
Performance
Measure (Y/N)
N
Y
N
N
N
Planning Target





National Target (FY2011 Pres. Bud)





Attachment A: OCSPP FY 2011 NPM Guidance Measures
Page 1

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US ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
Attachment A: OCSPP FY 2011 NPM Guidance Measures
G/O/S
4.1.1
4.1.1
4.1.2
4.1.3
4.1.3
Measures
Central
Code
RRP2
TR-1
CARE1
26
CR1
Measure Text
Number of active accreditations for lead-
based paint renovation, repair and
painting certification training providers in
the Region.
Number of tribal partnerships or projects
addressing lead based paint hazards and
exposure reduction.
Number of Community Action for
Renewed Environment (CARE)
cooperative agreement projects managed
in order to obtain toxic reductions at the
local level.
Total number of certified applicators.
Number of Region-specific projects or
initiatives that contribute to the
implementation and enhancement of the
container-containment field program
Non-
Commitment
Indicator
(Y/N)
Y
Y
N
N
N
State Grant
Performance
Measure (Y/N)
N
N
N
Y
N.
Planning Target





National Target (FY2011 Pres. Bud)





  Caveat to measure 26: There are varying state requirements for who has to get certified in each state, especially for commercial applicator certification, so the
total number of applicators requiring certification in each state can vary greatly depending on state laws and regulations. The total number of certified
applicators per state is not based on or directly related to federal certification requirements or funding.

The total number of applicators certified by a state is not within their control and is not a function of their efficiency or productivity. States have different
populations, levels of agricultural production, pest issues, costs to obtain certification, and regulatory requirements for certification.  This may affect the number
of people who pursue certification and the total number of applicators  certified by a state.
Attachment A: OCSPP FY 2011 NPM Guidance Measures
Page 2

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US ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
Attachment A: OCSPP FY 2011 NPM Guidance Measures
G/O/S

4.1.3

4.1.3

4.1.3


4.1.3

Measures
Central
Code

CR2

TR-2

TR-3


TR-4

Measure Text
Number of States and Tribes that the
Region has assessed to determine if they
have the capacity to implement the
pesticides Container-Containment rules.
Number of tribes covered under tribal
pesticide program and/or enforcement
grants and cooperative agreements for
continuing environmental programs
established since FY 2005 in Indian
Country.
Number of people covered under tribal
pesticide program and/or enforcement
grants and cooperative agreements for
continuing environmental programs
established since FY 2005 in Indian
Country
Number of acres covered under tribal
pesticide program and/or enforcement
grants and cooperative agreements for
continuing environmental programs
established since FY 2005 in Indian
Country
Non-
Commitment
Indicator
(Y/N)

Y

Y

Y


Y

State Grant
Performance
Measure (Y/N)

N

N

N


N

Planning Target










National Target (FY2011 Pres. Bud)










Attachment A: OCSPP FY 2011 NPM Guidance Measures
Page 3

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US ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
Attachment A: OCSPP FY 2011 NPM Guidance Measures
G/O/S
4.1.3
4.1.4
5.2.1
5.2.1
5.2.1
5.2.1
5.2.1
Measures
Central
Code
WP1/
CT1
WQ1
263
261
262
264
297
Measure Text
Number of Region-specific projects or
initiatives contributing to the
implementation and enhancement of the
worker protection (WPS) and C&T field
programs.
Number of evaluated pesticides of
concern that have been placed under State
or Tribal Program management due to
their propensity to approach or exceed
national water quality standards or other
human health or ecological reference
points.
Business, institutional and government
costs reduced by P2 program participants.
BTUs of energy reduced, conserved or
offset by P2 program participants.
Gallons of water reduced by P2 program
participants.
Pounds of hazardous material reduced by
P2 program participants.
Metric tons of carbon dioxide equivalent
(MTCO2e) reduced, conserved or offset
by P2 program participants.
Non-
Commitment
Indicator
(Y/N)
N
Y
N
Y
N
N
N
State Grant
Performance
Measure (Y/N)
N
N.
N
N
N
N
N
Planning Target







National Target (FY2011 Pres. Bud)







Attachment A: OCSPP FY 2011 NPM Guidance Measures
Page 4

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                                   US ENVIRONMENTAL PROTECTION AGENCY
                          OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
                 Attachment B: OCSPP Explanation of Changes between FY 2010 and FY 2011
     Change from FY 2010 Guidance Document
                                                  Reason for Change
                                       Affected Pages and Sections
Priorities
                 Addition - Antimicrobial Hospital
                       Disinfectant Efficacy
                                         The addition of the Antimicrobial Hospital
                                           Disinfectant Efficacy priority for the
                                          regions is consistent with the increased
                                          focus and priority this program area will
                                                 receive in OPP in FY 11.
                                           Section IV, Page 20
             Modification - Chemical Risk Management
               program and the Chemical Risk Review
                       program streamlined
                                         The Chemical Risk Management program
                                            and the Chemical Risk Review and
                                         Reduction Programs were combined in one
                                            section to provide a holistic view. In
                                         addition, the Chemical Risk Management
                                           program is expanded from asbestos to
                                        include other chemicals of concern that may
                                        require Regional office attention, consistent
                                          with the focus of the National Program.
                                                                                                  Section II, Page 10
                      Deletion - SAI deletion
                                         The Agency remains committed to SAI as
                                         an important tool for addressing the FY 11
                                           NPM priorities and helping growers
                                         transition to sustainable farming practices.
                                        We expect the regional and OPP investment
                                            in SAI will remain unchanged from
                                         previous years. However, we removed SAI
                                           as an NPM priority to streamline the
                                        guidance and make room for the addition of
                                            Antimicrobial Hospital Disinfectant
                                        	Efficacy priority.	
                                      Executive Summary, Page 4
Strategies
Addition: Soil Fumigants, Water Resources
In Worker Safety added a "soil fumigant
  outreach" component to the required
     outreach/education activities.
Section III, Page 13
  Attachment B: OCSPP Explanation of Changes between FY 2010 and FY 2011
                                                                                                        Page

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       Change from FY 2010 Guidance Document
                                                   Reason for Change
                                       Affected Pages and Sections
                                                        In Pesticides and Water Resources, added a
                                                          section to address activities to support
                                                           implementation of pesticide NPDES
                                                            permits, such as offering technical
                                                        assistance to the Regional Water Programs
                                                           on draft and final permits or routine
                                                          outreach and distribution of materials
                                                        provided by EPA or the State/Tribal Water
                                                         Agencies to educate pesticide users who
                                                       	may fall under the new permits.	
                                                                                      Section VI, Page 24
   Annual
Commitment
  Measures
               Addition:

 ACS Measure 14 - Number of abatement
 activities performed by certified abatement
 workers occurring in the Regions. [Non-
	Commitment Measure]	
 These measures underwent a measures
  review by a workgroup with HQ and
regional members; and the final decision
was supported by the Regional Division
Directors (RDD) during a RDD meeting.
Section I, Page 6
                             Deletions:

                 ACS Measure 11 A- Number of active
               individual certifications for lead-based paint
                abatement activities in the Region. [Non
              	Commitment Measure]	
                                           These measures underwent a measures
                                            review by a workgroup with HQ and
                                          regional members; and the final decision
                                          was supported by the Regional Division
                                          Directors (RDD) during a RDD meeting.
                                        Executive Summary, Page 4
                             Deletions:

                ACS Measure 12 - Cumulative number of
                 authorized state and tribal programs for
                abatement lead-based paint professionals.
                                                                                  Executive Summary, Page 4
   Attachment B: OCSPP Explanation of Changes between FY 2010 and FY 2011
                                                                                                          Page

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    Change from FY 2010 Guidance Document
Reason for Change
Affected Pages and Sections
                         Deletions:

            ACS Measure 12B - Cumulative number of
            authorized state and tribal RRP Programs in
            the Regions. [Non Commitment Measure]
                              Executive Summary, Page 4
                         Deletions:

              ACS Measure 21- Number of outreach
             partnerships addressing lead based paint
           hazards and reductions. [Senior Management
          	Measure]	
                              Executive Summary, Page 4
                         Deletions:

           ACS Measure SAI1- Average percent change
               in the utilization of reduced risk pest
               management practices over time as
            determined by the SAI Transition Gradient
                         Deletions:

               ACS Measure SAI2- Number of SAI
            collaborative actions contributing towards
               partnerships key to U.S. agriculture's
            transition towards sustainable reduced-risk
           pesticide management technologies. [Senior
          	Management Measure]	
                              Executive Summary, Page 4
                              Executive Summary, Page 4
Attachment B: OCSPP Explanation of Changes between FY 2010 and FY 2011
                                                                                                     Page

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    Change from FY 2010 Guidance Document
          Reason for Change
Affected Pages and Sections
              Modification (See underlined addition):

            ACS Measure WPCT- Number of Region-
           specific projects or initiatives contributing to
            the implementation and enhancement of the
           worker protection and C&T field programs.
Consistent with results of Regional and OPP
effort to review and streamline the pesticide
human health measures, the Worker Safety
 measures were combined (WP1 and CT1)
          into a single measure.
    Section III, Page 14
               Modification (See underlined edit):

            ACS Measure 13 A - Annual percentage of
               viable lead-based paint certification
            applications that require less than 20 days of
            EPA Regional effort to process  (For Direct
            Implementation - Regional Office efforts)
      Edit made to clarify measure.
      Section I, Page 6
               Modification (See underlined edit):

            ACS Measure 13B - Annual percentage of
               viable lead-based paint certification
              applications that require less than state-
              established timeframes to process (for
                authorized States] t
      Edit made to clarify measure.
      Section I, Page 6
                                       (,   t
                     Performance Measure]
Attachment B: OCSPP Explanation of Changes between FY 2010 and FY 2011
                                                                                                        Page

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     Change from FY 2010 Guidance Document
                                             Reason for Change
Affected Pages and Sections
                 Modification (See underlined edit):

              ACS Measure 15B - Number of outreach
               products produced [e.g., web products,
              written publications (fact sheets, booklets,
              reports), exhibits, training packages, mass
               mailings (electronic or US Postal mail)
                       addressing asbestos.
                                         Edit made to clarify measure.
      Section I, Page 6
Tracking
 Process
 Contacts
Modification:  Edit contact info
                                                       Mike Burns is currently the Acting Branch
                                                        Chief/Acting Deputy Director for EAD;
                                                       the Division manages the NPM Guidance
                                                                 process for OPPT.
                                                       Tala Henry is currently the Acting Deputy
                                                       Director for NPCD; her division leads the
                                                          Lead Risk Reduction Program and
                                                         Chemical Risk Management Program.
 Executive Summary, Page 5
 Attachment B: OCSPP Explanation of Changes between FY 2010 and FY 2011
                                                                                                        Page

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